No, because we do not consider ourselves to be in a joint-controller arrangement with customers. Here’s a an overview explaining the main processing activities at Remote and below is an overview of the main data flows at Remote. While both Remote and its clients access some of the same information Remote has received to employ people on clients’ behalf, we will use this information for different purposes. Remote will have more information about the hires since we’re dealing with payroll and tax filing, which requires us to process certain information irrelevant to clients.
On the other hand, clients will use the information on the platform independently and purely for their own purposes of personnel management. Remote has full and independent control over the means for processing that takes place via our platform. Nevertheless, the Data Sharing addendum in our Terms of Service covers all points on data sharing agreements in the UK ICO’s data sharing code of practice, which in our view, fully satisfy the requirements of Art 26 GDPE. So we and our clients are covered even if the foregoing assessment is put into question by a court or regulator.
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