Clear Core Limited Privacy Policy

Who we are

Clear Core

Devonshire House
60 Goswell Road
London
EC1M 7AD

Introduction

Clear Core Limited trading as ClearComm (“we”, “us”, or “our”) are committed to protecting and respecting the personal data that we hold. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights.

It applies to personal data provided to us, both by individuals themselves or by others on behalf of individuals. We may use personal data provided to us for the purposes described in this privacy statement or as made clear in another form before collecting personal data.

Personal Data

Personal Data is defined as “any information relating to an identified or identifiable natural person (‘data subject’); by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose differ, and are set out in the relevant sections below.

The personal data that is provided to us is provided either directly from the individual concerned, from a third party acting on behalf of an individual, or from publicly available sources (such as internet searches, and Companies House).

Where we receive personal data from a third party that relates to an individual, we request that this third party inform the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.

Individual’s rights

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights as follows:

1. The right of access.
2. The right to rectification.
3. The right to erasure or right to be forgotten.
4. The right to restriction of processing.
5. The right to be informed.
6. The right to data portability.
7. The right to object.
8. The right not to be subject to a decision based solely on automated processing.

If you wish to exercise any of these rights, please contact us at dataprivacy@ks.co.uk.

The Data Controller

A Data Controller is the individual or legal person who controls and is responsible to keep and use personal data in paper or electronic files. We are the data controller as defined by relevant data protection laws and regulation.

Lawful Processing

The lawful bases for processing are set out in Article 6 of the GDPR. At least one of these must apply whenever personal data is to be processed:

(a) Consent: you have given ClearComm clear consent for your personal data to be processed for a specific purpose.
(b) Contract: the processing is necessary for a contract you have with ClearComm, or ClearComm has asked you to take specific steps before entering into a contract.
(c) Legal obligation: the processing is necessary for ClearComm to comply with the law (not including contractual obligations).
(d) Vital interests: the processing is necessary to protect someone’s life.
(e) Public task: the processing is necessary for ClearComm to perform a task that is in the public interest or for its official functions, and the task or function has a clear basis in law.
(f) Legitimate interests: the processing is necessary for ClearComm’s legitimate interests, or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data that overrides those legitimate interests.

Security

We take the security of all the data we hold seriously. Staff are trained on data protection, confidentiality and security, and we maintain a culture of confidentiality.
We have a framework of policies and procedures which ensure that we keep the data we hold secure.
All information you provide to us is stored on our locally hosted secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask that you do not share your password with anyone.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Why do we process data?
Where data is collected for professional services, it is used for numerous purposes, such as but not limited to;
• Providing services to clients
• Client management
• Administration
• Regulatory
How long do we hold data for?
We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years).

Security

We take the security of all the data we hold seriously. Staff are trained on data protection, confidentiality and security, and we maintain a culture of confidentiality.
We have a framework of policies and procedures which ensure that we keep the data we hold secure.
All information you provide to us is stored on our locally hosted secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask that you do not share your password with anyone.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Why do we process data?
Where data is collected for professional services, it is used for numerous purposes, such as but not limited to;
• Providing services to clients
• Client management
• Administration
• Regulatory
How long do we hold data for?
We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years).

People who visit our offices

Personal data is collected when individuals visit our offices via CCTV and a visitor’s sign-in book. We have security in place at our offices, for the physical security of client information and for the benefit of our staff.
Signs in our office reception confirm that CCTV is in operation. The images are held securely and only accessed when needed when investigating an incident.

Website and mobile apps

When data subjects visit our website, personal data is collected both through automated tracking and interactions with various forms on the website or apps (collectively referred to as the websites).
Personal data may also be collected when individuals correspond with us by phone, e-mail or otherwise. This includes information provided when an individual may register to use our websites, subscribes to our services, applies to work for a ClearComm or reports a problem with our websites.

Why do we process data?

There are numerous reasons why we will process the personal data that an individual may provide to us when visiting our websites. As examples, these include;
• Administration
• Functionality
• Security
• Promotion and development of our offerings.
The data that we hold depends on what data was entered and for what purpose.
Where data is collected automatically, the data that we may collect includes technical information, including the Internet protocol (IP) address used to connect an individual’s computer to the internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
Our website uses cookies to distinguish individuals from one another. This helps us to provide a better experience when individuals browse our website.

How long do we hold data for?

We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years).

Sharing personal data

We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

Location of processing

As a data controller ClearComm will retain all your information inside the European Economic Area (EEA).
Where personal data may be transferred to, and stored at, a destination outside the European Economic Area (EEA) (to a country without an adequacy rating) ClearComm will take all reasonable steps to ensure that your data is processed in accordance with the Data Protection Act 2018 and GDPR.

Complaints

If you do want to complain about our use of personal data, please send an email with the details of your complaint to dataprivacy@ks.co.uk.

You also have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner’s Office (“ICO”). For further information on how to reach to the ICO, please refer to the ICO website https://ico.org.uk/concerns or Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Telephone: 0303 123 1113

Data controller and contact information
The data controller for Clear Core Limited registered in England under registration no. 10521104 and with its registration address at Devonshire House, 60 Goswell Road, London EC1M 7AD).

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Head of Data Privacy
Clear Core Limited
Devonshire House
60 Goswell Road
London EC1M 7AD

Email: dataprivacy@ks.co.uk
Phone: 020 7566 4000

Changes to our privacy statement
Updates to this privacy statement will appear on this website. This privacy statement was last updated on 24th April 2019.