Clearview Data Management Services Ltd (trading as Clearview Consulting) Privacy Notice
We are committed to protecting your privacy and complying with the principles set out in the General Data Protection Regulation (GDPR) and enforceable under the Data Protection Act 2018.
This notice explains how and why we collect your personal data and how it is used, and for the purposes of the relevant law we are the Data Controller. We are a company registered in England with the company number 11023123, at the registered office address 3 Whittons Close, Hook Norton, OX15 5QG .
We are committed to protecting the information you give us, and that we collect from you, which we use to provide you with the services you request from us.
You can access our web site and browse certain areas without disclosing personal data. We collect your personal data only with your knowledge, for instance when you contact us via email or telephone using the details on our contact page.
The information we collect includes your name, email address, phone number and the details of your message.
Third parties and International data transfers
We use service providers who process your data on our behalf in the following circumstances:
Hubspot: Hubspot provide a CRM (customer relationship management) system, and we store your contact details in Hubspot when you become a client of ours.
Mailchimp: Mailchimp are our email service provider and if you request our newsletter, your email address will be processed by Mailchimp in order for you to receive it. The email providing the newsletter will always contain an unsubscribe option.
These processors are based in the US, and both are signed up to the EU/US Privacy Shield agreement. At the moment this agreement is considered ‘adequate’ but the US are required to improve it before 1st September 2018 or lose this status. We will update this notice accordingly as a result of any decision taken.
Xero: Xero provide accounting software and we use it to prepare invoices. Data processed will therefore include your name and address if you are a customer of ours. Xero say the following about international transfers:
“Where your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data (like New Zealand), or to a third party where we have approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties”
Data Use, Retention and Legal Bases for holding your data
We use the data provided to contact you and discuss details of the services you are interested in, or information you have requested. If you download a document from our website, we will delete your data after we have provided it to you, unless you sign up to receive our newsletter. If you sign up to receive our newsletter, we will keep your data until you unsubscribe from the list.
We occassionally use licensed data to market to businesses, and we process this data on the basis of our legitimate interests in approaching organisations to promote our data management services. All emails contain a link to this privacy notice, an ‘unsubscribe’ link, and a contact email so that, if they wish, the recipient can contact us to object to the processing.
We will never give your details to anyone else for the purposes of them sending you marketing information. If we need to give your contact details to anyone else in the course of the business between us, or the services we are providing for you, we will always contact you first and record your agreement.
We will keep the data only for as long as we need to within our business relationship and will delete it when that purpose is complete.
There will be situations when we need to keep it for longer, such as within invoice details for tax reasons, and this is a ‘legal obligation’. We will keep only the minimum data we need for this purpose.
In order to contact you and provide our services to you, we need to hold your data on the basis of ‘contract fulfilment’.
Accessing Personal Data
You can contact us to ask whether we are holding any of your personal data, by sending an email to: firstname.lastname@example.org or writing by post to the address on the contact page. We are permitted to ask for identification, if necessary, to establish that you are entitled to receive the information, and we will supply it to you, without charge, within 30 days of your identity and entitlement being confirmed.
When you know what data we have, you can then ask us to delete, amend, or stop using it and we will do so unless there is any legal reason that prevents us – such as holding records for HMRC.
We have implemented security practices, rules and measures to protect the personal data that we have under our control, both on and off-line, from unauthorised access, improper use, alteration, unlawful or accidental destruction and accidental loss.
Find out more
If you have a complaint about the way we are using your personal data that you feel has not been resolved by contacting us, you can find out more about UK data protection laws, and can take your matter further, by visiting www.ico.org.uk.