Privacy and Data Processing Policy

Comoro Limited processes personal data in relation to work-seekers, individual client contacts and its staff. It is vitally important that we abide by the principles of the General Data Protection Regulations (GDPR) set out below. Comoro takes your privacy seriously. This policy describes how and why we obtain, store and process data which can identify you. In connection with these activities Comoro is the Data Controller.

Comoro Limited holds data on individuals for the following general purposes:

For work seekers (candidates) Comoro processes the following data:

If you are a candidate, most of the information above is collected when you apply for a job or when you contribute to or use some of the other features on our web site. If you apply for a job through the Comoro website your data is processed by our web site host company CTCentral. If you apply for a job through an external job board site your application is passed directly to our database.

We will only pass on information about you as an individual to third parties to enable us to perform services requested by you or with your prior agreement, such as pursing work opportunities for you with our clients. This may involve background or criminal record checks, if required by our clients. When we submit your data to a client you are agreeing to the use of the data in order for the client to evaluate if you are suitable for the role. You are also agreeing to the client sharing this data within their organisation as part of this assessment. In some cases this may mean the client passes the data to another department or one of their advisors. On occasion this may be outside the EU, but Comoro will endeavour to require that the client seek your agreement to this where this process is required.

We will never share your information with third parties for marketing purposes but may need to work with third parties in order to obtain references or information relating to your application for a role.

If you are engaged by Comoro as a Temporary Agency Worker and we process you through our PAYE payroll, as part of this process we are required to send all relevant payment information to HMRC.

If you are engaged by Comoro to work through your own Limited Company and we process the payments to you, we are required to collect information regarding you, your Limited Company and the payments we make and report these to HMRC.

In certain circumstances we may need to disclose information about you if you breach this policy or if you breach the Terms and Conditions. We may also disclose or access your account if required to do so by law or by a Government body.

We will only pass on information about you as an individual (as opposed to aggregate information) to third parties overseas to enable us to perform services requested by you.

For client contacts Comoro processes the following data:

As the Data Controller the GDPR requires Comoro to process data in accordance with the principles of data protection. These require that data shall be:

Legal basis for processing data

Comoro processes data under the following GDPR conditions:

Candidates

Comoro will process your data in order to find a suitable job for you, either permanent or temporary, when you submit your information to us. This is part of our legitimate interest as a recruitment company. Under the legitimate interests condition Comoro will endeavour to match you with roles on which our clients have briefed us. This is in both the interest of Comoro as a business, providing specialist recruitment services, and of you as the candidate, who is seeking a job within the marketing sector.  In this process the interests of both parties are aligned. However, this process does not affect your rights, which are available under the GDPR.

The data submitted may be in relation to a specific role but may be used in relation to other roles for which we believe you may be suitable.

We always check with you before we submit you for a role, to check you are happy for us to pass on your details, CV and other relevant information.

If you create a personal account on our website we keep the personal data connected to this account and other information about you in order for us to provide you with the services you have requested.

If you apply for a job, either through the website, directly or through an external job board similarly we keep your personal data to allow us to provide the services connected with the application and other roles that we feel might be of interest to you.

Automated Decision Making

Our systems filter out spam emails of multiple CVs and multiple CV applications from overseas. This is largely from countries outside the EU.

Individual Rights

The GDPR provides the following rights for individuals whose data is held:

All data subjects (individuals) have the right to be informed about the use of their data. Comoro has listed in this document what data we collect and how we use it. Individuals can request to see what data we hold through a Subject Access Request. Comoro will respond to any request made as soon as possible and in any case within one month, as per the requirements of the GDPR. Individuals can ask for data to be corrected or erased and to restrict the use of the data.

Any requests regarding the above can be made by contacting the person responsible for our data management using the following email address: [email protected]

Any complaints regarding the holding of data can be made to the Information Commissioners Office by contacting their website at https://ico.org.uk/

Comoro Limited – Registered Office – 12-14 Carlton Place, Southampton, SO15 2EA

Comoro Limited is registered in England No. 06802075

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