Privacy policy
+44 (0) 203 051 9792
Registered Office
Alderley Park, Glasshouse,
Congleton Rd,
Alderley Edge
Macclesfield
SK10 4TF
This privacy policy explains how we handle and protect your personal data when you visit our website, use our products and services, or when we receive your information in connection with services provided to a client. It also outlines your privacy rights and how the law safeguards your information under the UK GDPR.
Please read this privacy policy carefully.
Definitions and interpretation
1. In this privacy policy, the following definitions are used:
Data - collectively all information that you submit to CoComply Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Cookies a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
Data Protection Laws any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the UK GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the UK GDPR is effective in the UK;
UK GDPR a legal framework that governs the collection, use, and protection of personal data in the UK, ensuring individuals' privacy rights and imposing obligations on organisations to handle data lawfully and securely.
CoComply Limited, or Us -a company incorporated in England and Wales with registered number 12141000 whose registered office is at Glasshouse Alderley Park, Alderley Edge, Macclesfield, SK10 4TF and whose registration number is 12141000;
UK and EU Cookie Law - the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
"User" or "you" refers to any third party who accesses the website or whose information CoComply has received in connection with the services it provides. This definition excludes individuals who are: (i) employed by CoComply Limited and acting within the scope of their employment, or (ii) engaged as a consultant or providing services to CoComply Limited and accessing the Website as part of delivering those services.
2. In this privacy policy, unless the context requires a different interpretation:
a. the singular includes the plural and vice versa;
b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
d. “including” is understood to mean “including without limitation”;
e. reference to any statutory provision includes any modification or amendment of it;
f. the headings and sub-headings do not form part of this privacy policy.
3. Scope of this privacy policy
a. This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
B. UK GDPR is the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (EU GDPR).
c. Your new rights under the UK GDPR are set out in this notice and were last updated on 30th September 2024
4. The Information we collect
a. To carry out our core business activities, we collect information about you which may include: your name, marital status, address and post code; private and corporate e-mail address and phone number; financial information and compliance documentation; references verifying your qualifications and experience and your right to work in the United Kingdom; curriculum vitae and photograph; employment details and preferences; links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, Facebook for Business or corporate website.
5. How we collect this information
a. The information we collect about you will be provided by you, either by filling out a form on our website www.cocomply.co.uk or by corresponding with us by phone, e-mail or otherwise. It will also include information you provide when you register to use our website, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our website, enter a competition, promotion or survey, and when you report a problem with our site.
b. We may also obtain information about you from other sources such as LinkedIn, Lusha, corporate websites, Companies House, CoComply end clients, job board websites, online CV libraries, your business card, personal recommendations, and any relevant social media sites.
6. How we use your personal information and our lawful basis for processing your personal dataAssociates:
a. We have conducted a Legitimate Interests Assessment (LIA) to ensure that the processing of your personal data is necessary and does not unduly affect your rights and freedom
b. We collect, store and use information that we obtain in relation to you for our legitimate interests:
so that we can contact you (via email, SMS or phone) about opportunities and project assignments that we believe you will be interested in;
to help us to provide suitable associate profiles for our clients who engage us to assist them fulfil their consulting and resourcing requirements;
to provide a channel through which you can submit your profile for general applications, to apply for specific project opportunities, jobs or to subscribe to our job alerts;
to match your details with opportunities to assist us in finding a position that is most suitable for you and to send your information to clients for potential engagements. Please note that we will always obtain verbal or written consent before presenting your personal details to a client;
to enter into contracts which are necessary in order for your service to be supplied or made available to a hirer;
to provide recruitment-related support;
to carry out market research for our internal use;
to develop an industry-relevant database of associates and clients to help meet our clients’ resourcing requirements and connect candidates with work opportunities;
for internal record keeping purposes;
to carry out services that we, you or our client have requested including o
inform you of CoComply networking and other related events.
b. This storage and use of your personal information allows you to be contacted about opportunities which we think will be of interest to you, now or in the future, and we do not believe that this storage and use will unduly prejudice your rights or freedoms.
7. Client Data
a. The data we collect about clients is limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to maintain an effective business relationship. We also hold information relating to your online engagement with associate profiles and other material published by CoComply Limited to ensure that you receive timely marketing communications relevant to you.
b. we may also hold additional information that someone in your organisation has chosen to share with us. In certain circumstances, such as for training purposes our calls with you may be recorded, depending on the applicable local laws and requirements.
8. Supplier Data
a. the data we collect about suppliers is limited to maintain an effective business relationship. We will collect the details for our contacts within your organisation, such as names, telephone numbers, Ltd company details and email addresses. In some cases we’ll also collect bank details so that we can pay you. We may also hold additional information that someone in your organisation has chosen to share with us. In certain circumstances, such as for training purposes our calls with you may be recorded, depending on the applicable local laws and requirements.
9. Persons whose data we receive from Associates & Employees
a. in the case of ‘referees’, we require confirmation of information that we have already obtained from our associate or prospective CoComply employee to enable them to secure a project assignment. In the case of an ‘Emergency Contact’ – details provided in the case of an emergency When requesting a reference, we require the referee’s contact details (such as name, email address and telephone number).
10. How we share your personal Information and who we share it with
We will disclose information under the following circumstances:
a. Third-party service providers: When we share information with third-party service companies for them to facilitate and support us in the provision of the Services. This includes:
Providers of credit reference, vetting and screening services;
Payment processors and software providers;
These organisations are appointed by CoComply as data processors and authorised to use your personal information only as necessary to provide the relevant services to us. These organisations are required to process such information based on our instructions and in accordance with this privacy policy. They do not have any independent right to share this information.
11. Data Breach Notification
a. In the event of a data breach, we will notify the ICO within 72 hours and affected individuals without undue delay if there is a high risk to their rights and freedoms.
12. Third Party Services
a. This website might contain links to third-party websites and applications that you may find useful. Interacting with these links or enabling connections could allow third parties to gather or share your data. Since we do not control these external sites, we cannot be held responsible for their privacy practices. We recommend that you review the privacy policies of any external platforms or websites not operated by CoComply Limited.
13. Compliance with laws and legal proceedings
a. when we respond to court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. When we believe it is necessary to share information in order to investigate, prevent or take actions against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, or as otherwise required by law.
14. Consultancy services
a. When we are using your personal information in the context of our consultancy services, then we will share your personal information with clients where we believe that you or your consultancy services will be appropriate for a particular project opportunity or vacancy with that client.
15. Umbrella companies, personal service companies consultancy companies
a. When you inform us that you are supplying or intend to supply your services via CoComply to a client through an umbrella company, personal service company or consultancy company.
16. Recruitment Process Outsourcing and Managed Service Providers
a. In certain cases, an organisation such as a managed service provider will act as a gateway for the supply of Services made via CoComply to the hirer. Where this is the case, we will share your information with such organisations to the extent that it is necessary for the purposes of the supply. Where personal information is shared with clients, hirers, umbrella companies, personal services companies or managed service providers in the circumstances described above, then those organisations will handle your personal information in line with their own privacy policies.
17. Your rights
a. Under the UK GDPR, you have the following rights regarding your personal data:
The right to be informed about the personal data we collect and process about you.
The right of access to the personal data we hold about you.
The right to rectification if your personal data is inaccurate or incomplete.
The right to erasure of your personal data, also known as the "right to be forgotten," in certain circumstances.
The right to restrict processing of your personal data in specific situations.
The right to data portability, allowing you to obtain and reuse your personal data across different services in certain circumstances.
The right to object to the processing of your personal data, particularly for direct marketing purposes.
The right not to be subjected to automated decision-making, including profiling, that has legal or similarly significant effects on you.
We encourage you to log in to your profile on our website to ensure your personal data is accurate, complete, and up-to-date at all times.
18. Keeping Data secure
We will use technical and organisational measures to safeguard your Data, for example:
a. Access to your account is controlled by a password and a user name that is unique to you.
b. We store your Data on secure servers.
c. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: [email protected].
d. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
19. Data retention
a. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.
b. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
20. Your rights
You have the following rights in relation to your Data:
a. Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
b. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
c. Right to erase – the right to request that we delete or remove your Data from our systems.
d. Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
e. Right to data portability – the right to request that we move, copy or transfer your Data.
f. Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
g. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: [email protected].
h. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
i. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
21. Links to other websites
a. this Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.
22. Changes of business ownership and control
a. From time to time, CoComply Limited may expand or reduce its business, which could involve the sale or transfer of control of all or part of the company. If any such changes occur, and where relevant to the business being transferred, your Data may be transferred along with that part of the business. The new owner or controlling party will, under the terms of this privacy policy, be allowed to use your Data for the purposes for which it was originally provided to us.
b. We may also disclose Data to a prospective purchaser of our business or any part of it.
c. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
23. General
a. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
b. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
c. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
d. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
24. Changes to this privacy policy
a. CoComply Limited reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.
You may contact CoComply Limited by email at [email protected].
25. Children’s Data
Our websites and applications are not intended for children under the age of 13, and we do not knowingly gather personal data from children in this age group. If you believe we may be handling personal data related to a child under 13, please contact us using this email: [email protected].
26. Cookies
a. Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.
Strictly necessary
We use the following strictly necessary cookies:
Session Cookie - use this cookie to remember you and maintain your session whilst you are on our website
b. Analytical/performance
We use the following analytical/performance cookies:
Performance Cookie - We use this cookie to help us analyse how users use the website
c. Functionality
We use the following functionality cookies:
Functional Cookie - use this cookie to identify your computer and analyse traffic patterns on our website.
d. Targeting
We use the following targeting cookies:
Targeting Cookies - We use this cookie to enable us to show you adverts while you are browsing our website and other websites on the internet