Privacy Notice
INTRODUCTION
This privacy notice provides you with details of how we collect and process your personal data.
TCM SOLUTIONS LIMITED is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our email address is: info@tcm.uk.com
Our postal address is: TCM House, Saltire Centre, Pentland Park, Glenrothes, Fife, KY6 2AG, U.K.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). TCM is registered with the ICO and you can find our details here: https://ico.org.uk/ESDWebPages/Entry/Z2242849
We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@tcm.uk.com
Applicability and Scope of this notice
This notice applies to personal information collected from the following sources:
- Visitors to our web site or other online resources we control including social media pages;
- All enquiries and communications to our company;
- Business partners and associated entities who may collect information on our behalf;
- Customers, clients, suppliers and all of those who we engage with for operational activities;
- Our employees, sub-contractors or anyone working on our behalf.
In addition to this privacy notice further information on our data collection and processing activities pertaining to employees, candidates and contractors is available in our Data Protection Policy.
How we use your personal data
We will only use your personal data when required and where legally permitted. The most common uses of your personal data are:
- Where we need to perform the contract between us.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at info@tcm.uk.com or by clicking ‘unsubscribe’ found at the bottom of marketing emails and communications.
Information we may collect and process
In order to complete our business operations, we may need to collect personal data which we may collect from you directly or from a third party and this data includes the following:
- Contact details including name, address, email and telephone numbers;
- Communications content: including all correspondence you send directly to us or any of our representatives. We may also receive communications from third parties with your personal data;
- Personal identification details including national insurance / social security number, passport details, driving licence information and other ID numbers or identification information;
- Demographic information including gender;
- Background checks including a basic criminal record checks;
- Contact details of family members and next of kin;
- Candidate and Staff information including CV’s, qualifications, references, employment history, payroll information etc…;
- Web site information including IP address, web browser and operating system details, Internet Service Provider, location, cookies and other tracking information.
Purposes for processing your personal data
We use the personal information we collect to provide our services as detailed in this privacy notice. The activities that may require collection and processing of personal data are as follows:
- Providing our business services to customers and clients;
- Purchasing services from suppliers and sub-contractors;
- Employment of current staff and other operatives and meeting our obligations as an employer;
- Recruiting new staff and operatives;
- Marketing our services, collecting feedback from customers and completing market research;
- Completing internal business operations including internal auditing, staff training and appraisals and other operations required in accordance with our ISO compliant management systems;
- Management of our equipment and premises including Information Communication Technology facilities and security systems including CCTV;
- Monitoring and analysing traffic and performance of our web site and reviewing and analysing web site visitors.
Lawful Basis – we will only collect and process personal data where we have a clear reason and lawful basis. The lawful basis is dependent on the data processing activity and at least one of the following will apply:
a. Consent – where we have your consent to process your personal data;
b. Contract – the processing is necessary as part of our service provision;
c. Legal obligation – the processing is necessary for legal reasons;
d. Vital interests – the processing is necessary to protect life;
e. Public task – the processing is for a task in the public interest;
f. Legitimate interests – the processing is necessary for our legitimate interests without infringing your rights as an individual.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at info@tcm.uk.com if you need details about the specific legal ground we are relying on to process your personal data.
Marketing communications
You will receive marketing communications from us if you have:
- requested information from us or purchased services from us; or
- if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
- in each case, you have not opted out of receiving that marketing.
We will never share your personal data with any third parties within your specific opt-in consent for marketing purposes.
You can ask us to stop sending you marketing messages at any time by emailing us at info@tcm.uk.com.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
DISCLOSURE AND TRANSFER OF YOUR PERSONAL DATA
In completing our services, we may be required or obligated to share your personal data with other entities including;
- Trading partners including service providers who provide IT and system administration services;
- Sub-contractors, suppliers and other operatives working on our behalf;
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.;
- Our IT support providers including web hosting, analytics and cloud providers;
- Our software providers including operational, sales and accounts software;
- Your former employers or other parties provided as references;
- Employment screening and employee / candidate background check providers;
- Government agencies, regulators, law enforcement or other third parties where required for legal or regulatory compliance;
- Any other providers where you direct us to provide your information or where we have your consent;
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances;
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions. We will never sell or share personal data with any third parties who might use it for any purpose not associated with the provision of our services.
INTERNATIONAL TRANSFERS
Countries outside of the United Kingdom and European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the UK/EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the United Kingdom and European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the UK/EEA.
Whenever we transfer your personal data out of the UK/EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at info@tcm.uk.com if you want further information on the specific mechanism used by us when transferring your personal data out of the UK/EEA.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to the processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at info@tcm.uk.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.