Privacy notice
Version 2.10, effective 18 October 2026
This notice explains what personal data CargoCrew Ltd collects about drivers who register with us, why, who sees it, how long we keep it and your rights. It also covers visitors to this website and people who use our contact and invitation forms. The section numbers are referred to from the registration pack, the terms of engagement and the driver handbook.
1. Who we are
CargoCrew Ltd is an employment business supplying temporary HGV drivers to transport and logistics clients. We are the data controller for the information described in this notice. Company number 16006700. Registered office: 124 City Road, London, EC1V 2NX. Information Commissioner's Office registration ZB822403.
Questions about this notice and requests about your data go to our compliance team: [email protected], 0333 335 7199, or by post to the registered office.
2. What we collect
Almost everything we hold comes from you, through the registration pack and your account, from the referees you name, and from the checks described in section 3.
- Identity and contact: name, former names, date of birth, gender, nationality, address and address history for the last five years, a proof of address (a recent statement or bill), phone, email, emergency contact, and your registration photo.
- Right to work: your passport details and a copy of the photo page, and for non-British and non-Irish nationals your share code, the result of the online check and the date any permission ends.
- Driving: licence number, check code, categories and expiry dates, Driver CPC and tachograph card details, ADR, penalty points, disqualifications, collisions, pending prosecutions and other work you do. The licence, card and certificate details are read from the documents you upload instead of being typed, and a member of our compliance team checks every value against the image; points and entitlements come from the DVLA licence check. Before a photo is read we check that it shows the document asked for, and where it shows more than one we cut each document out of it; your original photo is kept unchanged as the record of the check.
- Five-year history and references: each period of employment, self-employment, study, unemployment or break, the referees you name, their replies, and the records of how we verified them.
- Payroll: National Insurance number, P45 or starter checklist answers, student loan plan, bank account, holiday pay choice, and if you register one, your limited company's details, Companies House record, certificate of incorporation, VAT number and VAT registration certificate, and bank account.
- Health: your answers to the five DVLA Group 2 questions on the Medical tab, including whether you have a short-term lorry licence for medical reasons and whether you have notified DVLA of a condition, as required by law; anything you choose to tell us about adjustments or about being a new or expectant mother; and, if you take it, the night worker health assessment, including the yearly re-offer (section 4).
- Criminal record: your declaration of unspent convictions and the basic criminal record certificate you provide (section 4).
- Training and documents: the manual handling confirmation, knowledge assessment result, the certificates you upload, and any other documents you choose to add.
- CargoCrew ID: the photo, ID number, issue and expiry dates and the log of when it was issued, shown and returned.
- Signing records: for every document you sign, the signature image, the time (UTC), your verified email address, IP address, browser, the document version and a hash of its text.
- Assignments and pay: assignment confirmations and your acceptance of them (time, IP address and browser), timesheets, pay and holiday records.
- Website and account: the sign-in codes we email you, your saved draft, and the technical data in section 10.
3. Why we use it and our lawful bases
We check every driver to our pre-employment standards: five-year verified history, address history, references, a basic DBS and cargo security training. We carry out these checks, keep the records, and issue you a CargoCrew ID card showing you have been checked. A client's security or compliance team may inspect the records. An airport pass is only needed for airside work and is applied for by the client, not by us.
We use your data to register you, verify your identity, right to work, licence, qualifications and five-year history, issue your CargoCrew ID, offer you assignments, confirm them in writing, pay you, meet our duties as an employment business and keep the records those duties require.
The lawful bases (UK GDPR article 6) are:
- Contract: agreeing and performing your terms of engagement, confirming assignments and paying you.
- Legal obligation: the Conduct of Employment Agencies and Employment Businesses Regulations 2003 (verifying identity, experience and qualifications and keeping records), right to work checks under the Immigration, Asylum and Nationality Act 2006, PAYE and pension duties, the Working Time Regulations 1998 and Road Transport (Working Time) Regulations 2005, and the Agency Workers Regulations 2010.
- Legitimate interests: verifying your five-year history and address history to our pre-employment standards, keeping the records a client may inspect, issuing and managing your CargoCrew ID, preventing fraud and misuse of the registration service, and running and securing this website. Where we rely on legitimate interests we have considered your interests and rights and the checks are no wider than the work we place you in requires.
- Consent: only where we say so, for example the DVLA licence check mandate, which lasts three years and which you can withdraw at any time (although we cannot place you on driving assignments without a current check).
We do not make decisions about you by automated means. Every decision on your suitability is made by a named member of our compliance team.
4. Health and criminal offence data
Health data. The Medical tab asks five questions to check you meet the DVLA's medical standard for lorry drivers: whether your Class 1 licence is expired, suspended or restricted, whether the DVLA has given you a short-term lorry licence for medical reasons, whether the DVLA has ever refused, taken away, added conditions to or shortened your lorry licence for a health or medical reason, whether you have notified DVLA of a condition, as required by law, and whether anything affects getting into and out of a cab or securing a load by hand. The date your lorry entitlement runs to is read from your licence, not asked, and the renewal cycle that applies at your age is worked out from your date of birth. We do not ask what any condition is. You can also choose to tell us that you would like to discuss adjustments, or that you are pregnant, have given birth in the last six months or are breastfeeding so that we can carry out a risk assessment; you do not have to, and an unticked box records nothing. The night worker health assessment is offered under regulation 7 of the Working Time Regulations 1998, when you register, once a year afterwards and before your first night assignment if you have not taken it; you can take it or decline, and we record each offer and your choice with a timestamp either way. We process this data under UK GDPR article 9(2)(b) and paragraph 1 of Schedule 1 to the Data Protection Act 2018 (employment and health and safety obligations), with an appropriate policy document in place.
These answers are kept in a separate health record, apart from the rest of your registration pack. Where you take the night worker assessment we keep your answers with it, because they are what a health professional reviews if an answer is yes. A client is told only the outcome (fit for night work, or further assessment needed), never your answers.
Criminal offence data. We ask about unspent convictions because they must be declared for the security checks we carry out, and we receive the basic criminal record certificate you obtain. We process this under UK GDPR article 10 and paragraph 1 of Schedule 1 to the Data Protection Act 2018. An unspent conviction does not automatically exclude you. Once a client has recorded its acceptance of you, we delete our copy of the certificate and keep only its date, reference number and outcome.
Health and criminal offence data are seen only by the compliance team and, for health data, any health professional we ask to review it. A yes answer leads to a conversation with you, not a rejection.
5. Who we share it with
We never sell your data. We share it only as follows.
- Clients: a client's security or compliance team may inspect the records of your checks before you work on their site and receives your assignment schedule, which includes your name, CargoCrew ID, the engagement route, your Conduct Regulations choice where a limited company is involved, and the outcome of your night work assessment where night work is involved. The client is a separate controller of what it receives, under its own privacy notice. An airport pass, where airside work needs one, is applied for by the client, not by us; we provide the client with the records it needs for that application.
- Referees: each referee you name receives your name, date of birth and the period they are asked about, with a copy of your signed authorisation.
- Government bodies: HM Revenue & Customs (payroll), the Home Office (right to work checks), the DVLA (licence checks), the Pensions Regulator and our pension provider, and regulators or law enforcement where the law requires.
- Service providers acting on our instructions: our hosting and database provider (Supabase, London region), our website host (Netlify), our email provider, Amazon Web Services (reading the details from the documents you upload, processed in the UK or the EU; it does not keep the images or use them to train its systems), Companies House for limited company checks, an identity verification provider where you choose the online passport check, and our accountants and professional advisers. Each is bound by a contract that limits what it may do with your data.
- Nobody else, unless you ask us to or the law requires it.
6. How long we keep it
We keep your data for as long as you are registered with us and for the periods below afterwards, then delete or anonymise it.
| What | How long | Why |
|---|---|---|
| Registration pack, signed documents and the record of each check | The length of your engagement and three years after your last assignment | Conduct Regulations record keeping and our pre-employment standards, which require the record of every verification step to be kept for the length of the engagement |
| CargoCrew ID card: photo, ID number, expiry and the issue log | Three years after your last assignment | To show a client when you were checked and that the ID was withdrawn when you left |
| Health answers, anything you told us about adjustments or pregnancy, and the night worker assessment | Three years after your last assignment | Working Time Regulations and health and safety records, and any adjustments we agreed |
| Basic criminal record certificate copy | Until a client records its acceptance of you, then deleted; the date, reference and outcome are kept with the pack | Data minimisation |
| Reference requests and replies | With the pack, as above | Evidence of verification |
| Payroll, timesheets and pay records | Six years after the end of the tax year they relate to | HMRC requirements |
| Assignment confirmations and your acceptance | Six years after the assignment | Contract records and the Agency Workers Regulations |
| Right to work check evidence | Two years after your engagement ends | Home Office requirement |
| Drafts of a registration never submitted | Twelve months after the last change | Housekeeping |
| Invitation requests and contact form messages | Twelve months | To answer you and keep a record of what was asked |
| Form protection counters: a scrambled (hashed) form of your IP address, or of your invitation link, and how many forms were sent from it in the hour | Two days | To stop repeated or automated form submissions |
7. Where it is stored
Your data is stored in the United Kingdom and the European Economic Area. Where a provider processes data outside the UK we rely on the UK's adequacy regulations or the International Data Transfer Agreement, and you can ask us for details.
8. Security
Your pack and documents are held in a private store that only our named office accounts can reach, with multi-factor authentication on those accounts. Sign-in uses one-time codes sent to your email, with no passwords to lose. Documents are served through time-limited links. Every signed document carries a fingerprint so that a copy can be checked against the one we issued. Our staff see only what their role needs.
9. Your rights
You have the right to ask for a copy of your data, to have it corrected, to have it deleted where we no longer need it, to restrict or object to how we use it, to receive the data you gave us in a portable form, and to withdraw any consent you have given. Email [email protected]; we answer within one month. You can also complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113.
10. Cookies and local storage
This website sets no advertising or analytics cookies and loads no tracking scripts from Google, Meta, Microsoft Clarity, Hotjar or similar services. It stores the following in your browser, all of which are needed for the site to work:
| Name | Type | What it does | How long |
|---|---|---|---|
| cargocrew.session | Local storage | Your sign-in token for the registration account or office dashboard, so you stay signed in between pages | Until you sign out, or the session expires |
| cargocrew.registration.v2 and cargocrew.registration.v2.tab | Local storage | A copy of your registration draft and the tab you were on, so nothing is lost if the connection drops | Until the pack is submitted or you sign out |
| cargocrew.invite | Local storage | The code from your invitation link, so you can submit your pack after a refresh or a later visit on the same device | Until the pack is submitted, or the link stops working |
| Cloudflare Turnstile | Third-party cookie or storage set by challenges.cloudflare.com | The bot check before you send any form on this site: the registration pack, the contact form, the knowledge assessment and the invitation request | Set by Cloudflare for the duration of the check |
No consent banner is shown because none of these is used for anything other than providing the service you asked for.
11. Changes to this notice
This is version 2.10, effective 18 October 2026. It replaces version 2.9: the address of this notice is now cargo-crew.co.uk/privacy, without "www"; nothing else has changed. Version 2.9 replaced version 2.8: section 10 says the bot check runs on every form on this site (the registration pack, the contact form, the knowledge assessment and the invitation request), not only on the registration pack and the contact form, and lists the invitation link code kept in your browser; section 6 lists the form protection counters. Version 2.8 replaced version 2.6: section 2 lists the proof of address every driver provides, the certificate of incorporation and VAT registration certificate for a limited company, and other documents you choose to add. Version 2.6 replaced version 2.5: section 2 said that licence, card and certificate details are read from the documents you upload and checked by our compliance team, and section 4 describes the revised DVLA Group 2 questions and the yearly re-offer of the night worker assessment. Version 2.5 replaced version 2.4: sections 2, 4 and 6 described the five DVLA Group 2 questions, the separate health record, and what you can choose to tell us about adjustments or being a new or expectant mother. Version 2.4 described the checks as our pre-employment standards. Version 2.3 described CargoCrew as supplying transport and logistics clients. Version 2.2 described the checks as our own requirement rather than our clients'. Version 2.1 updated section 4 for the shorter Medical tab and the night worker questions. Version 2.0 replaced version 1.0, with these main changes: a full description of the background checks we carry out and who may inspect them; the CargoCrew ID card; health and criminal offence data in their own section; a retention table; and the cookie and local storage table.
When we change this notice we publish the new version here with a new version number and date, and we tell registered drivers by email about any change that affects them. A copy of the version in force when you signed your registration pack is filed with your signed documents.
12. Contact
Compliance team, CargoCrew Ltd, 124 City Road, London, EC1V 2NX. [email protected]. 0333 335 7199.
Need to make a data protection request?
To see, correct or delete your data, or to ask anything about this notice, contact the compliance team. We answer within one month.
[email protected]