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Privacy Policy

Last updated: August 2026

1. Who we are

Recruitment Agency Sales is the specialist recruitment-sector business brokerage service operated by Jonathan Fagan Business Brokers Limited.

We provide business sale, acquisition, valuation and related advisory services to owners and prospective buyers of recruitment businesses.

For the purposes of UK data-protection law, Jonathan Fagan Business Brokers Limited is generally the data controller for the personal information described in this Privacy Policy. This means that we determine why and how that personal information is used.

Our contact details are:

Recruitment Agency Sales
Jonathan Fagan Business Brokers Limited
College House, 2nd Floor
17 King Edwards Road
London
HA4 7AE

Telephone: 0800 246 5016
Email: info@recruitmentagencysales.com

Website: www.recruitmentagencysales.com

We are registered with the Information Commissioner’s Office where required under UK data-protection legislation.

2. What this Privacy Policy covers

This Privacy Policy explains how we collect, use, store and disclose personal information when you:

  • contact us;
  • register as a buyer;
  • list a recruitment agency or other business for sale;
  • request a valuation;
  • instruct us to provide brokerage or advisory services;
  • enquire about a business for sale;
  • sign a confidentiality agreement or NDA;
  • participate in a proposed acquisition or sale;
  • subscribe to business-for-sale or other relevant updates;
  • communicate with us by telephone, email, online form or video call;
  • attend a webinar or event;
  • visit our website.

It also explains your rights under UK data-protection law.

3. What personal information we collect

The information we collect depends on your relationship with us.

Buyers and prospective buyers

We may collect:

  • your name;
  • business or employer name;
  • job title;
  • postal address;
  • telephone number;
  • email address;
  • geographical location;
  • acquisition criteria;
  • sectors of interest;
  • preferred business size;
  • budget or funding information;
  • details of businesses in which you have expressed an interest;
  • correspondence and notes of conversations;
  • information supplied when signing an NDA;
  • information about previous or proposed transactions;
  • information relevant to assessing whether you are a genuine and suitable prospective buyer.

Where necessary, we may also ask for evidence of identity, funding or authority to act.

Sellers and prospective sellers

We may collect:

  • your name;
  • business name;
  • job title or relationship to the business;
  • telephone number;
  • email address;
  • postal address;
  • details of your recruitment agency;
  • shareholding and ownership information;
  • information about directors, shareholders and key employees;
  • financial and management information;
  • information about clients, suppliers, employees and contractors where relevant to a proposed transaction;
  • reasons for sale and preferred timescale;
  • valuation information;
  • offers and proposed deal structures;
  • correspondence and transaction history.

Where possible, information about a business will be anonymised before it is provided to prospective buyers unless disclosure has been authorised.

Website visitors and general enquiries

We may collect:

  • your name;
  • email address;
  • telephone number;
  • IP address;
  • browser and device information;
  • information submitted through website forms;
  • records of pages visited or website interactions, where collected through permitted analytics or cookies;
  • any information included in your correspondence with us.

4. Information about other people

Information provided to us during a business sale or valuation may contain personal information about other individuals, including:

  • directors;
  • shareholders;
  • employees;
  • recruitment consultants;
  • contractors;
  • clients;
  • candidates;
  • suppliers;
  • professional advisers.

If you provide us with information about another individual, you are responsible for ensuring that you are entitled to provide it and, where required, that the individual has been given appropriate privacy information.

We encourage sellers to provide aggregated or anonymised information wherever possible, particularly during the early stages of marketing a business.

Candidate databases, CVs and unnecessary personal information about candidates should not normally be supplied to us as part of initial sale discussions.

5. How we obtain personal information

We may receive personal information:

Directly from you

For example when you:

  • complete a form;
  • send an email;
  • telephone us;
  • register as a buyer;
  • list a business for sale;
  • request a valuation;
  • participate in a transaction;
  • attend a meeting, webinar or event.

From other parties to a transaction

We may receive information from:

  • business owners;
  • prospective buyers;
  • shareholders;
  • directors;
  • solicitors;
  • accountants;
  • financial advisers;
  • lenders;
  • corporate finance advisers;
  • other professional advisers.

From publicly available sources

Where appropriate, we may obtain information from sources such as:

  • Companies House;
  • company websites;
  • LinkedIn and other professional networking services;
  • professional directories;
  • publicly available business information;
  • other lawful public sources.

Where we obtain personal information indirectly, we use it only where we have a lawful basis to do so.

6. Why we use your personal information

We may process personal information for the following purposes.

To respond to enquiries

We use information you provide to:

  • respond to questions;
  • arrange telephone or video calls;
  • provide information about our services;
  • assess whether we can assist you.

Our lawful basis will usually be legitimate interests or taking steps at your request before entering into a contract.

To provide brokerage, valuation and advisory services

We use personal information to:

  • discuss potential business sales or acquisitions;
  • prepare valuations;
  • prepare confidential sales information;
  • identify appropriate prospective purchasers;
  • arrange introductions;
  • manage buyer enquiries;
  • coordinate meetings;
  • assist with negotiations;
  • maintain transaction records;
  • liaise with professional advisers;
  • support transactions through to completion.

Where you have instructed us, processing will normally be necessary for the performance of our contract with you or to take steps at your request before entering into a contract.

We may also process information where necessary for our legitimate interests in operating a specialist business brokerage service.

7. Buyer registrations and acquisition opportunities

If you register as a buyer, we use the information you provide to:

  • maintain your buyer profile;
  • match your acquisition criteria with relevant businesses;
  • contact you about businesses that may be of interest;
  • provide updates about opportunities coming to market;
  • respond to expressions of interest;
  • administer confidentiality agreements and introductions.

We currently invite buyers to register free of charge to receive information about recruitment businesses available for acquisition. (Recruitment Agency Sales –)

Where communications relate directly to the service for which you registered, we rely on our contractual relationship or legitimate interests as appropriate.

Where a communication constitutes direct marketing, we will comply with applicable UK data-protection and electronic-marketing rules.

You may ask us to stop sending marketing communications at any time.

8. Sellers and confidential business information

We recognise that information concerning the proposed sale of a recruitment agency is commercially sensitive.

Where you list a recruitment agency with us, we may use information about the business to prepare an anonymous or confidential sales profile.

Identifying information will normally be provided to an interested buyer only where:

  • we consider disclosure appropriate;
  • the buyer has expressed a genuine interest;
  • appropriate confidentiality arrangements have been made where required; and
  • disclosure is consistent with our instructions from the seller.

The website currently states that businesses can be listed confidentially and that sellers are not charged an introduction fee under the standard model. (Recruitment Agency Sales –)

A seller should not provide highly sensitive employee, candidate or client-level personal data at an early stage unless it is genuinely required.

9. Our lawful bases for processing

Depending on the circumstances, we may rely on one or more of the following lawful bases:

Contract

Processing is necessary to enter into or perform a contract with you.

Examples include:

  • carrying out a valuation;
  • acting on a business sale;
  • making an acquisition introduction;
  • administering an agreed buyer introduction fee.

Legitimate interests

We may process information where necessary for our legitimate business interests, provided those interests are not overridden by your rights.

These interests may include:

  • operating and developing our brokerage business;
  • matching buyers and sellers;
  • responding to enquiries;
  • maintaining business relationships;
  • keeping records of transactions and introductions;
  • establishing, exercising or defending legal claims;
  • preventing fraud or misuse;
  • maintaining website and information security;
  • improving our services.

Legal obligation

We may process information where necessary to comply with a legal or regulatory requirement.

Consent

Where we specifically rely on consent, you may withdraw it at any time.

Withdrawal does not affect processing that took place lawfully before consent was withdrawn.

10. Special-category and sensitive information

Our normal services do not require us to collect special-category personal data about buyers or sellers.

However, information supplied during a transaction may occasionally contain sensitive personal information.

We ask customers not to provide special-category data unless it is genuinely necessary.

Where such information must be processed, we will ensure that an appropriate lawful basis and additional condition are available under applicable data-protection law.

11. Who we share information with

We do not sell personal information to third parties.

We may disclose information where reasonably necessary to:

  • prospective buyers;
  • sellers;
  • parties to a proposed transaction;
  • solicitors;
  • accountants;
  • tax advisers;
  • corporate finance advisers;
  • lenders and funding providers;
  • IT and website providers;
  • secure document or file-sharing providers;
  • email and communications providers;
  • CRM or database providers;
  • accounting providers;
  • professional advisers;
  • insurers;
  • regulatory, governmental or law-enforcement bodies where legally required.

We disclose only information that is reasonably necessary for the relevant purpose.

Where a service provider processes personal information on our behalf, we take reasonable steps to ensure that appropriate contractual and security arrangements are in place.

12. Confidentiality

Confidentiality is particularly important in business-sale transactions.

We use procedures designed to restrict access to information to those who require it for legitimate business purposes.

Depending on the transaction, prospective buyers may be required to agree to confidentiality terms before identifying or commercially sensitive information is provided.

Confidentiality agreements do not replace our obligations under UK data-protection law.

13. Security

We use appropriate technical and organisational measures intended to protect personal and confidential information against:

  • unauthorised access;
  • accidental loss;
  • misuse;
  • alteration;
  • disclosure;
  • destruction.

Our security arrangements include access controls and other technical and organisational safeguards appropriate to the nature of the information we process.

No internet or electronic storage system can be guaranteed to be completely secure.

14. How long we keep information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, including legal, accounting, contractual and dispute-resolution requirements.

Our retention periods may therefore differ depending on the information concerned.

As a general framework:

General enquiries

Usually retained for up to 5 years after the last meaningful contact.

Buyer registrations

Retained while the buyer remains registered and actively interested in acquisitions, with inactive records periodically reviewed.

Seller and transaction records

Normally retained for 6 years after the conclusion, abandonment or termination of the relevant transaction or instruction, where appropriate for contractual, evidential and legal purposes.

Financial and accounting records

Retained for the period required by applicable tax and company legislation.

Marketing records

Retained until you unsubscribe or we determine that continued retention is no longer appropriate, subject to retaining limited suppression information so that we can respect an unsubscribe request.

We may retain information for longer where:

  • litigation or a dispute is anticipated or ongoing;
  • required by law;
  • necessary to establish or defend legal rights.

15. International transfers

Some third-party technology providers may process or store personal information outside the United Kingdom.

Where this involves a restricted international transfer, we will take appropriate steps required by UK data-protection legislation, which may include:

  • transfer to a country covered by UK adequacy regulations;
  • use of approved contractual safeguards; or
  • another lawful transfer mechanism.

You can contact us for further information about safeguards applying to relevant international transfers.

16. Direct marketing

We may contact existing or prospective business customers about:

  • recruitment businesses for sale;
  • buyer opportunities;
  • valuation services;
  • relevant brokerage services;
  • webinars;
  • market information;
  • related services that we reasonably believe may be relevant.

We will comply with applicable UK rules concerning electronic marketing.

You may object to direct marketing at any time.

You can:

If you unsubscribe, we may retain your email address on a suppression list to ensure that we do not inadvertently send further marketing.

17. Cookies and website analytics

Our website may use cookies and similar technologies.

Cookies can be used for purposes including:

  • essential website operation;
  • security;
  • remembering preferences;
  • measuring website usage;
  • analytics;
  • other optional functionality.

Where consent is legally required for a non-essential cookie, it should not be set until appropriate consent has been obtained.

Details of the cookies currently used should be shown through the website’s cookie-management tool or separate Cookie Policy.

You can change your cookie choices using the cookie settings available on the website.

18. Links to other websites

Our website contains links to websites operated by third parties.

We are not responsible for the privacy practices, content or security of third-party websites.

You should review the privacy information on any third-party site before providing personal information.

19. Your data-protection rights

Depending on the circumstances, UK data-protection law may give you the right to:

Be informed

You have the right to be told how your personal information is being used.

Access your information

You may request a copy of personal information that we hold about you.

Rectification

You may ask us to correct inaccurate or incomplete personal information.

Erasure

In some circumstances you may ask us to delete your personal information.

Restriction

You may ask us to restrict the way in which we use your information in certain circumstances.

Object

You may object to processing based on legitimate interests in certain circumstances.

You have an absolute right to object to personal information being used for direct marketing.

Data portability

In certain circumstances you may ask for personal information you provided to us to be transferred to you or another organisation in a structured, commonly used and machine-readable format.

Withdraw consent

Where processing is based on consent, you may withdraw that consent. These rights are not absolute and exemptions may apply.

The ICO confirms that controller status carries responsibility for complying with individuals’ rights and the wider UK GDPR requirements. (ICO)

20. Exercising your rights

To exercise a data-protection right, contact:

Email: info@recruitmentagencysales.com

Please state clearly:

  • your name;
  • the right you wish to exercise;
  • sufficient information to identify the relevant records.

We may need to verify your identity before releasing personal information.

There is normally no charge for exercising your rights, although the law permits fees or refusal in limited circumstances involving manifestly unfounded or excessive requests.

21. Automated decision-making

We do not normally make decisions about individuals that produce legal or similarly significant effects solely by automated processing.

Buyer and seller suitability, introductions and transaction decisions involve human assessment.

If this changes materially, this Privacy Policy will be updated.

22. Children

Our brokerage and valuation services are intended for businesses and adults acting in a professional or commercial capacity.

We do not intentionally collect personal information from children through the website.

23. Complaints

If you have concerns about how we have used your personal information, please contact us first so that we can investigate.

You also have the right to complain to the UK’s independent data-protection regulator:

Information Commissioner’s Office (ICO)

The ICO provides information about data-protection rights and complaints on its website.

24. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect:

  • changes in law;
  • regulatory guidance;
  • changes to our services;
  • changes to our systems or suppliers;
  • changes in the way we process information.

The latest version will always be published on this page.

Last updated: August 2026