Privacy Policy


Comtecs is committed to protecting the privacy of personal data and maintaining the principles of integrity and trust in the course of Comtecs’ business.

1. Purpose of this privacy policy

This privacy policy aims to give you information on how Comtecs collects and processes your personal data through your use of this website.

2. The data we collect about you

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows and split by our services:

Web Development / IT Solutions / IT Recruitment

• Identity Data includes first name, maiden name, last name, marital status, title, gender, nationality, disability, date of birth and gender, identity and immigration and eligibility to work data (e.g. photographic identification, passport, signature), languages spoken, driving licence, job title and employer;

• Contact Data includes postal address, email address and telephone numbers and corporate contact details (including business "direct dial" or office address).

• Correspondence Data includes personal data given to us as a result of, and about, our correspondence and personal data about or contained in the substance of complaints, the progress of complaint resolution, and the outcome of complaints.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website and information about how you use our website.

IT Recruitment

• Recruitment data: skills and experience, qualifications, training, job history, LinkedIn contact and profile, references, CV and application, interview and assessment data, vetting and verification information, information related to the outcome of your application, details of any offer made to you.

Web Development / IT Solutions

• Financial Data includes bank account and payment card details (where necessary to conclude service contracts with you).

3. How is your personal data collected?

We use different methods to collect personal data from and about you. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. We may also receive personal data about you from various third parties, such as recruitment websites, and public sources, such as professional social media sites such as LinkedIn.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

For our IT Recruitment Services, consent and within our legitimate interest are usually the basis of processing your personal data.

Otherwise, we generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

5. Purposes for which we will use your personal data

We will process your personal data for the reasons set out below. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out.


Lawful basis for processing including basis of legitimate interest

To communicate with you and to process and respond to correspondence from you

To comply with law

To help us meet our contractual obligations to you

To contact you where we need to and it is within our legitimate interests to do so

To register you as a new client or supplier

To help us meet our contractual obligations to you

To manage our relationship with you which will include

To help us meet our contractual obligations to you

To keep our records updated and to provide our services and it is within our legitimate interests to do so

To help ensure the quality of our services

To maintain the quality of our services within our legitimate interests

To understand the performance of our business

To understand the performance of our business within our legitimate interests

To administer and protect our business and this website

To run our business, provide of administrative and IT services, network security and it is within our legitimate interests to do so

To comply with law

To use data analytics to improve our website, marketing, client relationships and experiences

To keep our website updated and relevant, to develop our business and to inform our marketing strategy, within our legitimate interests

To conduct direct marketing / contact you about potential suitable vacancies

Consent (which you have given us - you can opt out at any time)

To assess your suitability to work for our third party clients including short listing, assessments and interviews

To maintain the quality of our services within our legitimate interests as a provider of IT recruitment services

To provide your information to third party clients to whom we provide recruitment services to put you forward for a position to such third party client

Consent (which you have given us - you can opt out at any time)

To compare you with other applicants and make a decision whether to put you forward for a position with a third party client

To maintain the quality of our services within our legitimate interests as a provider of IT recruitment services

6. Direct Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you have given us your consent to send you marketing material by email or post, you have the right to opt out of receiving that material. We will also get your express opt-in consent before we share your personal data with any company other than Comtecs for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

7. Cookies

We use cookies. A cookie is a small piece of information that a website stores on the web browser on your device and can later retrieve. We use 'session' cookies during a single browsing session to let our website know that the same person is using it during that session (as soon as your browser is closed, the session cookie set by our website is destroyed) and use 'persistent' cookies to recognise your browser every time you visit our website and to track the pages you visit.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

8. Disclosures of your personal data

We may employ the services of third party service providers who help manage our business and deliver services and we may need to share your personal data with them. These service providers have agreed to confidentiality restrictions and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. Where third party service providers receive your information we will remain responsible for the use of your personal data. We take appropriate steps to ensure that such third parties treat your personal data with the same consideration that we do.

We may from time to time be required to disclose your personal data to law enforcement bodies, regulators, agencies or third parties under a legal requirement or court order. We act responsibly and take account of your interests when responding to any such requests.

9. International transfers

Third party service providers who handle data on our behalf may be based in locations around the world. For this reason, your personal data may be transferred to other countries both inside and outside of the European Economic Area. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

10. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For our IT Recruitment Services, if you provide us with your CV or we obtain your details from a third party, we will keep your details for a period of 48 months. If we put you forward for a position with a third party but are ultimately unsuccessful in a position, we will keep the information we receive about you throughout the recruitment process for a period of 48 months after completion of the application process.

12. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Your rights Further details

Rectification You can correct any personal data that we hold about you which is incorrect.

Erasure You can request that personal data that we hold about you be deleted where it is no longer necessary for us to hold your personal data, you have withdrawn consent or we have no legitimate interests to process your personal data.

Access You can request access to your personal data that is held by us, including the purpose of our processing, the types of personal data held and any recipients of your personal data.

Restriction of processing You can request that we restrict processing your personal data where we no longer need to process your personal data or you object to us processing your personal data.

Portability You can request the personal data that we hold about you to be provide in a commonly used format where you wish to provide that information to another party.

Object You have the right to object to the use of your personal data where we process it in our legitimate interests.

Withdrawal of consent You can withdraw your consent for any processing that we undertake on the basis of your consent.

Although you are encouraged to contact us if you would like to exercise your rights, some of these rights are only available in certain circumstances and so we may not be required to comply with every request.

13. Information about the data controller

This privacy policy is issued on behalf of the Comtecs group consisting of Comtecs Associates LLP and Comtecs Limited ("Comtecs"). When we mention "we", "us" or "our" in this privacy policy, we are referring to the Comtecs Group. If we are providing IT Recruitment Services the data controller will be Comtecs Limited. If we are providing other services the data controller will be Comtecs Associates LLP. We will make it clear to you who the data controller is at the time your personal data is collected.

14. Contact us

The primary point of contact for all issues arising from this privacy policy, is Tom Blackden. If you have any complaints or queries relating to the processing of your personal data by Comtecs or to exercise any rights in respect of your personal data, you should contact us in one of the following ways:

0044 (1) 892 514 636

Comtecs Group, 215a Upper Grosvenor Road, Tunbridge Wells, Kent, TN1 2EG

We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.

15. To contact your data protection supervisory authority

You have a right to lodge a complaint with your local data protection supervisory authority. In the UK, this is the Information Commissioner's Office ( Should you have a complaint, we hope you feel that you can approach us first so that we can try to resolve your concern.

16. Changes to the privacy policy and informing us of changes

This version was last updated on 18 May 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.