Privacy Notice - Suppliers and Business Contacts

Clugston Group Ltd provides construction, distribution, facilities management and property services. To support its business the Company uses a number of suppliers/business contacts that are providing services and/or goods to the company or could do so in the future.

The Company must process personal data so that services can be provided – in doing so, the company acts as a data controller.

We will only use your personal data in accordance with the terms outlined in our contracts and our privacy notice.

What information does the organisation collect?

  • You may give your personal details to the company directly, such as by seeking to provide services to us; or,
  • In some circumstances, your personal details may have been provided to us by another person in your company to offer and/or perform a contractual service.
  • Your details may have been identified via publicly available sources in relation to services you provide (e.g. LinkedIn or your company website).

In any case the Company must have a legal basis for processing your personal data. We will only use your personal data in accordance with the terms of a contract and our privacy notice.

Why does the organisation process personal data?

The Company will only collect and process your personal data for the purposes of fulfilling contracts, or including you in our supply chain.

The legal bases we rely upon when providing and/or offering to provide these services to you are:

Legal Obligation                 
To comply with law, e.g. HMRC and Tax legislation

Contractual Obligation
To perform a contract between us/you/your company
To assist us/you/your company to establish / exercise or defend legal claims

Legitimate Interest           
For marketing and public relations in relation to our services;

Consent                                   
Where we have explicitly obtained your consent to share your data with other potential suppliers e.g. to provide a testimonial and/or reference about our service provision

Who has access to data?

Where we need to share your personal data, we have contracts and data sharing agreements in place with the recipients that require them to treat your information as confidential and ensure the continued protection of your data whilst in their possession. The Company will process your personal data with the following recipients:

  • Governing bodies and authorities as required by law;
  • Our software providers;
  • Third party suppliers, e.g. business associates and professional advisers;
  • Marketing technology platforms and suppliers;
  • We may transfer your personal information to a third party as part of a sale of some or all our business and assets to any third party or a part of any business restructuring or reorganisation. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

How does the organisation protect data?

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures, e.g.:

  • encryption of our personal data;
  • review our information collection, storage and processing practices, including physical security measures;
  • restrict access to personal access to personal information;
  • internal policies setting out our data security approach and measures to deal with any suspected data breach.

For how long does the organisation keep data?

The Company will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.

Where services have not been provided

If you have not provided us with your services, or we have not had valuable contact with you (or, where appropriate, the company you are working for or with) for two consecutive years, your personal data will be deleted from our systems unless where we believe in good faith that the law or other regulation requires us to preserve it.

Where services have been provided

Your personal details may be included in a number of documents created during our contract with you/your company. To comply with legal requirements e.g. VAT and tax legislation, your data will be kept for 7 tax years directly prior to the last date on which services were provided to us by you/your company.  In the case of Construction projects, this could be longer, up to 15 years, where we believe in good faith that the law or other regulation requires us to preserve it.

Where the Company has obtained your consent to process your personal data we will do so in line with the relevant schedule detailed above.

After expiry of that period your data will no longer be kept.

Your rights

As a data subject, you have a number of rights. You can:

  • access and obtain a copy of your data on request;
  • require the organisation to change incorrect or incomplete data;
  • require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
  • object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing; and
  • ask the organisation to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation's legitimate grounds for processing data.

If you would like to exercise any of these rights, please contact data.protection@clugston.co.uk.
If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner.

Automated decision-making

The company does not use automated decision- making, including profiling. Should the company intend to change this process you will be notified in advance.