Privacy Policy

1. Who we are - True Worth Consulting Limited ("True Worth", "we", "us") is a specialist technology recruitment and consulting business. We are registered in England and Wales under company number 13561472, at Ground Floor, Rear Barn, Brookdale Business Centre, Knutsford, Cheshire. United Kingdom. WA16 0SR. 

Our ICO registration number is ZB524199.

We are the data controller for the personal information described in this policy. That means we decide how and why it is used, and we are responsible for it.

This policy applies to:

• Candidates: people looking for work, people we approach about roles, and people we place, including those working through a limited company or umbrella company
• Clients and prospective clients: the people we deal with at organisations that hire, or may hire, through us
• Referees, suppliers and partners
• Visitors to our website and people who contact us

Our associated company, True Worth AI Limited (company number 16906869), provides AI consultancy. It has its own privacy policy. Where we share information with it, we explain this in section 6.

Contact us about your data: Samuel Mikkelsen, Director, at info@trueworthconsulting.com, on 0161 399 1465, or by post to our registered address. We have not appointed a Data Protection Officer because we are not required to, but this contact handles all data protection questions.

2. What we collect

• Candidates; Name, contact details, location, CV and covering letter, employment history, skills, qualifications, salary or day-rate expectations, notice period, career preferences, interview notes, assessment results, references, right-to-work documents, security clearance status where relevant to a role, and recordings and notes of calls with us
• Contractors (once placed). In addition: limited company or umbrella details, bank details, National Insurance number, tax and IR35 status information, timesheets, assignment details and payment records
• Client and prospect contacts - Name, job title, employer, work email and phone, LinkedIn profile, notes of our conversations, hiring plans and roles, and our correspondence and contract history
• Referees - Name, job title, contact details and the reference you give
• Website visitors - Information you submit through forms or booking links, and technical data such as IP address, browser and pages visited (see section 8 on cookies)
• Sensitive information. We do not ask for special category data (such as health, ethnicity, religion or sexual orientation) unless the law requires it or you choose to tell us, for example to request reasonable adjustments. We may hold information about criminal convictions only where a client role legally requires a check, such as security-cleared work, and only as the law allows.

3. Where we get it from 

• From you: when you send us a CV, speak to us, register, apply for a role, sign a contract or contact us through our website
• Public professional sources: LinkedIn and LinkedIn Sales Navigator, job boards, company websites, Companies House and professional directories
• Referrals: from people in our network, including members of the True Worth Collective, who recommend you to us
• Referees you nominate
• Our clients: feedback on interviews and assignments, and timesheet approvals
• Funding and market news: public announcements about company investment and growth, which we use to identify organisations that may be hiring

If we obtain your details from a source other than you, we will tell you within one month, normally the first time we contact you, and point you to this policy. 

4. How we use your information and our lawful basis

We only use your information where the law allows. The table sets out each purpose and the lawful basis we rely on under the UK GDPR.

Purpose - Lawful basis

• Finding and matching you to suitable roles, and contacting you about them
• Legitimate interests (running a recruitment business); contract once you register with us
• Introducing you to a client for a specific role
• Your agreement, which we obtain before we send your CV or name to any client
• Including you in an anonymised candidate profile or hotlist (see below)
• Legitimate interests, with your prior agreement
• Managing contracts, timesheets, invoices and payments for contractors
• Contract; legal obligation
• Right-to-work checks, tax, IR35 and record-keeping duties, including under the Conduct of Employment Agencies and Employment Businesses Regulations 2003

Legal obligation

• Recording and transcribing calls to keep accurate notes
• Legitimate interests (accurate records and quality)
• Market intelligence and business development (see below)

Legitimate interests

• Managing our relationship with clients and prospects, and sending them relevant business communications

Legitimate interests

• Running our website, handling enquiries and bookings

Legitimate interests; consent for non-essential cookies

• Defending legal claims, preventing fraud, and meeting regulatory requests

Legal obligation; legitimate interests

• Where we rely on legitimate interests, we have assessed that our interests do not override your rights. You can object at any time (section 9).

Candidate hotlists and anonymised profiles

• We may send prospective employers a short, anonymised summary of candidates who are available. It describes your role, level, skills, experience and location, for example "Senior Product Manager, shipped AI features to production, Manchester, available in one month".
• We only include you after we have discussed it with you and you have agreed
• The summary does not include your name, contact details, current employer, or anything that would let the reader identify you
• We never share your full CV or identity with a client until you have agreed to be put forward for that specific role or organisation
• You can ask to be removed from any hotlist at any time

Market intelligence and business development

• When we review CVs and speak to candidates, we learn about the market: which organisations are hiring, how teams are structured, which skills are in demand, and typical pay. We use this to identify organisations we can help, to plan our outreach, and to publish aggregated market reports.
• This is about organisations and the market, not about you. It does not affect how we treat your application
• We do not use or pass on confidential information about your current or former employer that you share with us in confidence
• We will not approach your current employer in a way that reveals you are looking for a new role
• Published reports and statistics are aggregated, and no individual can be identified from them

5. AI tools, call recording and automated decisions

We use AI tools to help our team work faster. They help us:

• extract skills and experience from CVs
• summarise call notes and transcripts
• draft anonymised candidate profiles and outreach messages
• identify organisations and market trends from aggregated information
• Our current AI providers include Anthropic (Claude) and Fireflies.ai, and may include others; we keep an up-to-date list, available on request. Each acts as our processor under a contract that requires it to use your data only on our instructions, keep it secure, and not use it to train its AI models.
• We limit what AI tools see. Where practicable, we remove or mask names and contact details before processing, and we do not knowingly put special category data into AI tools.
• Call recording. We may record and transcribe calls and video meetings to keep accurate notes. We tell you at the start of a call if it is being recorded, and you can ask us not to record it.
• No automated decisions. A person always decides whether to put you forward for a role, include you in a hotlist, or end our relationship with you. AI tools support that work but never make those decisions alone.
• Your choice. You can ask us not to use AI tools on your information. We will then handle it manually.

6. Who we share it with

We never sell your personal information. We share it only as follows:

• Clients: your CV and details, only for roles you have agreed to be put forward for; anonymised profiles as described in section 4
• True Worth AI Limited: our associated AI consultancy. We may share organisation-level business information with it, such as which companies are hiring or investing in technology, so that both businesses can offer relevant services. We do not share candidates' CVs or personal details with it unless you agree
• Service providers acting for us: our recruitment database (Vincere), CRM (HubSpot), email and document storage (Microsoft 365 and Google Workspace), job distribution (Idibu), LinkedIn, call transcription and AI tools (section 5), contractor timesheet and payment platforms (such as Raise), our bank, and our accountants
• Referees and background-check providers, where needed for a role and with your knowledge
• Authorities: HMRC, regulators, the police or courts where the law requires it
• A buyer or successor, if all or part of our business is sold or restructured

International transfers. Some of our providers store or process data outside the UK, mainly in the US and the EU. Where they do, we rely on UK adequacy regulations (including the UK–US data bridge) or the ICO's International Data Transfer Agreement or Addendum to protect your data. Details are available on request.

7. How long we keep it and how we protect it

Information - How long we keep it

• Candidate records - 2 years from our last meaningful contact with you, such as a call, an application or an update. We will check in before then to ask whether you want us to keep your details
• Contractor, payroll and financial records - 6 years after the end of the tax year they relate to, to meet HMRC and accounting rules
• Client and prospect contact records
• 2 years from our last meaningful contact, or longer while we have an active business relationship
• Call recordings and transcripts - 12 months, unless needed for a live dispute; the notes we take from them are kept with your record
• Information needed for a legal claim - Until the claim is resolved. When the period ends, we securely delete or anonymise the information.

Security. We use access controls, multi-factor authentication, encrypted cloud services and need-to-know access. Our staff and contractors are bound by confidentiality. If a breach is likely to put you at risk, we will tell you and the ICO as the law requires.

8. Cookies

• Our website uses essential cookies to work and, with your consent, analytics cookies to understand how it is used. You can accept or decline non-essential cookies in the banner when you first visit, and change your choice at any time in your browser settings.

9. Your rights

You have the right to:

• access a copy of the information we hold about you
• correct information that is wrong or incomplete
• delete your information where we no longer have a good reason to keep it
• object to our use of your information based on legitimate interests, including market intelligence, hotlists and business development. We will stop unless we have compelling grounds to continue
• opt out of marketing and business communications at any time; we will always stop
• restrict how we use your information while a concern is looked into
• receive your information in a portable format, or have it sent to another organisation
• withdraw consent where we rely on it, without affecting what we did before
• ask for manual handling instead of AI tools (section 5)

To use any of these rights, email info@trueworthconsulting.com. We will respond within one month. There is normally no charge.

10. Complaints

If you are unhappy with how we have handled your information, please contact us first so we can put it right. We will acknowledge your complaint within 30 days and tell you the outcome.

You can also complain to the Information Commissioner's Office: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; telephone 0303 123 1113; ico.org.uk.

11. Changes to this policy

We review this policy regularly. The date at the top shows when it was last updated. If we make a significant change to how we use your information, we will tell you before it takes effect.