General Privacy Notice
Your personal data – what is it?
“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be directly using the data itself or by combining it with other information which helps to identify a living individual (e.g. a list of staff may contain personnel ID numbers rather than names but if you use a separate list of the ID numbers which give the corresponding names to identify the staff in the first list then the first list will also be treated as personal data). The processing of personal data is governed by legislation relating to personal data which applies in the United Kingdom including the General Data Protection Regulation (the “GDPR) and other legislation relating to personal data and rights such as the Human Rights Act.
Who are we?
This Privacy Notice is provided to you by Cluson Engineering Ltd which is the data controller for your data.
Other data controllers the company works with:
We may need to share your personal data we hold with them so that they can carry out their responsibilities to the company. If we and the other data controllers listed above are processing your data jointly for the same purposes, then the company and the other data controllers may be “joint data controllers” which mean we are all collectively responsible to you for your data. Where each of the parties listed above are processing your data for their own independent purposes then each of us will be independently responsible to you and if you have any questions, wish to exercise any of your rights (see below) or wish to raise a complaint, you should do so directly to the relevant data controller.
A description of what personal data the company processes and for what purposes is set out in this Privacy Notice.
The company will process some or all of the following personal data where necessary to perform its tasks:
How we use sensitive personal data
Do we need your consent to process your sensitive personal data?
The company will comply with the General Data Protection Regulation 2018. This says that the personal data we hold about you must be:
We use your personal data for some or all of the following purposes:
Our processing may also include the use of CCTV systems for the prevention and prosecution of crime.
What is the legal basis for processing your personal data?
The company has certain powers and obligations. Most of your personal data is processed for compliance with a legal obligation which includes the discharge of the company’s statutory functions and powers. We will always take into account your interests and rights. This Privacy Notice sets out your rights and the company’s obligations to you.
We may process personal data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract.
Sometimes the use of your personal data requires your consent. We will first obtain your consent to that use.
Sharing your personal data
This section provides information about the third parties with whom the company may share your personal data. These third parties have an obligation to put in place appropriate security measures and will be responsible to you directly for the manner in which they process and protect your personal data. It is likely that we will need to share your data with some or all of the following (but only where necessary):
How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is currently best practice to keep financial records for a minimum period of 8 years to support HMRC audits or provide tax information. We may have legal obligations to retain some data in connection with our statutory obligations. The company is permitted to retain data in order to defend or pursue claims. In some cases the law imposes a time limit for such claims (for example 3 years for personal injury claims or 6 years for contract claims). We will retain some personal data for this purpose as long as we believe it is necessary to be able to defend or pursue a claim. In general, we will endeavour to keep data only for as long as we need it. This means that we will delete it when it is no longer needed.
Your rights and your personal data
You have the following rights with respect to your personal data:
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
1) The right to access personal data we hold on you
2) The right to correct and update the personal data we hold on you
3) The right to have your personal data erased
4) The right to object to processing of your personal data or to restrict it to certain purposes only
5) The right to data portability
6) The right to withdraw your consent to the processing at any time for any processing of data to which consent was obtained
7) The right to lodge a complaint with the Information Commissioner’s Office.
Transfer of Data Abroad
Any personal data transferred to countries or territories outside the European Economic Area (“EEA”) will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union.
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Changes to this notice
We keep this Privacy Notice under regular review and we will place any updates on www.cluson.co.uk [https://clulite.cluson.co.uk]. This Notice was last updated in February 2018.
Please contact us if you have any questions about this Privacy Notice or the personal data we hold about you or to exercise all relevant rights, queries or complaints at:
The Data Controller, Cluson Engineering Ltd, 6 Bedford Road, Petersfield, Hampshire, GU32 3LJ
Telephone: 01730 264672