Privacy Policy

CLEAR TRAININGS LTD

Clear Trainings LTD

07874 646 044

contact@cleatrainings.co.uk

GDPR Data Protection Policy

PRIVACY POLICY

INTRODUCTION

At Clear Trainings LTD we care about your privacy and personal data. It is our policy to respect your privacy regarding any information we may collect from you across our website, https://cleartrainings.co.uk.

Clear Trainings hold personal data about our employees, clients, suppliers, and other individuals for a variety of business purposes.

This policy sets out how we seek to protect personal data and ensure that staff understand the rules governing their use of personal data to which they have access in the course of their work. 

                                                                                            PRIVACY POLICY

                                                                                               DEFINITIONS

                                          THE PURPOSES FOR WHICH PERSONAL DATA MAY BE USED BY US:

Personnel, administrative, financial, regulatory, payroll and business development purposes, record keeping of training date for clients, marketing purposes and communication purposes.

Business purposes include the following:

• Compliance with our legal, regulatory, and      corporate governance obligations and good practice.
• Gathering information as part of investigations      by regulatory bodies or in connection with legal proceedings or requests.

· Ensuring business policies are adhered to (such as policies covering email and internet use).

· Operational reasons, such as recording transactions, training, and quality control, ensuring the confidentiality of commercially sensitive information, security vetting, credit scoring and checking.

· Investigating complaints.

· Checking references, ensuring safe working practices, monitoring, and managing staff access to systems and facilities and staff absences, administration, and assessments.

· Monitoring staff conduct, disciplinary matters.

· Marketing our business.

· Improving services.

SCOPE

This policy applies to all staff. Staff must be familiar with this policy and comply with its terms.

We may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted.

WHAT INFORMATION DO WE COLLET?

When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details.

Personal information

We may ask for personal information, such as your:

· Name

· Email

· Phone/mobile number

· Job role

· Experience

· Employer name

Business information

We may ask for your business information such as:

· Business name

· Business address

· Business email

· Business phone number

· Company number (for invoicing purposes)

· Company UTR (for invoicing purposes)

                                                                                         OUR  PROCEDURES

Fair and lawful processing.

Clear Trainings LTD will process personal data fairly and lawfully in accordance with individuals' rights. Training will be provided to ensure that all staff know what this means in practise and our processes are designed to maintain company compliance with current personal data protection law and regulation. 

The principles we must follow in relation to Data Protection:

The data we collect will be:

· Processed lawfully, fairly and in a transparent manner in relation to the data subject ('lawfulness, fairness and transparency');

· Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);

· Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);

· Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (accuracy');

· Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (storage limitation');

• Processed in a manner that ensures appropriate      security of the personal data, including protection against unauthorised      or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures (integrity and confidentiality').
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Accuracy and relevance

· We will ensure that any personal data we process is accurate, adequate, relevant, and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.

· Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform Clear Trainings LTD.

Your personal data

· You must take reasonable steps to ensure that personal data we hold about you is accurate and updated as required. For example, if your personal circumstances change, please inform the Clear Trainings LTD so that we can update your records.

Data security

· You must keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, the Clear Trainings LTD will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.

Storing data securely

• In cases      when data is stored on printed paper, it should be kept in a secure place      where unauthorised personnel cannot access it.
• Printed      Personal data must not be left unattended or in view and data should be      shredded when it is no longer needed. When not in use printed or hard      copies of Personal data must be stored in a secure environment.

· Data stored on a computer should be protected by strong passwords (please refer to the information security policy).

· Data stored on CDs or memory sticks must be locked away securely when they are not being used.

· The Management of Clear Trainings LTD must approve any cloud used to store data.

· Servers containing personal data must be kept in a secure location, away from general office space.

· Data should be regularly backed up in line with the company's backup procedures.

· All servers containing sensitive data must be approved and protected by security software and strong firewall.

Data retention

· Personal data may only be retained based on a 'current' lawful basis and legitimate purpose. We must retain personal data for no longer than is necessary.

                                                                               SUBJECT ACCESS REQUERSTS

Please note that under the General Data Protection Regulation, individuals are entitled, subject to certain exceptions, to request access to information held about them.

If staff will receive a subject access request, they should refer that request immediately to the management team. 

Please contact the Clear Trainings LTD if you would like to correct or request information that we hold about you. There are also restrictions on the information to which you are entitled under applicable law.

Processing data in accordance with the individual's rights

• Staff should abide by any request from an individual not to use their      personal data for direct marketing purposes and notify the management team      about any such request.
• Staff to contact the management team for advice on direct marketing      before starting any new direct marketing activity.

Training

• All staff will receive training on this policy. New joiners will      receive training as part of the induction process. Further training will      be provided at least every six months or whenever there is a substantial      change in the law or our policy and procedure.

· Training is provided through an in-house seminar on a regular basis, and it will cover:

• The law relating to data protection.
• Our data protection and related policies and procedures.

o Completion of training is compulsory.

                                                                                             GDPR PROVISIONS

Where not previously specified in this policy, the following provisions will be in effect with regards to GDPR.

                                                       PRIVACY NOTICE - TRANSPARENCY OF DATA PROTECTION

Being transparent and providing accessible information to individuals about how we will use their personal data is important for our organisation. The following is the information that every privacy notice needs to include:

• Identity and contact details of the controller.
• Purpose and lawful basis for processing.
• Legitimate interests of the controller and third party, where      applicable.
• The categories of data held (not required if data came from the      subject).
• Any recipient or categories of recipients of the personal data.
• Details of transfers to third countries and safeguards.

· Retention period or criteria used to determine the retention period of the data.

· The existence of each of the data subjects’ rights.

· The right to withdraw consent at any time, where relevant.

· The right to lodge a complaint with a supervisory authority.

· The source of the personal data and whether it came from publicly accessible sources (not required if data came from the subject).

· Whether the personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data.

· The existence of automated decision making, including profiling, and information about how decisions are made, the significance and the consequence.

Conditions for processing

Clear Trainings LTD will ensure any use of personal data is justified using at least one of the lawful conditions for processing and this will be specifically documented. All staff who are responsible for processing personal data will be aware of the conditions for processing. The conditions for processing will be available to data subjects in the form of a privacy notice.

                                                                         JUSTIFICATION FOR PERSONAL DATA

We will process personal data in compliance with all six data protection principles.

We will document the additional justification for the processing of sensitive data.

                                                                                                   CONSENT

The personal data that we collect is subject to a positive action by the subject, which needs to be documented, to validate that 'Consent' is the lawful basis for processing that personal data. Consent can be revoked but the subject at any time.

                                                                                 CRIMINAL RECORD CHECKS

Any criminal record checks are justified by law. Criminal record checks cannot be undertaken based solely on the consent of the subject.

                                                                                          DATA PORTABILITY

Upon request, a data subject should have the right to receive a copy of their data in a structured format. These requests should be processed within one month, provided there is no undue burden, and it does not compromise the privacy of other individuals. A data subject may also request that their data is transferred directly to another system. This must be done for free.

                                                                                   RIGHT TO BE FORGOTTEN

A data subject may request that any information held on them is deleted or removed, and any third parties who process or use that data must also comply with the request. An erasure request can only be refused if an exemption applies.

                                                                         INTERNATIONAL DATA TRANSFERS

The personal information we collect is stored and processed in United Kingdom, or where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties (if any).

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.

Reporting breaches

All members of staff have an obligation to report actual or potential data protection compliance failures. This allows us to:

• Investigate the failure and take      remedial steps if necessary
• Maintain      a register of compliance failures
• Notify the Supervisory      Authority (SA) of any

· compliance failures that are material either in their own right or as part of a pattern of failures

Please refer to our Compliance Failure Policy for our reporting procedure.

Monitoring

Everyone must observe this policy. The management has overall responsibility for this policy. They will monitor it regularly to make sure it is being adhered to.

                                                                  CONSEQUENCES OF FALING TO COMPLY

We take compliance with this policy very seriously. Failure to comply puts both you and the organisation at risk.

The importance of this policy means that failure to comply with any requirement may lead to disciplinary action of staff under our procedures which may result in dismissal. If you have any questions or concerns about anything in this policy, do not hesitate to contact the management team.

Business transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy.

Limits of our policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites and cannot accept responsibility or liability for their respective privacy practices.

CHANGES TO THIS POLICY

At our discretion, we may change our privacy policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. Your continued use of this site after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.

If we make a significant change to this privacy policy, for example changing a lawful basis on which we process your personal information, we will ask you to re-consent to the amended privacy policy.

Clear Trainings LTD – Data Controller

Bogdan Chitac

contact@cleartrainings.co.uk