Privacy Notice for Clarity Procurement Solutions Ltd

Clarity Procurement Solutions is committed to protecting your personal data and to ensuring that your rights to privacy are protected. We will collect data from you at a number of points, including via account or tender registration forms (both online and paper). Your personal data will be stored on secure databases and access will be permitted only to those with a need to know.

In order to be open and transparent, Clarity Procurement Solutions Ltd wants you to know that:

1. Clarity Procurement Solutions is the Data Controller of the information it holds or will hold on you.

2. Clarity Procurement Solutions Ltd has a nominated person for data protection, and contact details for this person may be obtained by requesting them from us by telephone at 01942 725438, or via email at nathan@clarityprocurement.co.uk.

3. The information we collect from you and subsequently process may include:

3.1 your contact details (e.g. name, address, telephone numbers, email address etc.);

3.2 business activities of the person whose personal information we are processing;

3.3 goods and services provided;

3.4 financial details;

3.5 education details;

3.6 employment details, and any other data that is relevant to the legitimate aims of Clarity Procurement Solutions.

4. The information held on customers may be collected from forms, tender documents and letters, emails, on-line applications, written material, verbal discussions, and text messages etc.

5. The information is collected and will be processed so that Clarity Procurement Solutions may:

5.1 comply with our contractual obligations and provide you with your agreed level of service, including;

5.1.1 contacting you in relation to, and arranging matters relating to our services;

5.1.2 contacting you to advise you of upcoming events or opportunities which may be of interest to you;

5.1.3 arranging, maintaining, managing and taking other steps in relation to your and/or your businesses operation;

5.1.4 providing you with general news about Clarity Procurement Solutions (including information about other products and ways we can assist your business), with the newsletter and e-newsletter (in both paper and electronic format); and

5.2 collate management information, to adjust our services accordingly;

5.3 ascertain, verify and analyse compliance with anti-money laundering regulations; and

5.4 evaluate the effectiveness of our services.

6. In particular, Clarity Procurement Solutions has the following legal bases for the processing of your personal data:

6.1 For non-special / non-sensitive data:

6.1.1 where it is necessary for the performance of any contract you may have with Clarity Procurement Solutions, or to take steps to enter into such a contract; and

6.1.2 where it is necessary for the purposes of Clarity Procurement Solution’s legitimate interests.

6.2 For special / sensitive data:

6.2.1 where it has been manifestly made public by you; and

6.2.2 where it is necessary for statistical purposes in accordance with Article 89 of the General Data Protection Regulation, in a manner which provides for suitable and specific measures to safeguard the fundamental rights and the interests of you (including pseudonymisation and/or anonymisation).

7. In addition to the above bases, Clarity Procurement Solutions may also process any of your personal data for other reasons where it has received your explicit, freely given consent.

8. The information may be shared with third parties for administration and/or management purposes, where it is necessary and lawful for Clarity Procurement Solutions to do so. However, Clarity Procurement Solutions will share only the minimum information that is necessary. Such sharing of information will include the following:

8.1 provided you have given consent, we will share information (including sensitive personal data and/or special categories of data) with our insurers and insurance brokers (including Your Insurance broker) for the purposes of arranging, maintaining, managing and taking other steps in relation to your and/or our insurance;

8.2 we will share information with our partners so that we are able to comply with our contractual obligations and provide you with your agreed contractual services, including but not limited to the following parties:

8.2.1 Microsoft Office 365 – Privacy Notice Link for their website is as follows – https://privacy.microsoft.com/en-gb/privacystatement;

8.2.2 Delta eSourcing – Privacy Notice Link for their website is as follows – https://www.delta-esourcing.com/privacy-policy/;

8.2.3 Dropbox – Privacy Notice Link for their website is as follows – https://www.dropbox.com/privacy.

8.3 we will share information with the following parties on the basis that it is necessary for the purposes of our legitimate interests, including the following parties:

8.3.1 law enforcement; and

8.3.2 the relevant revenue and customs service.

9. The information will not be processed outside the EEA without your prior written consent.

10. The information will be retained for as long as is necessary and in accordance with clause 11 below. When the information is no longer required, it will be destroyed securely.

11. You have certain rights, which include:

11.1 the right to obtain access to your personal data (what personal data of yours Clarity Procurement Solutions holds);

11.2 the right to have personal data rectified if it is inaccurate or incomplete;

11.3 the right to request the deletion or removal of personal data where we are not otherwise entitled to retain and process such data and there is no compelling reason for its continued processing;

11.4 the right to restrict or suppress the processing of your personal data, in certain circumstances. Further information is available upon request;

11.5 the right to withdraw consent at any time, where relevant; and

11.6 the right to lodge a complaint with a supervisory authority (the Information Commissioner’s Office) The ICO can be contacted on 0303 123 1113, Monday- Friday 9am-5pm or via this link https://ico.org.uk/concerns.

If you wish to exercise any of these rights, please contact us by telephone at 01942 725438, or via email at nathan@clarityprocurement.co.uk for details of how an application may be made.