Privacy policy
hello@cocomply.co.uk
+44 (0) 203 051 9792
Registered Office
Alderley Park, Glasshouse,
Congleton Rd,
Alderley Edge
Macclesfield
SK10 4TF
This privacy policy applies between you, the User of this Website and CoComply Ltd, the owner and provider of this Website. CoComply Ltd takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.
This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at: www.www.cocomply.co.uk/privacy-policy
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 Ltd 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 GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;
GDPR - the General Data Protection Regulation (EU) 2016/679;
CoComply Ltd, or us -a company incorporated in England and Wales with registered number Suite 3, Bailey Court 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 - any third party that accesses the Website and is not either (i) employed by Francis North Group Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Francis North Group Ltd and accessing the Website in connection with the provision of such services; and
Website - the website that you are currently using, www.cocomply.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
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. the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
c. Your new rights under the GDPR are set out in this notice and were last updated on 10th May 2018.
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 data Associates:
a. 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 work-related references, qualifications and criminal references checking services, verification of the details you have provided from third party sources, psychometric evaluations or skills tests;
• to 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 rather 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 Francis North Group, 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 rather 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:
o Providers of credit reference, vetting and screening services;
o 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. 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.
12. 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.
13. 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.
14. 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.
15. Your rights
a. the GDPR provides you with the following rights.:
• The right to be informed about the personal data we process on you
• The right of access to the personal data we process on you
• The right to rectification of your personal data
• The right to erasure of your personal data in certain circumstances
• The right to restrict processing of your personal data
• The right to data portability in certain circumstances
• The right to object to the processing of your personal data
• The right not to be subjected to automated decision-making and profiling.
Therefore, we encourage you to log in to your profile through our website to ensure your data is accurate, complete and up to date at all times.
16. 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: hello@cocomply.co.uk
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.
17. 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.
18. Your rightsYou 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: hello@cocomply.co.uk.
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.
19. 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.
20. Changes of business ownership and control
a. CoComply Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of CoComply Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied 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.
21.Cookies
a. This Website may place and access certain Cookies on your computer. CoComply Ltd uses Cookies to improve your experience of using the Website and to improve our range of products and services. CoComply Ltd has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
b. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
c. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling CoComply Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
d . This Website may place the following Cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies - They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies - These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies - These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
e. You can find a list of Cookies that we use in the Cookies Schedule.
f. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
g. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
h. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
i. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
22. 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.
23. Changes to this privacy policy
a. CoComply Ltd 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 Ltd by email at hello@cocomply.co.uk.
24. 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