Privacy Policy 2018-05-23T09:26:36+00:00

Privacy Policy

The purpose of this statement is to provide information regarding how and why The Clarion Group of Companies collect, process and store data, as well as providing the appropriate contact information should you wish to request the information we hold about you, withdraw from processing or request deletion of any data we hold about you.

Under the EU General Data Protection Regulation (GDPR) there are six lawful bases for processing personal data.  These are detailed as follows:

  • Consent – the individual has given clear consent for you to process their personal data for a specific purpose

  • Contract – the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract

  • Legal Obligation – the processing is necessary for you to comply with the law (not including contractual obligations)

  • Vital Interests – the processing is necessary to protect someone’s life

  • Public Task – the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law

  • Legitimate Interests – the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)

Further information regarding the lawful basis for processing personal data can be found at ico.org.uk

For your information The Clarion Group of Companies is comprised of: Clarion Communication Management Ltd (CCM), Clarion Communication Information Technology Ltd (CCIT), and Clarion Communication Systems Ltd which is also trading as SystemsXchange and Commswarehouse.

The Clarion Group of Companies Marketing and Sales Data

As an organisation that processes business related data, The Clarion Group of Companies has assessed all six grounds for lawful processing of personal data and has selected ‘Legitimate Interests’ as the most suitable lawful ground for the processing of data for the purposes of The Clarion Group of Companies marketing and sales.

The Clarion Group of Companies collects, processes and stores data relating to businesses and decision makers.  We believe that the individuals that we process the data of, are likely to have an interest in The Clarion Group of Companies products and/or services.  Deemed as ‘Legitimate Interest’ this is based upon specific criteria including the business industry sector, size of organisation as well as the individual’s job function within the organisation.  Our typical segmentation includes those within marketing, sales, business development, Finance, MD and owner related job functions, although this list is not exhaustive and other variables may apply.

We will only ever collect, process and store the essential information required for making contact with the data subjects within a business environment.  The personal data we collect is limited to first name, last name, email address, social profiles (limited to Linkedin) as well as business IP and physical address.  Other business-related data may also be processed including business name, job function, and turnover, however we will never collect further personal data such as those classed under ‘Special Categories of Personal Data’.

The data collected will be used to communicate marketing and sales messages relating to The Clarion Group of Companies products and services, based upon the job function held by the data subject.  The Clarion Group of Companies specifically only sends messages to those we believe are likely to be interested in The Clarion Group of Companies products and services based upon the organisation they are employed by and based upon their job function within that organisation.  Messages from The Clarion Group of Companies could be delivered via email, social media, via telephone or any other business to business (B2B) marketing methods that may be relevant.

When you send The Clarion Group of Companies an enquiry or booking form via our website or one of our micro sites you will be asked to provide your contact details. We will use the data you provide to process your request and may use it to inform you by email, telephone or mail about other Clarion Group of Companies products and services that we feel may be of interest to you. It is deemed that if you have visited one of The Clarion Group of Companies websites and provided us with your contact information that you are legitimately interested in our products and services.  You have the right to object from any method of correspondence at any time, using the unsubscribe button on an email, by informing the telephone operator or by contacting us via any of the methods below.

How we Procure Data

At The Clarion Group of Companies we procure data in a variety of ways, collected in line with the lawful basis of ‘Legitimate Interests’.  If you have received correspondence from us, we will have procured your data in one of the following ways:

  • You have requested information from The Clarion Group of Companies on a previous occasion

  • Someone has sent us your e-mail address requesting information about our articles and/or services be sent to you.

  • You or someone else has expressly shared your contact details with us for the purpose of receiving information now and/or in the future

  • We have previously met at an event and your business card or contact details were handed to us willingly

  • You or a business colleague has visited our website and we believe that there is a genuine legitimate interest in our services

  • You have previously connected with a member of our team via Linkedin and discussed our services

  • A member of our team has found your business and your contact details online, believing that your business would genuinely be interested in The Clarion Group of Companies products and/or services. And based upon your job function aligning with our typical customer profiles they have made contact to introduce you to our products and services.

  • Your data has been purchased from a registered third party data supplier, which will have been segmented by industry, organisation size and job function based upon our typical customer profiles and the legal basis for our processing of this data has been established and verified.

Email marketing tracking

Tracking email opens

When we send marketing emails promoting any of the Clarion Group of Companies products and services we employ a common software technology called beacons. Beacons are tiny 1px x 1px graphics with a unique identifier, similar in function to cookies, and are used to track if you have opened a marketing email. We use these in our HTML-based emails to let us know which emails have been opened by recipients. They allow us to gauge the effectiveness of certain communications, and the effectiveness of our marketing campaigns. We also combine the information gathered by beacons in emails to our customers’ personal data. If you would like to opt-out of these emails you can do so by clicking on the unsubscribe link in the footer of each email we send you.

Tracking email clicks

When we send marketing emails promoting any of The Clarion Group of companies products and services we personalise each link in each email with unique code to enable us to track whether the recipient has clicked on the link in the email. This allows us to gauge the effectiveness of certain communications, and the effectiveness of our marketing campaigns. We also combine the information gathered by beacons in emails to our customers’ personal data. If you would like to opt-out of these emails you can do so by clicking on the unsubscribe link in the footer of each email we send you.

Legitimate Interest Assessment (LIA)

The Clarion Group of Companies has carried out a Legitimate Interest Assessment (LIA) as advised by the ICO.  Based upon that assessment it is deemed that the rights and freedoms of the data subjects would not be overridden in our correspondence regarding The Clarion Group of Companies and that in no way would a data subject be caused harm by our correspondence. Based upon our segmentation by organisation and by specific job function, coupled with our processing of personal data within the context of a business environment, we believe that any individual that receives correspondence from The Clarion Group of Companies in a direct marketing or sales capacity, could be legitimately interested in The Clarion Group of Companies solution.  It is also deemed that direct marketing and sales is necessary in the context of promoting The Clarion Group of Companies to professionals in business in order to increase awareness of our ICT Products and services.

Per the ICO guidance, The Clarion Group of Companies can confirm:

  • We have checked that legitimate interests is the most appropriate basis

  • We understand our responsibility to protect the individual’s interests

  • We have conducted a legitimate interests assessment (LIA) and kept a record of it, to ensure that we can justify our decision

  • We have identified the relevant legitimate interests

  • We have checked that the processing is necessary and there is no less intrusive way to achieve the same result

  • We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests

  • We only use individuals’ data in ways they would reasonably expect

  • We are not using people’s data in ways they would find intrusive or which could cause them harm

  • We do not process the data of children

  • We have considered safeguards to reduce the impact where possible

  • We will always ensure there is an opt-out / ability to object

  • Our LIA did not identify a significant privacy impact, and therefore we do not require a DPIA

  • We keep our LIA under review every six months, and will repeat it if circumstances change

  • We include information about our legitimate interests in this privacy notice

The Clarion Group of Companies has an in-house data verification team, who are responsible for ensuring the validity and quality of the data contained within The Clarion Group of Companies CRM system.

Data Storage and Retention

The data held within The Clarion Group of Companies CRM system is processed and stored in the UK within a secure environment.

We will use your data to update you with details of our product and service offerings, However, we will delete your data should you no longer show interest in these details at a time 5 years after the last verifiable contact we have with you.

Security of personal data

Appropriate measures

We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse, or alteration of your personal data.

Secure storage

We will store all your personal data on secure servers, personal computers, and mobile devices, and in secure manual record-keeping systems.

Password storage

Any passwords you provide us will be stored by us in encrypted form.

Financial transactions

Data relating to financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

Acknowledgement of you transmitting unencrypted data

You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of that data sent over the internet

Providing your personal data to others

In this Section, we provide you with information about which third parties we may pass your data to.

Our group companies

We may share your personal data within our group of companies (this means our subsidiaries, our ultimate holding company, and all its subsidiaries) insofar as is reasonably necessary for the purposes set out in this policy.

Our technical providers

Your personal data may be stored in our data centre, on our telephony system and servers where it may be accessed by third party administrators insofar as is reasonably necessary for the safe and efficient storage of your data. We may use third parties such as email service providers and campaign analytics services who may process your personal data at our request in order to maximise the efficiency of our communications with you.

Our payment providers

Financial transactions relating to our website and services may be handled by our payment services providers, PayPal and Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries relating to such payments and refunds.

Our productivity and communication application providers

We may use your personal data in our internal productivity and communication applications insofar as is reasonably necessary for the purposes of proper administration of our website and business.

For compliance with a legal obligation

In addition to the specific disclosures of personal data set out in this Privacy Policy, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Right to Object

In all correspondence with you we will give you the right to object from receiving further correspondence from The Clarion Group of Companies.  On any emails you receive from The Clarion Group of Companies there will be the option to ‘unsubscribe’ from receiving any further email correspondence.  If you receive a telephone call from us, you have the right to request not to receive any further calls.  The Clarion Group of Companies has a companywide CRM system. Your request to object will be logged within our CRM system to ensure that you do not receive any further calls.

Should you wish to object to receiving communication from The Clarion Group of Companies, you can do so in a variety of ways:

  • Please click the ‘unsubscribe’ link at the bottom of every email

  • If you have received a call, please tell the representative that you do not wish to receive any further communication

  • Please call 0333 222 6633 and ask to speak with the Data Compliance Team

You can also make your request by emailing:

data-compliance@clarioncomms.com 

Or by writing to:

Data Compliance, The Clarion Group of Companies, Unit W.01, Canalot Studios, 222 Kensal Road, London W10 5BN

All requests will be processed within 30 days. Your details will be added to a suppression file to ensure that your details cannot be processed by The Clarion Group of Companies CRM system in the future.  Please note this applies only to the processing of your personally identifiable data, not that of the business data which does not fall under the remit of GDPR.

Right to Request Erasure

It is important to understand the difference between a right to object and a request for deletion.  If you make a request for deletion, we will remove any data we hold about you from The Clarion Group of Companies CRM system.  This will also mean that we will remove you from our suppression files.  If you are removed from our suppression files, there is a risk that your data may be processed again in the future if your details are re-added to our CRM system by a member of our sales team who genuinely believes that your business would benefit from The Clarion Group of Companies.  If you do not wish for us to contact you again about The Clarion Group of Companies products and services, we would recommend you request to object rather than make a request for deletion, as this will ensure that your details are always suppressed from processing.

The option however is yours, and in either case we will process your request within 30 days.

Please make your request in writing by emailing: 

data-compliance@clarioncomms.com

Or by writing to:

Data Compliance, The Clarion Group of Companies, Unit W.01, Canalot Studios, 222 Kensal Road, London W10 5BN

Right to Access

You may request that we send you all of the data we hold that relates to you.  Please make your request in writing;

By emailing:

data-compliance@clarioncomms.com

Or by writing to:

Data Compliance, The Clarion Group of Companies, Unit W.01, Canalot Studios, 222 Kensal Road, London W10 5BN

We will process and respond to your request within 30 days, this service will be free of charge.

Under the GDPR you have a number of data privacy Rights including those listed above. For more information on these rights please see the website of the Information Commissioner’s Office at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

This policy was last reviewed and updated on the 10th May 2018.  Policies are periodically reviewed to ensure compliance with the current compliance environment.

For questions relating to this policy, please contact: 

data-compliance@clarioncomms.com 

For further information on the GDPR as well as other Data Protection and Data Privacy issues and regulations please visit www.ico.org.uk

The Clarion Group of Companies Limited is registered with the Information Commissioner’s Office under registration reference: Z186878X