Protecting your private information is our priority. This Privacy Notice applies to the basicdisclosure.com website a trading style of Clear Check Ltd and governs data collection and usage. For the purposes of this Privacy Notice, unless otherwise noted, all references to Clear Check Ltd include basicdisclosure.com. The basicdisclosure.com website (the “Site”) is a website through which Clear Check Ltd provides an application review and submission service. Clear Check Ltd is the data controller for the purposes of The United Kingdom General Data Protection Regulation (UK-GDPR) & The Data Protection Act 2018.
COLLECTION OF YOUR PERSONAL INFORMATION
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Clear Check Ltd may collect, use, store and transfer different kinds of personal data about you. These have been detailed as follows:
- Identity Data includes, first name, maiden name, last name, marital status, title, date of birth, gender, national insurance number, driving licence details, national entitlement card number, passport number.
- Contact Data includes, current and previous addresses, email address and telephone numbers.
- Financial Data includes, bank statements (credit card, mortgage), government tax statement.
- Transaction Data includes, details of products and services you have engaged us for.
- Technical Data includes, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes, information about how you use our website, products and services.
- Marketing and Communications Data includes, your preferences in receiving marketing from us and our third parties and your communication preferences.
Clear Check Ltd also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Clear Check Ltd do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Clear Check Ltd may on occasion, collect but not store information about criminal convictions and offences in the context of The Check People certificate to be provided.
USE OF YOUR PERSONAL INFORMATION
Clear Check Ltd rely upon your consent given by way of our Terms and Conditions in order to provide you with our service (i.e. application for The Check People check).
Clear Check Ltd will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract, we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where Clear Check Ltd need to comply with a legal or regulatory obligation.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you |
| To process and deliver your service to you including: (a) verification checks on documents provided | (a) Identity (b) Contact (c) Financial (d) Transactional (e) Special Category (f) Criminal | Performance of a contract with you |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | Necessary for our legitimate interests (to develop our products/services and grow our business) |
SHARING YOUR PERSONAL DATA
Clear Check Ltd may have to share your personal data with the parties set out below for the purposes set out in the table and paragraph below. These companies will not use your information to contact you. Selected third parties will be subject to obligations to process your personal information in compliance with the same safeguards that we deploy.
Clear Check Ltd work carefully with selected data processing companies such as:
| Company Name | Company Details | Processing Activity |
|---|---|---|
| Clear Check Ltd. | Processor | Processing application details to provide you with the service |
| Elucidate Contractor Services (ECS) Ltd. | Processor | Processing application details to provide you with the service |
| BuzzPoint Limited | Software Provider | Provision of software for our Customer Relationship Management (CRM) |
Clear Check Ltd may also disclosure your information with:
- The Disclosure and Barring Service, Regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Accountants, Solicitors, Compliance Consultants and other like services acting as processors, based in the United Kingdom who require reporting of processing activities in certain legal and compliance circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
Clear Check Ltd require all third parties to respect the security of your personal data and to treat it in accordance with the law. Clear Check Ltd do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
TRANSFERS OUTSIDE THE UK
Clear Check Ltd may transfer your data outside of the UK. Clear Check Ltd rely upon the basis of the transfer of data which is necessary for the performance of a contract between you and us and/or for pre-contractual steps taken at your request.
Clear Check Ltd have implemented contractual relationships with our third-party processors which stipulate the safeguards they must put in place regarding the security of your data.
Clear Check Ltd require all third parties to respect the security of your personal data and to treat it in accordance with the law. Clear Check Ltd do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
YOUR DATA RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
REQUESTING A COPY OF YOUR PERSONAL DATA
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may also charge a further administrative fee when you request for us to provide further copies of the information already provided to you.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. We will respond to your request within one month of receiving your request. We will inform you of the third parties to whom your data has been disclosed.
If you wish to exercise any of the rights set out above, please see the contact details below.
USE OF COOKIES
The site may use “cookies” to help you personalise your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Text-based Cookies (I.e. non-executable text files) cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. We may in some cases also use web beacons in order to track the opening web pages or emails specific to individual customers and/or visitors.
Please see our COOKIES POLICY for more information.
SECURITY OF YOUR PERSONAL INFORMATION
Clear Check Ltd secures your personal information from unauthorised access, use or disclosure. When personal information (such as a credit card or debit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol. Clear Check Ltd does not collect payment information and at no point receive and therefore store the credit/debit card information. Customers of the Site are redirected to a third-party payment gateway to submit a payment. While we use industry standard procedures to safeguard your PII once we receive it, no transmission of data over the internet or any other public network can be guaranteed to be 100% secure.
STORAGE OF YOUR PERSONAL INFORMATION
Clear Check Ltd will only retain your personal data for as long as necessary to fulfil the purposes Clear Check Ltd collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, Clear Check Ltd consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether Clear Check Ltd can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available and you can request from Clear Check Ltd by using the contact details below. By law Clear Check Ltd have to keep certain information about our customers and this data will be held solely and securely for those legal purposes.
CHILDREN UNDER SIXTEEN
The site is not directed to children under the age of 16 however, and Clear Check Ltd does not knowingly collect PII from children under the age of 16. If you are under the age of 16, it must be stressed and made clear that you are not permitted to use the site
OPT-OUT & UNSUBSCRIBE
We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from Clear Check Ltd by contacting us:
– Web page: www.basicdisclosure.com
– Email: [email protected]
CHANGES TO THIS PRIVACY NOTICE
This version was last updated on the date indicated at the top of this page. Historic versions can be obtained by contacting us by the details above.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance on the details below.
If you have any concerns about our processing of your personal information, please contact our Data Protection Officer;
The DPO Office [email protected]
Post:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113
CONTACT INFORMATION
Clear Check Ltd welcomes your questions or comments regarding this Privacy Notice. If you believe that Clear Check Ltd has not adhered to this Statement, please contact Clear Check Ltd:
CONTACT INFORMATION
basicdisclosure.com – 27 Old Gloucester Street, London, WC1N 3AX. Please do not send any correspondence to this address as it will not be read.
Should you wish to contact us by mail for any reason, you can get in touch at:
The Check People, PO Box 2965, Romford, RM7 1RG
basicdisclosure.com is a trading name of Clear Check Ltd. Registered in England & Wales: Company No.: 05853202
Email Address: [email protected]
Telephone number: 0333 030 0446.
