Multiple CVs sent to same Job Spec

A friend is currently looking for a job. He found out today when speaking to a recruitment agency that when they tried to submit his CV for a job, they already had two other copies of his CV from other agencies.

He has spoken to multiple agents about this job but hadnt decided on whether he wanted to apply so asked for them not to send the CV through

Does he have any recourse?
He is worried about what else they may have done without his permission and is unsure as to the next course of action

SLS, theoretically it's a breach of the Data Protection Act sending your personal information without your permission.
Contact: info@dataprotection.ie
Case Study: [broken link removed]
If you know who the agencies are, I'd check www.nrf.ie to see if they're members and if so quote the code of conduct:
at both the MDs of the agencies and the NRF.
"(c) Applicants must be given full details of any job for which the agency intends to recommend them and permission must be sought from the applicant. An applicant's permission must be sought and obtained before his or her details are revealed to an employer. The agency should also determine whether or not the applicant has been approached by another agency about the same job."

However, it can be toothless. As far as I'm aware there is only one recruitment company in Dublin that has a clause written into it's handbook stating that sending CVs without permission is deemed gross misconduct and as such a sackable offence. The bad news however is that sending CVs without permission is a symptom of race to the bottom type "recruitment" in this recession, and the previous downturn etc.

Love to know how you get on but feel free to PM me if I can advise further.
K