A Recruiter is only allowed to do a reference on you if you have given permission. But be warned if it’s on your CV then technically speaking permission has been given and they may phone before your interview and before your chance to explain your situation!
Recruiters usually won’t want to speak to your current employer (and jeopardise your current employment in any way) but be warned they will phone the company and without saying who they are ask to speak to you, just to ensure that you are still employed there!
There are very few situations where a Recruiter will do a reference, with a family member, colleague or teacher especially if you have work experience. Ideally they will want two good references with your manager or above. Even if they phone your Referee on a cell phone a good Recruiter will always phone the company to confirm with a third party that your referee was in fact a manager at that company! (You would be surprised how many times I have caught candidates out with that one!)
When it comes to references you always have to ask yourself; has your referee agreed to vouch for you and can you guarantee that they will only say nice things about you? Keep in contact with them, send Christmas and birthday messages every year and if you think a Recruiter is about to phone, then give them a call to say hi and enquire if they will still vouch for you. It is not a guarantee but there is less chance of them saying horrible things about you if you have just spoken to them. You have also just created an opportunity to remind them how fantastic you were and what your achievements were when you worked with them!