Privacy POLICY

Effective from May 2018 

This is the Privacy and Cookies Policy (the “Privacy Policy”) for The Employment Management Platform Limited (Registered company number 10559324) having its registered office at 5th Floor Hampton by Hilton, 42-50 Kimpton Road, Luton, Bedfordshire, LU2 0FP (“Flexr”, “we”, “us”, or “our”) who operate the Flexr platform (the “System”) including the website (the “Website”).

Please read this Privacy Policy carefully as it explains how Flexr collects and processes the information of an individual person or business creating a User Account through our System or visiting our Website (“you” or “your”) in accordance with the Data Protection Legislation. This Privacy Policy is in addition to, and does not relieve, remove or replace, any obligations under the Data Protection Legislation.

Flexr is committed to protecting your privacy and this Privacy Policy is designed to help you understand what data we collect, why we collect it, what we do with it, and your rights in connection with this.   This Privacy Policy is intended to be read in conjunction with our Terms of Use. Terms defined in our Terms of Use shall have the same meaning when used in this Privacy Policy.

Depending on how our System is used by you, we might be considered to be a Data Controller, Data Processor or a Sub- Processor.  In all cases, you and we will comply with all applicable requirements of the Data Protection Legislation. Flexr is registered with the Information Commissioner’s Office (“ICO”) as a Data Controller, Registration Number ZA312915.

Information we collect

The Facility that Flexr provides is designed to simplify the business purpose of sending and receiving information and data for the fulfilment of employment and Human Resources activities (including temporary, permanent or otherwise).  Flexr is designed to facilitate the management of:

  • CV’s and references
  • Assignments, Employment and Placements
  • Absence and sickness recording
  • Payroll activities
  • Verification of worker suitability
  • Identification documents
  • Clearance to work
  • Criminal records bureau clearance
  • Right to remain and work in the UK
  • Qualifications and training records
  • Registrations with regulatory, professional and trade bodies

We will only collect such information as is necessary for the provision of the Facility and other authorised purposes including those which we are required by law to undertake.  Any information collected will be used solely for the purpose for and to the extent necessary to carry out these and other tasks undertaken by us.

The Facility is a dynamic, innovative environment, which means we are always seeking to improve the Facility. We might introduce new features, some of which may result in the collection of new information. If we start collecting substantially new types of information and materially change how we handle your data, we will modify this Privacy Policy and notify you.

How do we collect this information?

We collect information in the following ways:

  • Information that you provide- For example when you sign up for a User Account we’ll ask you for personal information like your name, email address and telephone number. We may also keep a record of any e-mail correspondence you send to us and telephone calls made to or by our customer service line.
  • Information that other Users provide- For example where you are a Worker, Employee or Contractor, information about your Assignment, Employment or Placement will be given to us by the owner of that Assignment, Employment or Placement (namely your Employer, Engager, Hirer or Provider)
  • Information we get from your use of our System- For example we collect information about the services that you use and how you use them. This helps us to deal quickly with any problems you may experience with the Facility and improve it. We also keep details of visits to our Website and the resources accessed including, but not limited to, traffic data, location data and other communication data.

By entering information through the System you accept that we may retain your information and it may be held by Flexr or by any third-party which processes it on our behalf.

Some of our services require registration or creation of a User Account before they can be accessed. This may require you to provide personal data. In these situations, if you choose to withhold any personal data requested by us, it may not be possible for you to gain access to these services or for us to respond to your query.

What types of information do we collect

We may collect and store personally identifiable information about you, also known as personal data.

The personal data that we may collect and store includes your name, address, title, date of birth, telephone number, mobile number, address, e-mail address, gender, marital status and dependants, next of kin and emergency contact information, National Insurance number, bank account details, payroll records, tax status information, salary information, annual leave information, pension information, benefits information, start date, location of employment or workplace, copy of passport, copy of driving licence, copy of right to work information, copy of references, recruitment information, employment records (including job titles, work history, working hours, training records and professional memberships), performance information, disciplinary and grievance information, information obtained through electronic means, information about use of information and communication systems, and photographs).

We may also collect and store special category data. This special category data requires a higher level of protection and will be treated accordingly.

The special category data we may collect and store includes information about health, for example details of a sickness absence, and information about criminal convictions and offences. It might be necessary for us to process this information for several reasons – for example, absence and appointment recording. Where we obtain special category data, we will ensure that we have appropriate arrangements in place to secure the data and also that we will obtain the required consent to process the data.

Where we hold the personal or special category data of persons under the age of 18 we will ensure that the reasons for holding the data are made clear to them and that their right to privacy is protected. If you are under 18 and wish to use our System or the Facility, you may need to ask for consent from a parent or guardian.

How we use your information

We use your information in the ways listed below:

  • To provide you with information, products or services that you request from us.
  • To allow us to fulfil any contractual obligation entered into between you and us.
  • To allow you to participate in interactive features of our online services, if you choose to use these.
  • To notify you about any significant changes to the Facility.
  • To verify your identity and any relevant accreditation, registration or certification for the purposes of your User Account.
  • To enquire about and search records held by crime and credit reference agencies. We may also check your details held by fraud prevention schemes.
  • For administrative purposes, including the processing of medical certificates and to maintain our records.
  • For quality and training purposes, including the recording of calls. You will be advised at the start of every call that the call will be recorded for this reason. Should you object the recording can be deleted following completion of the call, or communications can take place via email.
  • To respond to your query or complaint.
  • To analyse which of our communications are most effective. This can help to reduce administration costs.
  • To allow us to contact you by post, telephone, SMS, e-mail or as part of delivery of the Facility with information which is relevant to you about features, products, services, events, promotions and special offers, we may analyse your personal data to create a profile of your interests and preferences. If we contact you for the purposes of direct marketing, we will only do so where:
    • You have given us consent to contact you in this way
    • Where we have another legal basis for doing so and where we provide you with the opportunity to tell us you don’t want to be contacted by us in the future.
  • To conduct market research including statistical analysis of customer behaviour which we may disclose to third-parties in depersonalised, aggregated form.
  • To ask you to participate in a survey for our research purposes.
  • To collect information about your visits to our website and the resources you access, to provide you with a better web experience. For more information about this, please read our Cookies Policy.
  • To prevent and detect fraud or abuses of the Facility.
  • If you default on payments, we may disclose your relevant details to debt collection agencies.
  • To comply with any requirements imposed on us by law or court order.

Protecting your information

We will take all reasonable organisational and technical security measures to prevent unauthorised access to any personal data you provide to us. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using industry standard technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our System, you are responsible for keeping this password confidential. We ask you not to share your password with anyone, and to please inform us if you believe your password has been compromised so that we can ensure your information is protected.

Whilst we take steps to met industry standard levels of security safeguarding, no method of the transmission of information via the internet is completely secure and therefore we cannot guarantee the security of data sent to us electronically and the transmission of such data is entirely at your own risk.

Where we store your information

Data that is provided to us is stored on our secure servers. Details relating to any transactions entered into via our Website will be encrypted to ensure its safety. If you are using our System from outside of the United Kingdom, please be aware that you are sending information (including Personal Data) to the United Kingdom where our servers are located. That information may be transferred within the United Kingdom depending on the type of information and how it is stored by us.

We retain your personal data in order to meet the obligations of our relationship with you, to provide you with information and updates about the System and the Facility, and keep you informed. We will store your personal data for as long as you are a User of the System and the Facility. Where personal data is no longer required for the provision of the Facility, and there is no other legal requirement to hold onto the data, it will be irrevocably deleted.

Some organisations that provide services to Flexr run their operations outside of the European Economic Area (EEA). We take steps to ensure that any such organisation which may have access to your data will provide an adequate level of protection in accordance with the Data Protection Laws.

Sharing your information

Where we are required to do so we will ensure that we have all necessary and appropriate consents and notices in place to enable lawful processing of the personal data and, where applicable, the sharing or transfer of the personal data for the duration and purposes of the Facility.

From time to time we may be required to share your personal data with organisations which deliver services on our behalf. By using the Facility this means that you are allowing these third-parties to access and use your Content including identification documents, sensitive financial information and sensitive medical information. In this regard, you give us permission to use your Content for these purposes. At all times where we use or disclose your information it will remain secure.  Where a third party is delivering services on our behalf, we will enter into a Data Processing Agreement with that organisation which contains provisions broadly similar to that of Clause 9 of our Terms of Use. This helps to ensure, to the fullest extent possible, that we can protect your personal data by requiring that the organisation meets their own responsibilities in respect of the Data Protection Legislation.

We do not provide, share, or sell your personal data to other organisations for marketing purposes unless you agree otherwise.


We fully respect your right to confidentiality. We may however be required to disclose your personal data to third parties in the following circumstances:

  • if we are under a legal duty to disclose or share your personal data in order to comply with the law
  • in order to enforce or apply our Conditions, Terms of Use or other agreements
  • to protect the rights, property, or safety of Flexr, our stakeholders and partners
  • where we sell any or all of our business and/or our assets to a third party

We will ensure that all personnel who have access to and/or process personal data are obliged to keep the personal data confidential.

Your rights

  • You can make a ‘Subject Access Request’ to request access to the information we hold about you. If you wish to make a request, please contact our Data Protection Officer using the details supplied at the end of this Privacy Policy. We will make sure to provide you with a copy of the data that we process about you. In order to comply with your request we may ask you to verify your identity. We will fulfil your request by sending your copy electronically unless the request expressly specifies a different method.
  • If you believe that the information we have about you is incorrect you can request that we correct your personal data or erase it altogether if it is no longer required. Please note: If you no longer wish to be contacted and ask us to remove your data from our records it may be necessary for us to retain a very small amount of data, to ensure that we do not contact you again.
  • You can ask us not to use your personal data for certain purposes, including for marketing. We will inform you, before collecting your data, if we intend to use your personal data for such purposes.
  • You can tell us whether you are happy to be contacted whenever you provide your contact details, usually via tick boxes. You can also change your preferences at any time by contacting our team.

The Telephone Preference Service (TPS) is an official register through which an individual can opt out of receiving unsolicited sales or marketing calls. You can register online at: Please note that it may take up to 28 days from when you register with TPS for the change to take effect on our communications with you.

Cookies & Remarketing

You may notice that sometimes, after visiting a website, you see increased numbers of adverts from the site you visited. That’s because the website you visited has placed “cookies” on your web browser. Cookies are small text files sent by a web server to your web browser, stored on your computer or mobile device and sent back to the web server each time you use their site. Cookies are not computer programs, and cannot read other information saved on your hard drive. They cannot be used to disseminate viruses, or get a user’s e-mail address. Using that cookie and web analytic tools, the website owner will be able to show you adverts on third-party websites that they think you might be interested in. The cookie does not give access to your computer or mobile device, but may be able to identify you from your IP address. Cookies make the interaction between users and platforms faster and easier and are used by the vast majority of platforms to provide features such as automatic login.

All web browsers allow you to restrict the use of cookies on your computer or mobile device but disabling them may prevent you from being able to use the Facility as we may use them to enable you to log into your User Account. Flexr may use cookies within the Facility to manage the login process.

You might find links to third party websites on our Website. These websites should have their own privacy policies which you should check. We do not accept any responsibility or liability for their policies whatsoever.

Google remarketing

You can visit our Website without giving away any personal information. Flexr uses Google’s Analytics to show relevant adverts to Users who have previously visited our site, as they browse other websites. This enables us to tailor our marketing to better suit your needs and only display ads that are relevant to you. You may see Flexr in search results pages (using Google Ad Words), on YouTube, in banner adverts on Gmail and on the Google Display Network.

Any personal data collected will be used in accordance with our own Privacy Policy and Google’s privacy policy. Please note that Google may keep this data for up to two years, but will remove part of your IP address after 9 months and the cookie information after 18 months. If you do not wish to see ads, you can:

The collected information is used to provide an overview of how people are accessing and using the Flexr Website. It is not used for any additional purpose, such as to profile those who access our Website.

Future changes to this Privacy Policy

Any changes we make to our Privacy Policy in the future will be posted on this page.  You should check this page regularly for updates.

How to contact us

Questions or comments about the System and our Website are welcomed – please visit our ‘Contact Us’ page for all the ways you can get in touch with us.

If you have any questions regarding this Privacy Policy or would like to:

  • Request access to information that Flexr has about you
  • Correct any information that Flexr has about you
  • Delete information that Flexr has about you

Or, if you have any other questions about our collection and storage of data, please contact our Data Protection Officer at