Clarity People Solutions – Privacy Statement
Purpose of this Policy
What information do we collect about you?
We collect information about you when you instruct us to provide advice; visit our website; attend one of our seminars; and engage in business dealings with us.
Our primary goal in collecting personal information from you is to help us:
• verify your identity
• deliver our Services
• carry out requests made by you on the Site or in relation to our Services
• investigate or settle inquiries or disputes
• protect the rights, property or safety of us or third parties, including our other clients and users of our Services
• with recruitment purposes, and
• use as otherwise required or permitted by law.
To undertake these goals we may process the following personal information:
If you are an individual client in receipt of our Services or prospective individual client:
• Name and job title.
• Contact information including the company you work for and email address, where provided.
• Payment information.
• Information that you provide to us as part of us providing the Services to you, which depends on the nature of your instructions to Clarity People Solutions.
• Relevant information as required as part of our client intake procedures.
• Information you provide to us for the purposes of attending meetings and events, including dietary requirements which may reveal information about your health or religious beliefs.
• Other information relevant to provision of Services.
How will we use the information about you?
When you visit our website, a record of your visit is made. That data is used completely anonymously, in order to determine the number of people who visit our website and the most frequently used sections of the site. This enables us to continually update and refine the site. If you use any forms on the website to send an email to us, a record will also be made of your email address and your telephone number.
We may collect, hold, use and disclose the information collected to respond to any email enquiries; notify you of any upcoming marketing, training or other events; manage quality control; manage systems administration; attend to compliance issues; provide you or your organisation with advice; and for other marketing purposes.
We will not use or disclose your personal information for any other purpose which is not related (or in the case of sensitive information, directly related) to the above purposes without your consent, unless otherwise authorised, required or permitted under the laws of England and Wales.
If you no longer wish to receive information about our services, please send an email to firstname.lastname@example.org advising that you do not wish to receive further information.
Will we disclose your data?
We may disclose your personal information on a confidential basis to external service providers so that they can provide services such as financial or administrative services in connection with the operation of our business; and to any person (where necessary) in connection with their services, such as law enforcement, regulatory authorities, associates or advisors.
If we engage external service providers, we will take reasonable steps to ensure those entities comply with their obligations under the Data Protection Act 1998 when they handle your personal information. We will also ensure external service providers are only authorised to use personal information for the limited purposes specified in our agreement with them.
What is our legal basis to use or process your personal information
It is necessary for us to use your personal information;
• To perform our obligations in accordance with any contract that we may have with you.
• It is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the Services in the best way that we can.
• It is our legal obligation to use your personal information to comply with any legal obligations imposed upon us.
Where do we transfer your data to?
We will not transfer data outside of the European Economic Area (EEA). If a client is not based in it’s entirety within the EEA then please note that where necessary to deliver the Services we will transfer personal information to countries outside the EEA.
Who do we share your personal information with
We may share personal information with a variety of the following categories of third parties as necessary to supply services and fulfil contractual obligations:
• Our professional advisers such as lawyers and accountants.
• Government or regulatory authorities.
• Professional indemnity or other relevant insurers.
• Regulators/tax authorities/corporate registries.
• Third parties to whom we outsource certain services such as, without limitation, document processing and translation services, confidential waste disposal, IT systems or software providers, IT Support service providers, document and information storage providers.
• Third parties engaged in the course of the services we provide to clients such as counsel, arbitrators, mediators, clerks, witnesses, court, opposing party and their lawyers, document review platforms and experts such as tax advisors.
• Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide the Services as effectively as we can.
We conduct an appropriate level of due diligence and put in place contractual documentation in relation to any sub-contractor to ensure that they process personal information appropriately and according to our legal and regulatory obligations.
How long do we keep your personal information for?
For service provision to any client, we will retain relevant personal information for at least six years from the date of our last interaction with that client and in compliance with our obligations under the EU General Data Protection Regulation, or for longer as we are required to do so according to our regulatory obligations or professional indemnity obligations. We may then destroy such files without further notice or liability.
If personal information is only useful for a short period e.g. for specific learning and development, we may delete it.
How to access your information and your other rights?
You have the following rights in relation to the personal information we hold about you:
• Your right of access
If you ask us, we’ll confirm whether we’re processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
• Your right to rectification
If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
• Your right to erasure
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
• Your right to restrict processing
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
• Your right to data portability
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
• Your right to object
You can ask us to stop processing your personal information, and we will do so, if we are:
o relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
o processing your personal information for direct marketing purposes.
• Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
• Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the relevant Supervisory Authority.
Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.
How to contact us
Lisa Price, Director 07810870243