Freelancer Data Privacy Policy


Welcome to Workfree Limited’s data privacy policy.  

Workfree Limited (“Workfree” or “We”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or contact us via email or phone and share your data with us. It also tells you about your privacy rights and how the law protects you. This privacy policy is mainly directed at freelancers who are using the website. If you don't fall into that category of user, don't worry, it also tells you how we use personal information generally. 

         1. Important information and who we are

Purpose of this privacy policy 

This privacy policy aims to give you information on how Workfree collects and processes your personal data through your use of this website, including any data you may provide through this website when you complete any forms on our site or send any information to us as well as any data that you provide to us in person, via email or on the phone. It is important that you read this privacy policy so that you are fully aware of how and why we are using your data. 

We do not knowingly collect data relating to children and do not use any data relating to children. 

We are the controller and responsible for your personal data. If you have any questions on this policy, including any requests to exercise your legal rights, please contact Jonathan Cartmill using the details set out below: 

Full name of legal entity: Workfree Limited 

Email address: 

Postal address: 128 City Road, London, EC1V 2NX 

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.  

Changes to the privacy policy and your duty to inform us of changes 

We keep our privacy policy under regular review. This version was last updated in July 2023.  

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. 

Third-party links 

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.  

         2. The data we collect about you 

Personal data, or personal information, 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: 

  • Identity Data includes first name, last name, username, or similar identifier.  
  • Contact Data includes billing address, delivery address, email address and telephone numbers. 
  • Profile Data includes information you have uploaded as part of your Workfree profile, such as job title, short biography, skills, recommendations, portfolio/code base links and work/freelance history, as well as any client compliments you have chosen to add to your Workfree profile
  • Financial Data includes bank account and payment card details. 
  • Assignment Data includes details about brief responses, booked assignment, conversations about briefs and assignments, details of timesheets and approvals, that have been created through use of the website, and any feedback provided through the website. 
  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  • 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. 
  • Usage Data includes information about how you use our website and services. 
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. To the extent that you choose to provide any of these types of personal data via the website, you do this entirely of your own choosing and we will not have any way of identifying that this is special category data.  

If you fail to provide personal data 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.  

          3. How is your personal data collected? 

We use different methods to collect data from and about you including through: 

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 
  • Create an account on our website
  • Add or amend your work/experience history
  • Update or amend your profile information, including by choosing to add client compliments to your profile
  • Ask us questions or give us some feedback (including via the website or our surveys)
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below: 
  • Technical Data
  • Identity and Contact Data 
  • Identity and Contact Data from publicly available sources such as the Electoral Register and Companies House
  • Assignment Data from clients giving feedback 

The complete list of third party providers the company uses is in Disclosures of your personal data below. Some of these providers are global companies, and we do not control how they operate – at any given time, they will have operations inside and outside the UK. Where we can choose in our contract with them if your data is held inside or outside the UK, we will choose inside the UK. More information may be found in International transfers below. 

         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. For example, to provide you with the services via our website.  
  • 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. For example, to enable us to provide our services to you on a personalised basis and develop our services for the future. Or to provide our freelancers and clients with services to help them comply with their own legal or regulatory obligations (e.g. under IR35). Or to liaise with your umbrella company, if you are an umbrella freelancer. 
  • Where we need to comply with a legal obligation. For example, to meet the requirements of being an ‘employment business’ under UK law and in our statutory reporting to HMRC.  

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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. 

Purposes for which we will use your personal data 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 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 grounds, we are relying on to process your personal data where more than one ground has been set out in the table below:  


Type of data 

Lawful basis for processing including basis of legitimate interest 

To register you as a new user 

(a) Identity  

(b) Contact 

(c) Assignment 

Performance of a contract with you 

Necessary to comply with a legal obligation (e.g. verification of your identity, how you operate as a freelancer) 

Necessary for our legitimate interests (e.g. keeping business records of our users) 

To process and deliver your service including: 

(a) Enable you to create your profile in our freelancer database 

(c) Enable our client to promote their freelance opportunities to our freelancer database generally 

(c) Enable you to receive and respond to briefs which clients looking for freelancers may make available to you 

(d) Keep your profile updated, including your freelancer score and (if you choose to publish it there) your client compliments 

(e) Promote your services to potential clients via our website 

(f) Enable you to participate in any IR35 assessment a client may be undertaking 

(g) Administer contracts, timesheets and invoicing for assignments agreed between you and a client 

Administer payment to you for any assignment you undertake or via your chosen umbrella company, if you are an umbrella freelancer 

(a) Identity  

(b) Contact  

(c) Marketing and Communications 

(d) Financial 

(e) Transaction 

(a) Performance of a contract with you  

(b) Necessary to comply with a legal obligation 

(c) Necessary for our legitimate interests (e.g. company credit check and the administration of our business, to show your published client compliments on our website, communications and social media)  

To manage our relationship with you which will include: 

(a) Notifying you about changes to our terms or privacy policy 

(b) Asking you to leave a review or take a survey 

(a) Identity  

(b) Contact  

(c) Profile  

(d)Marketing and Communications 

(a) Performance of a contract with you  

(b) Necessary to comply with a legal obligation 

(c) Necessary for our legitimate interests (e.g. the administration of our business) 

To enable you to complete a survey 

(a) Identity  

(b) Contact  

(c) Profile  

(d) Usage  

(e) Marketing and Communications 

(a) Performance of a contract with you  

(b) Necessary for our legitimate interests (to study how freelancers use our services, to develop them and grow our business) 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)   

(a) Identity 

(b) Contact 

(c) Technical 

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud) 

(b) Necessary to comply with a legal obligation 

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you 

(a) Identity  

(b) Contact  

(c) Profile  

(d) Usage  

(e) Marketing and Communications  

(f) Technical  

Necessary for our legitimate interests (to study how our clients/freelancers use our services, to develop them, to grow our business and to inform our marketing strategy) 

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

(a) Technical  

(b) Usage  

Necessary for our legitimate interests (to define types of clients/freelancers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) 

To make suggestions and recommendations to you about goods or services that may be of interest to you 

(a) Identity  

(b) Contact  

(c) Technical  

(d) Usage  

(e) Profile  

(f) Marketing and Communications 

Necessary for our legitimate interests (to develop our services and grow our business) 



We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

Promotional offers from us  

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).  

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. 

Third-party marketing  

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.  

Opting out 

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.  

Where you opt out of receiving these marketing messages, this will not affect our use of your personal data for other purposes. We still need to use your personal data to provide our service to you.  

Change of purpose  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.  

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

         5. Disclosures of your personal data 

We may employ third party companies and individuals to facilitate our service, provide service on our behalf, perform service-related services or assist us in analysing how our service is used.  

We may share your personal data with third parties for the purposes set out in the table Purposes for which we will use your personal data above. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

  • Digital Ocean: Our cloud service provider 
  • Analytics: We may use third-party Service Providers to monitor and analyse the use of our Service.
  • Google Analytics  
  • Hotjar
  • Hubspot 

        6. International transfers 

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Some of our clients and freelancers may be based outside the UK.  

Whenever we transfer your personal data out of the UK, 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 approved by the Information Commissioner’s Office (ICO), which currently includes the European Economic Area (EEA) and all the countries currently deemed to provide an adequate level of protection for personal data by the European Commission. Data transfers from the EEA to the UK are also permitted as the European Commission has determined that the UK has adequacy.  
  • Where we use certain service providers, we may use specific contracts approved by the ICO which give personal data the same protection it has in the UK (called Standard Contractual Clauses)
  • Following the Schrems II case in July 2020, we no longer make data transfers to the US based on Privacy Shield.  
         7. Data security 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will take reasonable steps to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.  

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 request that our third-party contractors and site service providers follow similar standards of security and 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.  

         8. Data retention 

How long will you use my personal data for? 

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

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, regulatory, tax, accounting, or other requirements. 

In some circumstances you can ask us to delete your data: see your legal rights below for further information. 

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.  

No fee usually required 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances. 

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

Time limit to respond 

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.  

          9. Glossary 

Consent means when you freely provide a specific, informed and unambiguous indication of your wishes through a written statement or clear affirmative action, inter alia, to being contacted by our marketing teams, or being asked to participate in a market research project which would be collected on our behalf by us or our third-party recruiters. 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. 

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. 

        10. Your legal rights 

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

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.  

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:  

  • If you want us to establish the data's accuracy. 
  • Where our use of the data is unlawful, but you do not want us to erase it. 
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.  
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.  

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.  

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.