How long must a recruitment agency keep candidate and client records? One year under regulation 29, and the longer clocks on a temp's file

A recruitment agency must keep its records of candidates and clients for at least one year. Regulation 29 of the Conduct Regulations 2003 starts that year on the day each record is created and, for the details of a work-seeker or a hirer, again on the day the agency last provided them with its services. A temp's file also holds working time, right to work, payroll and minimum wage records, and those run for two, three and six years.

This guide covers Great Britain.

The periods, side by side

The fifth row belongs to the employment intermediary report. The right to work row applies to workers you employ; the right to work check router covers the check itself.

What regulation 29 covers

The regulation asks for records "sufficient to show" that the Act and the Regulations are being followed. GOV.UK lists them.

For each candidate you find work for, or try to:

• name, address and, if under 22, date of birth
• the terms between you, and any document changing them
• training, experience, qualifications and any authorisation, with copies of documents
• the engagements that result and when they start
• enquiries about the candidate and the position, with dates

For a temp, Schedule 4 adds the Key Information Document. For each client with a vacancy: the position, its likely length, the experience and qualifications required, enquiries made, and the dates of fee requests with copy invoices.

Regulation 29(3) says you need not keep these particulars for applications you take no action on, and GOV.UK's example is the speculative CV you never use.

Where the one-year clock starts

Every record must last a year from its creation. The particulars of a candidate or a client must also last a year from the date the agency "last provides services" to them.

For a client you still supply, the second clock has not started. For a temp who works for you on and off for three years, it starts when the last piece of work-finding is over. The regulation does not define the last service more closely, so write your own rule down.

One temp's file, with dates

A packer registers with you on Monday 2 March 2026. Her assignment runs from 16 March to Friday 11 September 2026. She is paid weekly, and her last pay period ends on Sunday 13 September. You look for more work for her until Wednesday 30 September 2026, when she takes a permanent job elsewhere and you issue her P45.

One folder holds five dates over five years. Timesheets are working time records for two years and part of the minimum wage record for six, so keep them for six. Deleting everything after a year would destroy the minimum wage records five years early, and GOV.UK says it is a criminal offence not to keep those for the required period.

The limit in the other direction

Regulation 29 sets a floor and data protection law sets a ceiling. The ICO's guidance on storage limitation says you must not keep personal data for longer than you need it. The UK GDPR sets no specific time limits, so you must be able to justify the period you choose, and the ICO expects a policy with standard retention periods.

For an agency that produces three groups:

1. Candidates you acted for. The periods in the table justify keeping the file until each end date.
2. Candidates you never acted for. No rule in the table makes you keep the CV. Pick a period you can justify and delete on time.
3. Candidates you placed permanently. You were never their employer, so the payroll and right to work periods are the client's. The one-year rule is yours.

Tribunal time limits are one reason to hold a placement file beyond the minimum, as our Employment Rights Act dates guide explains.

When an inspector asks

Since 7 April 2026 the Fair Work Agency has enforced the Conduct Regulations. GOV.UK says records an inspector asks for must be provided by the end of the second business day after the request: asked on Monday, due by the end of Wednesday. It says breaches are criminal offences with an unlimited fine, and that an inspector can seek a prohibition order through an employment tribunal. The standards for a gangmaster's licence carry the same one-year minimum.

A retention paragraph to copy

We keep the file of every candidate we seek work for, and of every client, for one year from our last service to them. For workers we employ we keep right to work copies for two years after they leave, payroll records for three years after the tax year ends, and minimum wage records, timesheets included, for six years. CVs we take no action on are deleted after [your period].

Overlyft can set up an AI Compliance Clerk that records each right to work check and diaries the end of its two-year retention period. This page is general information, not legal advice.