Thorpe Molloy McCulloch (TMM) Recruitment Ltd understands how important your privacy is and commits to ensuring that your privacy is respected and maintained at all times.

As a recruitment business, TMM Recruitment provides work-finding services to our clients and work-seekers, therefore we must process personal data (including sensitive personal data) in order to provide these services – in doing so, we are acting in the capacity of a data controller.

TMM Recruitment is committed to protecting the privacy of our candidates, clients and users of our website. We want to provide a safe and secure user experience. We will ensure that the information you submit to us via our website or through our office is only used for the purposes set out in this policy.

You may give your personal details to us directly, such as on an application or registration form or via our website, or we may collect them from another source such as a job board. We 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 the terms of the following statement.

1. Collection And Use Of Personal Data

a. Purpose of processing and legal basis

We 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. Depending on the circumstances more than one legal basis may apply. The legal bases we rely upon to offer this service to you in full are:

  • Consent
  • Legitimate Interest
  • Legal Obligations
  • Contractual Obligations

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. For more information please read our cookie statement.
  • Information provided for the use of registering as a work-seeker and / or subscribing to our Job Alert service.
  • Information provided for business purposes, industry analysis or internal statistics.
  • Information provided for contacting you directly.
  • Information provided for TMM Recruitment marketing activities and keeping you informed about TMM Recruitment services.
  • In connection with any legal proceedings or prospective legal proceedings.
  • In order to establish, exercise or defend our legal rights.

b. Legitimate Interest

Our legitimate interest in order to process your data is as follows:

We provide work finding services to both candidates and clients and therefore process personal data in order to be able to provide these services. We need to check the identity of candidates, their right to work and qualifications as well as process pay and manage entitlement to certain statutory rights. We therefore feel it is reasonable to conclude that processing personal data in order to provide work finding services is in the legitimate interests of all parties involved – the recruiter, the work-seeker and the client.

c. Recipient/s of data

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.

d. Statutory/contractual requirement

Your personal data could be required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are that we will be unable to provide work finding services to you.

2. Job Alerts

To subscribe to Job 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 in your nominated specialism. Should you decide that you no longer wish to receive this information, unsubscribe links are provided in every job 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 job alert subscription your data record will be deleted 30 days after you took action to cancel your subscription.

3. Overseas Transfers

TMM Recruitment may transfer only 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

TMM Recruitment will retain your personal data for as long as you maintain a record with us or as otherwise necessary to provide you our services. We will also retain your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

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.

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 Send Your CV and Submit A Vacancy calls to action and website records for Job Basket submissions 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 we process on you;
  • The right of access to the personal data we process 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 processing your personal data and sensitive personal data you have the right to withdraw that consent at any time. You can do this and also make a request for your personal data to be deleted by simply contacting us via:

TMM Recruitment
38 Albyn Place
AB10 1YN
01224 327 000
Email Us

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. Equal Opportunities

TMM Recruitment 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.

8. 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. TMM Recruitment cannot guarantee the security of data sent over the internet.

9. Change To Our Privacy Policy

Any changes to this Privacy Policy will be posted on this website so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any time we decide to use Personal Data in a manner significantly different from that stated in this Privacy Policy, or otherwise disclosed to you at the time it was collected, we will notify you by email, and you will have a choice as to whether or not we use your information in the new manner.

10. Complaints Or Queries

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

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

Should you feel your complaint went unresolved or was not dealt with effectively and believe your data protection rights have not been adhered to, you also have the right to raise concerns with the Information Commissioner’s Office here.

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