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.
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.
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:
To comply with law, e.g. HMRC and Tax legislation
To perform a contract between us/you/your company
To assist us/you/your company to establish / exercise or defend legal claims
For marketing and public relations in relation to our services;
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
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:
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.:
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.
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.
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.
As a data subject, you have a number of rights. You can:
If you would like to exercise any of these rights, please contact firstname.lastname@example.org.
If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner.
The company does not use automated decision- making, including profiling. Should the company intend to change this process you will be notified in advance.