Privacy Policy
Privacy Policy
Torpai Consulting Ltd
Last updated: 10 September 2026
1. Who we are
Torpai Consulting Ltd is a recruitment, headhunting and consulting business registered in England and Wales under company number 17434864. We are responsible for the personal information we process for our own recruitment, business development, website and administration purposes.
Contact: kester@torpaiconsulting.com
Registered office: 11 Thorncliffe Green, Kirkburton, Huddersfield, England, HD8 0UQ
2. The information we collect
Depending on our relationship with you, we may collect your name, contact details, job title, employer, location, employment history, resume, qualifications, professional licenses, career interests, compensation expectations, communications, interview notes and other information relevant to recruitment.
For clients and business contacts, we may also collect information about business requirements, vacancies, projects, commercial discussions, contracts and correspondence.
When you use our website contact form, we collect the name, email address and message you provide. Our website provider may also process technical information needed to operate, secure and measure the website.
3. Where information comes from
We may receive information directly from you, through professional networking and recruitment platforms, publicly available professional sources, referrals, business contacts and contact-data providers.
Where we obtain information indirectly, we will provide relevant privacy information within the period required by applicable law, unless a lawful exception applies.
4. Why we use information
We use personal information to respond to enquiries, identify and discuss relevant opportunities, assess professional suitability, arrange introductions, manage recruitment processes, maintain business relationships, provide consulting services, administer contracts and invoices, protect our systems and comply with legal obligations.
Depending on the activity, our lawful basis may be legitimate interests, taking steps at your request before entering a contract, performing a contract, complying with a legal obligation or consent where required.
Where we rely on legitimate interests, these include identifying suitable professionals, helping clients fill vacancies, maintaining relevant business relationships and operating a secure business. We assess whether those interests are necessary and appropriately balanced against your rights and interests.
5. Recruitment and sharing your information
We may share relevant information with prospective or actual hiring organisations, authorised service providers, professional advisers and authorities where required by law.
We will not send an identifiable resume to a specific employer without appropriate permission to represent you for that opportunity. We will take account of any companies you have asked us not to approach.
We do not sell personal information or provide general access to our contact network or recruitment database.
6. Sensitive information
We aim to collect only information relevant to the purpose. We do not routinely require sensitive personal information or criminal-record information at the initial recruitment stage.
Where such information is necessary and lawful, we will identify the appropriate legal basis and additional condition, explain the purpose and apply suitable safeguards.
7. International transfers
Torpai is based in the UK and works predominantly with U.S. clients and professionals. Relevant personal information may therefore be shared with organisations outside the UK.
Where a transfer is restricted under UK data protection law, we will use an applicable adequacy arrangement, appropriate safeguards or a permitted exception. You may contact us for information about the safeguards relevant to your information.
8. How long we keep information
We keep personal information only for as long as necessary for a lawful purpose.
Our retention approach is to review unresponsive sourcing contacts after 12 months, review active relationships at least annually and generally review inactive candidate records for deletion within 24 months of the last meaningful contact, unless a documented reason justifies longer retention.
Placement, contractual, accounting and other business records may need to be retained for longer where required by law, contract or a legitimate need to establish, exercise or defend legal claims. We may retain minimal suppression information where necessary to respect a request not to be contacted.
9. Marketing
We may contact business contacts about relevant services where permitted by applicable law. We will not treat possession of a personal email address as permission to send marketing.
You can object to direct marketing at any time by contacting us. We will respect valid objections and maintain appropriate suppression records.
10. Website cookies and analytics
Our website is provided through IONOS MyWebsite Now. IONOS SiteAnalytics may process technical usage information for statistical analysis and website optimisation.
We will explain the actual cookies, tracking technologies and any optional third-party services used on the website through our cookie information and privacy settings. Where consent is required, visitors will be given an appropriate choice.
11. Security
We use appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse and disclosure. Access is limited to those who need the information for legitimate business purposes.
12. Your rights
Subject to applicable law, you may request access to your personal information, correction, erasure, restriction of processing or data portability, and you may object to certain processing.
Where we rely on consent, you may withdraw it at any time. You also have the right to object to direct marketing.
To exercise your rights, contact kester@torpaiconsulting.com. We will respond within the applicable statutory timeframe.
13. Complaints
If you have a concern about how we handle your personal information, please contact kester@torpaiconsulting.com. We will acknowledge a data protection complaint within 30 days, investigate it appropriately and respond without undue delay.
You also have the right to complain to the UK Information Commissioner’s Office (ICO).
14. Changes to this notice
We may update this notice when our services, systems, legal obligations or data-processing practices change. The latest version will be available on our website.