Clearwater People Solutions Privacy Notice

Policy Statement

CLEARWATER PEOPLE SOLUTIONS LIMITED (“We”) are committed to protecting the privacy and security of personal data. This privacy notice explains how we collect, use, store and protect information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Our Group means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in Section 1159 of the UK Companies Act 2006. For the purpose of data protection legislation in force from time to time, our data controller is Office Manager of CLEARWATER PEOPLE SOLUTIONS LIMITED based at Cross Keys House, 2nd Floor, 50-52 The Broadway, Crawley, West Sussex, RH10 1HB. Registered Office: East Grinstead House, Wood Street, East Grinstead, West Sussex, RH19 1UZ.

Scope

This notice applies to all individuals whose data we process, including employees, customers, suppliers, and website visitors. It covers all personal data collected, whether provided directly or obtained through other sources.

Personal Data We Collect

We may collect and process the following types of personal data:

Name, address, email and contact details.
Employment and financial information.
IP addresses and online identifiers.
Compliance documentation and reference details.
Photographs and links to your professional profiles are available in the public domain (e.g., LinkedIn, Twitter, Facebook or corporate websites).
Any other data required to provide our services.

We may automatically collect the following information each time you visit our website or company profiles available on the public domain:

Technical information, including the Internet Protocol (IP) address used to connect your device to the internet, your login information if applicable, browser type, and version, browser plug-in types and versions, operating system, and platform.
Information about your visit, including the full Uniform Resource Locator (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our mainline number.

Personal Data We Collect from External Sources

We may collect and process personal data from external sources such as job board websites, LinkedIn, corporate websites, online CV libraries, your business card, personal recommendations, personal websites and portfolios and professional references.

In this case, we will inform you by telephone, email or by sending you this privacy notice, within a maximum of 30 days of collecting personal data, of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process our personal data.

How We Use Personal Data

We use personal data for the following purposes:

To provide and manage our services.
To communicate with customers and employees.
To comply with legal and regulatory requirements.
To improve our business operations and security.
For marketing with explicit consent where required.

Our legal basis for the processing of personal data is our legitimate business interests, although we will also rely on contract, legal obligation, and consent for specific uses of data:

Rely on Contract: We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
Rely on Legal Obligation: We will rely on legal obligation if we are legally required to hold information o you to fulfil our legal obligation.
Rely on Consent: We will in some circumstances rely on consent for use of your data and you will be asked for your express consent, if legally required. Examples when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).

Legal Basis for Processing

We process personal data under the following legal bases:

Performance of a contract.
Compliance with legal obligations.
Legitimate business interests.
Consent (for specific purposes, such as marketing).

Consent

Should we want or need to rely on consent to lawfully process your data, we will specifically request your consent orally, by email, or by an online process for the specific activity we require consent for and record your response on your system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this processing at any time.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site.

Data Sharing and Transfers

We do not sell personal data. We may share information with:

Service providers and partners assisting in our operations.
Regulatory authorities were required by law.
Third parties in connection with business transfers or legal matters.
Data processors ensuring compliance with security and privacy laws.

Data Retention

We retain personal data only as long as necessary for the purpose collected, in compliance with legal and regulatory requirements. Data no longer required is securely deleted or anonymised.

Data Security

We implement appropriate security measures to protect personal data from unauthorised access, alteration, or loss. These include encryption, access controls, and regular security measures.

Individual Rights

Under UK GDPR, individuals have the right to:

Access their personal data.
Request correction of inaccurate data.
Request deletion of personal data.
Restrict or object to processing.
Data portability where applicable.
Withdraw consent for processing where consent was given.
Lodge a complaint with the Information Commissioner’s Office (ICO).

Contact Information

For any queries or requests related to this Privacy Notice, please contact:

Office Manager

Email: info@clearwaterps.com

Address: Cross Keys House, 2nd Floor, 50-52 The Broadway, Crawley, West Sussex, RH10 1HB

Phone: 01293 217 444

Updates to this Privacy Notice

This Privacy Notice is reviewed regularly and updated as necessary to reflect changes in legislation or business practices. The latest version will always be available on our website.

Policy Statement

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Scope

This notice applies to all individuals whose data we process, including employees, customers, suppliers, and website visitors. It covers all personal data collected, whether provided directly or obtained through other sources.

​

Personal Data We Collect

We may collect and process the following types of personal data:

Name, address, email and contact details.

Employment and financial information.

IP addresses and online identifiers.

Compliance documentation and reference details.

Photographs and links to your professional profiles are available in the public domain (e.g., LinkedIn, Twitter, Facebook or corporate websites).

Any other data required to provide our services.

We may automatically collect the following information each time you visit our website or company profiles available on the public domain:

Technical information, including the Internet Protocol (IP) address used to connect your device to the internet, your login information if applicable, browser type, and version, browser plug-in types and versions, operating system, and platform.

Personal Data We Collect from External Sources

We may collect and process personal data from external sources such as job board websites, LinkedIn, corporate websites, online CV libraries, your business card, personal recommendations, personal websites and portfolios and professional references.

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How We Use Personal Data

We use personal data for the following purposes:

To provide and manage our services.

To communicate with customers and employees.

To comply with legal and regulatory requirements.

To improve our business operations and security.

For marketing with explicit consent where required.

Our legal basis for the processing of personal data is our legitimate business interests, although we will also rely on contract, legal obligation, and consent for specific uses of data:

Rely on Contract: We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.

Rely on Legal Obligation: We will rely on legal obligation if we are legally required to hold information o you to fulfil our legal obligation.

Rely on Consent: We will in some circumstances rely on consent for use of your data and you will be asked for your express consent, if legally required. Examples when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).

Legal Basis for Processing

We process personal data under the following legal bases:

Performance of a contract.

Compliance with legal obligations.

Legitimate business interests.

Consent (for specific purposes, such as marketing).

Consent

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Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site.

​

Data Sharing and Transfers

We do not sell personal data. We may share information with:

Service providers and partners assisting in our operations.

Regulatory authorities were required by law.

Third parties in connection with business transfers or legal matters.

Data processors ensuring compliance with security and privacy laws.

Data Retention

We retain personal data only as long as necessary for the purpose collected, in compliance with legal and regulatory requirements. Data no longer required is securely deleted or anonymised.

​

Data Security

We implement appropriate security measures to protect personal data from unauthorised access, alteration, or loss. These include encryption, access controls, and regular security measures.

​

Individual Rights

Under UK GDPR, individuals have the right to:

Access their personal data.

Request correction of inaccurate data.

Request deletion of personal data.

Restrict or object to processing.

Data portability where applicable.

Withdraw consent for processing where consent was given.

Lodge a complaint with the Information Commissioner’s Office (ICO).

Contact Information

For any queries or requests related to this Privacy Notice, please contact:

Office Manager

Email: info@clearwaterps.com

Address: Cross Keys House, 2nd Floor, 50-52 The Broadway, Crawley, West Sussex, RH10 1HB

Phone: 01293 217 444

​

Updates to this Privacy Notice

This Privacy Notice is reviewed regularly and updated as necessary to reflect changes in legislation or business practices. The latest version will always be available on our website.