Overview 

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TCM Partners Privacy Policy sets out the ways in which we collect, process, and retain data including the personal data of candidates, clients, users of our websites, suppliers, and any third parties we may speak to, to carry out legitimate business services. Your privacy is important to us, and we are fully committed to safeguarding and protecting your data privacy rights. 

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We also use Trustpilot to gather and manage customer feedback to improve our services. This means that some of your personal data, such as your name and email address, may be shared with Trustpilot for the purpose of sending invitations to leave a review. Trustpilot operates as a data controller for this purpose, and we advise you to review their privacy policy for more information on how they handle your data. 

 

We collect personal data based on the lawful processing conditions set out in Article 6 of the General Data Protection Regulation (GDPR). The lawful bases we rely on for processing your personal data include:  

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• Consent: Where you have given consent for us to process your personal data. 

• Contractual Necessity: Processing necessary to fulfil a contract or steps prior to entering into a contract. 

• Legal Obligation: When processing is necessary to comply with the law. 

• Legitimate Interests: To fulfil our legitimate business interests, provided your rights and interests do not override these. 

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Information for Candidates 

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TCM aim to provide an excellent service to our candidates. To identify suitable job openings with a high degree of accuracy, we collect personal information which we only request, utilise, transfer, process, and store in line with the services we are providing and our legitimate business interests. 

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Relevant information is gathered at each stage of the process. This could include, but is not limited to, your name, address, telephone numbers, employment history, skills, attributes, salary, education details, qualifications, and details you may use in the future to log on to our website and/or recruitment database such as your username and password. 

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In addition, our clients may require us to carry out certain financial, criminal background, passport, compliance, or diversity checks to facilitate their own recruitment processes, due diligence, and compliance. In such circumstances, we will obtain your explicit consent to gather, utilise, transfer, process, store, and share this data. 

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Data that TCM holds about you may be shared with our clients or any other third parties as required, and with your express permission, for the purpose of facilitating the recruitment process. Candidates are advised to familiarise themselves with the data and privacy policies of any such third parties and contact them directly should they need any further support regarding their data. 

We retain candidate data for a period of 6 years from the date of our last interaction, unless there is a legal obligation or legitimate business interest that requires us to retain it for longer. 

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Information for Business Clients

 

For business clients, to provide an appropriate, efficient, and effective recruitment service, we need to collect, utilise, store, process, and transfer details about your organisation and its employees to aid us in fulfilling tasks in line with our services and legitimate business interests, including those of our candidates. This may include, but is not limited to, name, job titles, email addresses, and phone numbers of individuals within the organisation. 

Access to this data is strictly limited to authorised personnel who require it to deliver our services. 

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Information for our Suppliers 

 

For suppliers, we may need to collect, utilise, store, transfer, and process contact details of any individuals involved in the delivery of products and services to ourselves, together with the organisation and/or individual bank details required for us to be able to pay you. 

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Information for Website Users 

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To provide you with a better user experience and pursue our own legitimate business interests, TCM may collect, use, store, and transfer limited personal data about visitors to our website. This may include, but is not limited to, your IP address, browser type and version, and any associated plugins and versions, time zone settings and location, operating system and platform, and other technology related to the services you use to access the website and information on how you engage with the website (e.g., time spent on the website, number of visits, pages visited, etc.), according to your browser settings. 

 

We use Trustpilot to collect reviews from website users. Personal data such as your name and email address may be shared with Trustpilot solely for the purpose of collecting feedback on your experience with our website and services. 

 

Our website also uses cookies to track visitor behaviour and enhance the user experience. You can manage your cookie preferences via your browser settings.  

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Other Data Usage 

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TCM may also collect emergency contact information on behalf of a candidate or client, should it be required. This may include, but is not limited to, name, address, contact number, email, and/or job title where appropriate. 

 

As part of our reference-checking procedures, TCM may also collect information from a candidate or a member of staff to carry out these checks. This may include, but is not limited to, name, address, contact number, email, and/or job title where appropriate. 

 

Information and/or aggregated data for market research purposes may also be collected, used, stored, and transferred for future research, market insights, and to improve our services. 

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How do we collect data? 

 

Information about candidates is most frequently collected directly from our candidates to facilitate the recruitment process and provide the best service possible. 

 

Information may also be gathered from CVs submitted by our candidates, for example, in response to a direct message we may have sent via social media, or in response to an advertisement we may have placed on a job board, or social network such as LinkedIn, via our website, or via other social media platforms. 

 

We also gather information during phone calls, emails, and via direct messaging with our candidates and clients to facilitate the recruitment process. 

 

Should we be required by our clients to comply with their legal responsibilities and due diligence, information may also be gathered via third-party sources, for verification or vetting purposes, for which we obtain our candidate's consent in advance. Information may also be gathered from other interested parties, for example, those who may refer an individual they feel may be suited to a particular job opening. In this instance, contact is made with the individual concerned, and their consent is obtained to retain and/or use their data to facilitate the identification of suitable job openings. 

 

Information on our clients' organisation and the individuals it employs is generally gathered when TCM has been contacted directly by the client by phone, email, or via our website, or where candidates have supplied the information for the purposes of securing a reference in support of their job application process, or where TCM has initiated contact or market research to pursue its legitimate business interests or those of the clients in facilitating the recruitment process. 

 

Personal information about our suppliers is generally gathered directly from our suppliers when contact is initiated by either ourselves or the supplier to pursue their legitimate business interests, for example, to facilitate the provision of services. 

 

We automatically collect limited data in accordance with the cookie settings on your browser when you visit the TCM website. You can review and change your own browser settings in line with your privacy preferences. 

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How is your data used? 

 

Candidates 

 

Our goal in obtaining data from our candidates is to be able to provide them with an unrivalled recruitment service. The quality of information we obtain has a clear positive correlation with our ability to deliver an exceptional service. Candidates’ personal information will be stored and updated within our cloud-based recruitment system, which has in-built data compliance, alongside other third-party applications as strictly necessary to facilitate the recruitment process. Your data may be used to: 

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• Identify a match between your skills, experience, and/or assess your suitability for a particular role or roles. 

• Allow you to apply for jobs and to facilitate your application. 

• Apply for jobs on your behalf, with your express agreement. 

• Conduct research and gather insights into how we might improve our services. 

• Provide clients with an anonymised, aggregated snapshot of available talent in line with their current or future needs. 

• Enable us to fulfil any contractual obligations relating to contracts between yourself and a third party, such as an employer. 

• Obtain references. 

• Keep you informed of suitable career openings, market developments, and insights. 

• Provide information on our partner companies, update you on our services, and supply information we feel may be of benefit to you or your career. 

• Invite you to events we feel may be of interest or benefit to you. 

• Request your participation or feedback on our services, for example, via surveys, on how those services might be improved. 

 

Marketing information will be kept to a minimum, and you may unsubscribe from our marketing communications at any time via the unsubscribe link sent in our email correspondence. 

 

You can update your marketing preferences at any time by contacting us directly. 

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General Information 

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Information supplied and/or gathered relating to any individuals for the purposes of referencing, or when such an individual is named as an emergency contact, will only be used to make contact as and when needed, unless that individual later becomes, or also fits the definition of a candidate, client, supplier, or user of the TCM website. 

 

We will only use personal information obtained from, or supplied by candidates, clients, suppliers, website users, referees, and emergency contacts where: 

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• It is necessary for our legitimate business interests, or those of our clients and candidates. 

• Where your interests and fundamental rights do not override those interests. 

• Where we need to comply with a legal or regulatory obligation. 

 

We implement "privacy by design" measures across all data collection processes, ensuring that data collection is minimised and that only the necessary personal data is processed for each purpose. 

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How do we keep your data secure? 

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Your privacy and the security of your data are important to us.  In the event of a data breach, we will notify the relevant authorities and affected individuals within 72 hours of first becoming aware of the breach. We have selected a cloud-based, secure, GDPR-friendly recruitment and CRM platform on which to store data and prevent unauthorised access. Personal data relating to our candidates, clients, and suppliers is held primarily within this system, but may also be held within password-protected Microsoft applications and emails, or via secure applications provided by third parties such as those necessary to facilitate the recruitment process.  

 

These may include the clients' own internal job application portals and/or applicant tracking systems, or third-party applications that may be required to facilitate communication or any compliance checking, or screening processes as required by our clients. It is the responsibility of candidates and clients to familiarise themselves with the data and privacy policies of any such sites which, by their nature, sit outside of the jurisdiction of TCM's data and privacy agreements. 

 

In supplying data to such sites or agreeing that TCM may supply data on their behalf in pursuit of a particular job application, candidates enter into their own individual agreement with such sites and acknowledge that TCM have no on-going control over the management or processing of that data, and therefore cannot be held liable for any ensuing breach, or misuse of that data. 

Such data, whilst hosted on third-party sites, may also be viewable by and/or transferable to TCM and/or our clients and candidates as necessary to facilitate the recruitment process, compliance checks, or fulfil legal obligations. 

 

TCM will seek to prompt candidates when the need arises to share their data externally and obtain appropriate permissions. 

From time to time the need may also arise for TCM to record information on paper, for example when making notes during a meeting, however staff are encouraged to make notes directly on to the system where possible, and securely dispose of any information contained within paper files at regular intervals, once there is no longer a reason to hold the information, for example, once it has been transferred to the recruitment and CRM platform. 

 

Additional measures employed by TCM to protect your personal data include: 

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• Mandatory staff training on the importance of data handling, privacy and the associated policies and processes we follow to uphold this. 

• Restricting visibility of data to authorised persons only. 

• Regular data compliance audits and checks. 

• Password-protected systems. 

• Regular, secure disposal of paper-based files. 

• Regularly updated virus-checking software. 

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Where is your data stored? 

 

Except in instances when your data may be shared, with your express consent, with organisations outside of the European Economic Area (EEA), for example if you apply for a job outside of this region, your personal information will be stored securely and backed up within the UK.  

 

Data Subject Rights 

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"In accordance with GDPR, you have the following rights regarding your personal data: 

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• Access: Request access to the data we hold about you. 

• Rectification: Correct any inaccurate or incomplete data. 

• Erasure: Request deletion of your data ('right to be forgotten'). 

• Data Portability: Obtain a copy of your data in a structured format for transfer to another controller. 

• Objection: Object to processing based on legitimate interests or for direct marketing purposes." 

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Should you wish to exercise these rights, please contact our Data Protection Officer  at hello@tcm-partners.co.uk 

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How long do TCM retain your personal data? 

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TCM will usually keep your data for the following time periods to comply with our legal obligations and legitimate business interests. 

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• Permanent candidates that have been placed: 6 years from the commencement of employment with our clients unless an on-going relationship* is in place. 

• Permanent candidates not placed: 6 years from the initial collection of data unless an on-going relationship* is in place. 

• Contractor placed: 6 years from the end of an assignment unless an on-going relationship* is in place. 

• Contractor not placed: 6 years from the collection of data unless an on-going relationship* is in place. 

 

Data on candidates and clients with whom we have an on-going relationship, or whose data we have a legitimate reason or legal obligation to hold will also be retained. 

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*An ongoing relationship for the purposes of this policy is an exchange of messages whether by phone, email, direct messaging, or social media which takes place between TCM and the individual or company concerned in order to facilitate current or future recruitment needs. 

 

Data Retention 

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"We retain personal data as follows: 

• Candidates: Data is retained for 6 years from the last interaction or longer if there is a legal requirement. 

• Clients and Suppliers: Data is retained for the duration of our business relationship and for 6 years afterward. 

• Website Users: Data is retained for the duration of your website session and according to cookie preferences." 

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How can you access your data? 

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The General Data Protection Regulation (Regulation (EU) 2016/679) stipulates that you have the right to be informed about the collection and use of your personal data. If you would like to get in touch to discuss the data that we hold for you or make changes, please contact our Data Controller at hello@tcm-partners.co.uk. We aim to respond to all requests promptly and no later than a month following a request, unless the data requested is exempt from right of subject access, details of which can be found at www.ico.org.uk. 

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In line with the above Data Protection Regulation, you have the right to access your personal data. This includes confirmation on how your data has been processed, access to your data and other supplementary information. Please contact us if you would like to access your data. We will endeavour to respond to your request promptly and within one month of receipt of your request. 

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Whilst accessing such data is free of charge, we may charge a reasonable administration fee for any additional copies that may be required. Where possible, we will provide information in the format requested although this may not always be possible. 

You have the right to rectify your personal data if you believe any of it to be incorrect or incomplete. Please contact us our Data Controller at hello@tcm-partners.co.uk if you believe this to be the case and we will respond to your request promptly within one month of receipt. 

 

 

Erasing Data 

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You have the right to have the data we have for you erased for example if it is no longer needed for the purposes for which we collected it, or if you decide, for any reason, to withdraw your consent for your data being held. 

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Please contact the Data Protection Officer at hello@tcm-partners.co.uk if you would like us to erase any of the data we hold for you, and we will respond promptly to your request and within one month following receipt of your request. Following such a request, we will, without undue delay, erase your personal data unless continued retention is necessary, required or permitted by law. 

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Should your data have been shared with your permission for example with a third party such as an employer, potential employer or a portal used to facilitate the recruitment process, that data will be considered public data and outside the jurisdiction and liability of TCM, although we will endeavour to remind you, where possible, of where else that data may be held so that you can take appropriate action. 

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Please note that if your personal data is erased, we will keep no record of your details including your request for erasure, and therefore will not be able to purposefully avoid recollection of your data where it is held publicly via a third-party source. 

 

 

Data Portability 

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You have the right to data portability, or the right to transfer the data we have for you, to another data controller provided this does not impact the data privacy of other parties. 

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In this instance we will provide you with the data you require in a commonly read, password protected format. We may also make reasonable endeavours to verify your identity before transferring data. Please contact us to discuss this requirement and we will respond to your request promptly and within one month of receipt. 

 

 

General 

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You have the right to object to us processing your personal data for our legitimate interests or the performance of tasks in the public interest, exercise of official authority, in the case of direct marketing and profiling, or for the purpose of research and statistics. 

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If your objection relates to the processing of data for direct marketing purposes, we will cease processing of your data immediately. 

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If your objection relates to the processing of your data in relation to the pursuit of our legitimate interests, the performance of a task in the public interest, or exercise of official authority and you feel it impacts your rights and freedoms, we will stop processing your personal data, unless specific exemptions apply. Please contact us if you would like to object to us processing your data for any of these purposes. 

 

 

TCM’s Legal Basis for Processing Your Data

 

In accordance with Article 6(1)(f) of the General Data Protection Regulation, organisations can process data where it is necessary for the purposes of the legitimate interests pursued by the organisation or by a third-party. As a provider of recruitment services, we believe that it is necessary for us to collect and process certain personal data to fulfil our function and deliver our recruitment services. 

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We need certain details about our candidates and clients to provide a highly specialised, efficient, and effective recruitment service. Our service is carefully designed to address the specific needs of our customers. We deem data required to enhance and/or facilitate this process as having a legitimate business interest to TCM. 

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TCM's Data Protection Officer can be contacted at hello@tcm-partners.co.uk. We appreciate the opportunity to resolve any complaints or issues ourselves, however you also have the right to make a complaint directly to the Information Commissioner's Office (ICO). The ICO is the UK supervisory authority for data protection issues further details on how to make a complaint can be found at www.ico.org.uk. 

TCM Partners Ltd (company no. 12340402), of Office 312 The Base, Dallam Lane, Warrington, WA2 7NG is the data controller. For the purposes of this policy "we", "us", "our", "TCM" or "TCM Partners" relates to "TCM Partners Ltd". 

 

TCM are a registered data controller with the Information Commissioner’s Office (registration number: CSN4615342).