We are committed to protecting the privacy of anyone interacting with us and will treat all information you give us carefully.
Where possible, our policies are written under the guidelines of the Plain English Campaign for ease of reading and interpretation.
We promise to:• Tell you why we collect personal information, how we do this and what we use it for• Only collect the information we need to deliver the service to you• Keep all personal information up to date and ensure it is safe and secure• Tell you why we can process your information• Tell you the reason we are processing your Personal Data• Tell you whether you must provide it to us• Tell you how long we shall retain it• Tell you whether there are other recipients of your personal information• Tell you whether we intend to transfer it outside of the UK• Whether we use automated decision-making
We may update this policy from time to time. The date this policy was last updated is shown at the end of this document.
As the Data Processor, we fully comply with the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (as amended) and the UK General Data Protection Regulations 2018 (UK GDPR 2018).
We are registered on the ICO Data Protection Register under registration number ZB482139 and at Companies House (England & Wales), Company number 10708051.
Our registered address is:33 Scottow Enterprise ParkLamas Road, Badersfield, Norwich, Norfolk, NR10 5FB
2 WHO WE ARE
In this policy, all references to “Claritest”, “we,” “us”, and “our” are to Claritest Ltd.We will process any personal information in accordance with the instructions received from the organisation requesting the testing. Therefore, we are considered the “Data Processor” and not the “Data Controller”.Our representative is Rachel Cooper, Quality Manager, email@example.com.
Our Data Protection Officer is Keith HebbornHebborn Consultancy Ltd. Tedder House, Tedder Close WattonNorfolk IP25 6HUkeith@hebborn.co.uk 0333 772 1510
3 WHAT INFORMATION DO WE COLLECT?
We collect personal information about you to enable us to provide the services or fulﬁl a role with us. This could include:• Your name• Date of birth• Gender• Photo identification• UK National Insurance number• List of any medications currently taken• In certain cases, a phone number/ email address• Test results, and information relating to test results
Some of this information is confidential, and shall be treated as ‘sensitive’ data, as defined by the Data Protection Act 2018. Testing results, any medical information and the reason for test are all considered to be ‘sensitive’.(Claritest Employees Only) In addition to the information above, we also need to collect further information about you:• Details of your employment• Your full name and address• Date and Country of Birth• National Insurance Number• Passport Number• Personal Bank Details• Personal Email address• Personal contact number
4 HOW DO WE COLLECT PERSONAL INFORMATION?
We collect personal information in the following ways:• When you make contact to enquire about our services• When you provide information by filling in a form on registration or information provided at any other time• Through the provision of our services to you• When you participate in discussion forums or other social media on our site or sites managed by us• When you contact us by email, telephone, social media or any other way• When you visit our website• When you sign in and out of our premises (Visitors Log)
5 HOW WE USE THE INFORMATION AND WHY WE NEED IT
We use the personal information to provide services to clients, guests, employees, visitors, and newsletter recipients or to meet our contractual commitments to you.
This may include:• Contract – if we have a contract with you, we will process your personal information to fulﬁl that contract• Consent – generally, we will only ask for your consent to process your personal information if there is no other legal ground to process it. Where we need your consent, we will ensure you are as fully informed as possible and use that consent solely for the reason you gave it to us. You can change your mind anytime by contacting us at the address in paragraph 14. Any email or text sent to you will have a link to let you do so (unsubscribe)• Public interest – we will process your personal information when performing a task in the public interest• When necessary, to defend legal claims or court action• Vital interests – When necessary, to protect your vital interests or those of another person• Employment – when necessary to fulﬁl our duties under employment law• Marketing – in addition to the processing, we will use your personal information to provide you with information about services you have requested or would reasonably expect to receive from us. You can change your mind anytime, and we will keep your preferences current. Any emails to you about marketing will have a link to let you unsubscribe.We do not use automated processing.
6 LEGITIMATE INTERESTS
Claritest may also process your Data when it is in our legitimate interest to do this and when these interests do not override your rights. These legitimate interests include:
• Keeping our records up to date• Statistical research and analysis to enable us to monitor and improve services• Sharing your personal information with people or organisations to comply with legal or regulatory obligations or enable us to run our organisation• To fulﬁl laws that apply to us and the third parties we work with• To take part in or be the subject of any merger, sale, or purchase of all, or part of, our business• Managing our relationships with you and third parties who assist us in providing you services, providing you with information on product services and oﬀers by partner service providers.
7 WHO WILL SEE THE INFORMATION?
Your information will only be accessible to our staﬀ, and only where appropriate regarding the role they are carrying out. We will never sell your information or let other organisations use it for their purposes. We will only share your personal information:• Where consent is necessary, we will have obtained your consent to us doing so and will provide information for the speciﬁc reason your consent was given. You will have the opportunity to withhold consent when you complete the form on which we collect the Data, or you can also contact us at the address in paragraph 13 at any time• Where it is necessary to protect your vital interest (i.e., your life or health)• Organisations or people whom we must share your personal information with by law or regulations• The police or other law enforcement agencies for them to perform their duties if we must do this by law or under a court order• Where (for employees) we use other organisations to provide services on our behalf for processing, such as payroll, pension accountancy and other outsourced HR administration• When using auditors and professional advisors and with your pension administrator• With our Shareholders• If we merge with another organisation, form a new entity, sell our business, or purchase a business• Where a third-party Data processor is used, we ensure they operate under a contract that includes conﬁdentiality and security of Personal Data and their obligations under the Data Protection legislation.
The security of your personal information is very important to us. We protect all Personal Data we hold and ensure we have appropriate organisational and technical measures in place to prevent unauthorised access or unlawful processing of Personal Data and to prevent Data from being lost, destroyed, or damaged.All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our site, you are responsible for keeping this password conﬁdential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Data before it reaches our site.
Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.Personal Data is processed in the UK; your information may be stored outside the European Economic Area (EEA) for IT hosting and maintenance.
9 YOUR RIGHTS
You have the following rights:• A right to transparency concerning how we use your personal information (right to be informed)• To request a copy of the information we hold about you, which will be provided to you within one month (right of access)• To require an update or amendment of the information we hold about you (right of rectification)• To ask us to stop using your information (right to restrict processing)• To ask us to remove your personal information from our records (right to be forgotten)• To request us to remove your information for marketing purposes (right to object)• To obtain and reuse your Data for your purposes (right to portability)• Not to be subject to decision-based automated processingYou can contact us concerning any of your rights at the address in paragraph 13. To protect your privacy, we may ask you to prove your identity before we formally respond to any request. There is no charge for a request, and we will respond to the request within one month.
If you are dissatisfied with how we deal with your request, contact the Information Commissioners Office at 0303 123 1113 or their website, www.ico.org.uk.
11 RETENTION OF INFORMATION
We keep your information only for as long as necessary for each purpose we use it. We use the following guidelines:• Any time limits set by law or recommended by regulators, professional bodies, or associations• For as long as we have a reasonable need to manage our relationship with you
More information concerning the retention and disposal of data can be found on our Retention andDisposal Policy within our Service Level Agreement.
For GDPR, the deﬁnition of ‘CCTV’ includes dash-cams in company vehicles or private vehicles used in Company business.
CCTV monitors our premises for the safety of visitors and staﬀ, and the security of the property. Images are retained for up to 30 days under ICO guidelines.
13 HOW TO CONTACT US
If you have any questions about how we collect, store, and use personal information, or if you have any other privacy-related questions, please get in touch with us by any of the following means:Telephone 0333 772 1510Email firstname.lastname@example.org
In writing Data Protection Officer Claritest33 Scottow Enterprise Park BadersﬁeldNorwichNorfolk NR10 5FB