TMM Executive

Privacy Policy

We are committed to ensuring that your privacy is respected and maintained at all times.

This privacy notice explains how Thorpe Molloy McCulloch Recruitment Ltd (TMM Recruitment), and its affiliated entities, use any personal information we collect about you when you use our services or websites.

TMM Recruitment (the Company) is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.

You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with this privacy statement. At all times we will comply with current data protection laws.

1. Collection and Use Of Personal Data

a. Purpose of processing and legal basis

The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients.

If you have opted-in we may also send you marketing information and news via email/ text. You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us.

In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

We must have a legal basis to process your personal data. The legal bases we rely upon to offer our work-finding services to you are:

  • Your consent;
  • Where we have a legitimate interest;
  • To comply with a legal obligation that we have;
  • To fulfil a contractual obligation that we have with you.

TMM Recruitment undertakes to use all information responsibly. Any information collected and stored will be of the following kind:

  • Activity on our website, including visits from third party sites.
  • Information provided for the use of registering as a work-seeker and / or subscribing to our Role Alert service.
  • Information provided for business purposes, industry analysis or internal statistics.
  • Information provided for contacting you directly.
  • Information provided for our marketing activities and keeping you informed about our services.
  • In connection with any legal proceedings or prospective legal proceedings.
  • In order to establish, exercise or defend our legal rights.

b. Legitimate interest

This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

  • Managing our database and keeping work-seeker records up to date;
  • Providing work-finding services to you and our clients;
  • Contacting you to seek your consent where we need it;
  • Giving you information about similar products or services that you have used from us recently.

c. Statutory/contractual requirement

The Company has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements.) Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you do not give us personal data we need to collect we may not be able to continue to provide work-finding services to you.

d. Recipient/s of data

The Company will process your personal data and/or sensitive personal data with the following recipients:

  • Clients (whom we may introduce or supply you to).
  • Former employers whom we may seek references from.

TMM Recruitment will process your personal data and/or sensitive personal data only with our clients that we provide work finding services too. TMM Recruitment will not provide any personal information to a client and/or third party (except as provided in this policy and our cookie policy) unless you have given your consent.

2. Role Alerts

To subscribe to Role Alerts emails, you will be required to provide your first name, surname and e-mail address, which will be used for the purpose of keeping you informed, by e-mail, of the latest jobs. Should you decide that you no longer wish to receive this information, unsubscribe links are provided in every role alert email that you receive. If you do not verify your job alert subscription your data record will be deleted 30 days after the verification email was sent to you. If you cancel your role alert subscription your data record will be deleted 30 days after you took action to cancel your subscription.

3. Oversea Transfers

The Company may transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

4. Data Retention

The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time. For example, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.

We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. This is currently 3 to 6 years.

Where we no longer need to process your personal data for the purposes set out in this Privacy Policy, or we have had no meaningful contact with you over the past 5 years we will delete your personal data from our systems.

Where permissible, we will also delete your personal data upon your request. Information on how to make a deletion request can be found in section 5 below.

Website records for Talk With Us calls to action will be deleted from our web hosting secure servers 30 days after the records were uploaded. Online Registration Form records will also be deleted from our web hosting secure servers 30 days after the completed registration form is submitted. The web records for registration forms which have been generated but not accessed, or accessed and only partially completed, will be deleted from our web hosting secure servers 30 days after the registration form link was generated.

5. Your Rights

Please be aware that you have the following data protection rights:

  • The right to be informed about the personal data the Company processes on you;
  • The right of access to the personal data the Company processes on you;
  • The right to rectification of your personal data;
  • The right to erasure of your personal data in certain circumstances;
  • The right to restrict processing of your personal data;
  • The right to data portability in certain circumstances;
  • The right to object to the processing of your personal data that was based on a public or legitimate interest;
  • The right not to be subjected to automated decision making and profiling; and
  • The right to withdraw consent at any time.

Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting:

Mr Steve McCulloch
Associate Director and Head of Data Protection
01224 327 000
Email Steve

Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.

There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.

If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.

6. Collecting Data From Our Online Visitors

We gather information and statistics collectively about all visitors to our website. This includes information such as how you use our website, the most visited areas and frequency with which you access our website, and the times that our website is most popular.

We only use such data in the aggregate form. This information helps us determine what is most beneficial for our users and how we can continually improve our online services to create a better overall experience for our users.

Information on how this data is gathered and how you can opt-out is provided in our cookie policy.

7. Links to external websites

The Company’s website may contains links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website.

8. Equal Opportunities

The Company is an equal opportunities employer and a company committed to diversity. This means that all job applicants and members of staff will receive equal treatment and that we will not discriminate on grounds of gender, marital status, race, ethnic origin, colour, nationality, national origin, disability, sexual orientation, religion or age. As part of our commitment to equal opportunities we may from time to time use information provided by you for the purposes of diversity monitoring. All such information will be used on an anonymised basis.

9. Sale of Business

If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.

10. Safeguarding Your Data

We care about protecting your information and are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures that are designed to prevent unauthorised access to, and misuse of, your personal data. The Company cannot guarantee the security of data sent over the internet.

11. Changes To This Privacy Policy

We will update this privacy policy from time to time. We will post any changes on the policy with revision dates. If we make any material changes, we will notify you.

12. Complaints or Queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact:

Mr Steve McCulloch
Associate Director and Head of Data Protection
01224 327 000
Email Steve

You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or here, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.

Rev 01. April 2021

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