The aim of this data protection notice (Privacy Notice) is to inform the website visitors of www.clearway.co.uk, customers/suppliers to Clearway, job applicants and physical visitors to any of our premises, on the collection, use, disclosure, transfer, and other processing of their individually identifiable information (Personal Data). Please read this Privacy Notice carefully as it explains how we use any personal data that you provide to us. We may change this Privacy Notice and, when we do, we will post any changes on this page, so please check back frequently.
1) Who we are
The Clearway Group Limited is the ultimate data controller for Personal Data processed on this website. Otherwise, the data controller will be the group member of Clearway that you have an engagement with (e.g. terms of business) (together, Clearway, we, us or our). You can find out more about our group here.
You can contact us:
By post: Pennine Place, 2a Charing Cross Road, London, England, WC2H 0HF
By phone: +44 (0)20 3325 0250
By email: contact our data protection officer at email@example.com.
2) Personal Data: collection, purposes and lawful basis
This Privacy Notice applies to the collection of and processing of your Personal Data by Clearway. We collect Personal Data from you directly through your use of our website via one of our contact forms; through a mobile app registration/login process; through a newsletter sign-up form or via a LiveChat window. We also have CCTV cameras at some of our properties, or properties we manage, which directly capture video and audio footage. We also receive Personal Data indirectly from landlords and credit agencies. Where you apply for a position via our website, we may also receive information indirectly from recruitment agencies and your references (including previous employers).
The type of Personal Data we process differs depending on how you engage with us. The table below provides this information including how we will use the Personal Data and the context for which we use your Personal Data:
|Types of Personal Data||Purposes||Legal Basis|
|Your first name, surname, email address, residential address, business address, date of birth, gender, payment information (including bank account information and transaction data) and communications/complaints.||To process and administer accounts and payments in relation to the services and products you request/use and resolve any complaints you may have. This includes processing to administer our relationship with you, process any orders that you have submitted and send statements, invoices and payment reminders to you, and collect payments from you. Also, to make payments to our sub-contractors and/or consultants in relation to the services and products you request/use.||(a) the processing is necessary to our performance of a contract with you; and|
(b) it is our legitimate interest to review and respond to any correspondence or queries you send to us, and to send service information regarding our products and/or services that you have bought or requested.
|Credit rating details for corporate tenants, insolvency/ administration information and credit history.||This includes processing to administer our relationship with you and ensure that tenants will be able to pay invoices due; also to verify against fraudulent activity.||(a) the processing is necessary to our performance of a contract with you;|
(b) where necessary to comply with applicable legal obligation; and
(c) necessary for our legitimate interests to monitor, investigate, detect and protect against fraud, including but not limited to violation of our contract terms or laws or regulations.
|Identification information and details of your qualifications and education history, CV, application letters, references, candidate assessment (including interview notes and interview video); information relating to right to work and information about your skills, experience and education.||To respond to request for vacancies and for recruiting and hiring purposes and to improve our recruitment process and activities.||(a) the processing is necessary for us to administer our contract with you- or take steps to consider entering into an employment contract with you;|
(b) necessary for our legitimate interests to maintain a world class reputation as a leading employer; and
(c) necessary to comply with employment and social security law obligations (for example, carrying out right to work checks).
|Your first name, surname, email address, residential address, business address.||To send you marketing material, newsletters and other related information, including, surveys, and promotions and to send solicited information (e.g. quotes in response to an enquiry).||(a) our legitimate interest to send you communications related to similar products or services to which you have previously purchased or entered into negotiations to purchase, where permitted by privacy laws; or|
(b) your consent or where information is solicited.
Please see section 6 of this Privacy Notice for more information.
|CCTV images and audio.||To capture footage to help prevent and detect crime and for security purposes.||Our legitimate interest to ensure the security of our customers’ premises and for purposes of detecting and preventing crime.|
We have a separate CCTV policy which you can request/is available on site.
|Names, email addresses, residential addresses, business addresses.||To conduct data analytics and market research for statistical and survey purposes and for internal business administration.||(a) our legitimate interest to measure the use of our products and/or services and interaction to inform and improve service/product direction and development and to enable provision of accurate and reliable reporting; and/or|
(b) the processing is necessary to our performance of a contract with you.
|Information about your visits to our website, your geo-location and IP address, the browser software you use, the top-level domain-name used (for example .ie, .com, .org, .net), the pages visited on the website, i.e., URL’s visited, the previous website address from which the visitor reached us, including any search terms used, clickstream data which shows the traffic of visitors around the website (for example, pages accessed), and the date and time you access the website.||To help us to keep the website available and improve your experience when you visit it. This includes: (a) for verification and administration, and for statistical analysis to improve, test and monitor the effectiveness of the website; (b) to monitor metrics such as total number of visitors and traffic data (including demographic patterns); and (c) to ensure content on the website is presented in the most effective manner for you and to enhance your use of the website.||(a) our legitimate interest to provide and maintain our website through utilising cookies that are strictly necessary;|
(b) your consent for cookies that are not strictly necessary, such as cookies relating to performance, functionality and target/advertising.
Important: Website users should also read our Cookie Notice which is also available on our website.
|All Personal Data set out above.||In connection with any merger, sale, transfer of our assets, investment, acquisition, bankruptcy, or similar event or corporate transaction.||Necessary for our legitimate interests to ensure we can protect and grow our business.|
|All Personal Data set out above.||To perform financial accounting functions including tax reporting to comply with applicable laws and accounting standards that Clearway adheres to.||Necessary to comply with relevant legal obligations (for example, relating to tax reporting).|
|All Personal Data set out above.||To help us improve and optimise our products and services.||Necessary for our legitimate interests to maintain our reputation as a leading provider of property and site security, highways CCTV installations, mobile security devices and monitoring services.|
|All Personal Data set out above.||To protect the rights of Clearway and Data Subjects||(a) necessary to comply with relevant legal obligations (for example, applicable data protection/privacy laws).|
(b) necessary for our legitimate interests to act in, and protect, the interests of our business.
In limited circumstances we may process any of the Personal Data we hold to the extent necessary to defend, establish and exercise legal claims or to comply with legal or regulatory obligations.
Where we need to collect personal data due to a legal or regulatory obligation, or for performance of a contract, and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products/services). We will notify you of this at the time.
3) Disclosure of your Personal Data
Depending on your dealings with us, we may disclose some or all of the Personal Data we collect from and obtain about you to the following:
Other entities within our group. We will share your Personal Data internally between the Clearway group described in section 1 and our investors to the extent required for internal administrative purposes, management purposes or other business-related purposes as described in this Privacy Notice.
Service Providers and Processors. We engage third party vendors, from time to time, including:
Third parties in case of a legal requirement. We also disclose your Personal Data if disclosure is required by law or in the context of an investigation, regulatory requirement, judicial proceeding, court order or legal process (including to law enforcement or competent authorities like the police/tax authorities, such as HMRC in the UK).
Third parties in case of a corporate transaction. In addition, information about our customers, including Personal Data, may be disclosed as part of any merger, sale, transfer of our assets, investment, acquisition, bankruptcy, or similar event, including while engaging with our actual or potential investors.
We may provide anonymous information to analytics and search engine providers to help us improve and optimise our services. We will only share this information in a form that does not directly identify you.
Some of those recipients may be based outside the European Economic Area and/or the United Kingdom. Whenever we make transfers of your Personal Data, we implement appropriate safeguards in accordance with applicable data protection laws, e.g., the Standard Contractual Clauses, the UK Addendum, transfer impact assessments and/or make transfers to countries that have an adequacy decision by the European Commission and/or the UK Information Commissioner’s Office. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries and International transfers | ICO. If you would like to find out more about any such transfers or obtain a copy of safeguards, please contact us using the details set out in section 1.
4) Retention of your Personal Data
We will not retain your Personal Data longer than it is necessary to carry out the purposes listed in this Privacy Notice or than is required by law. We will generally store Personal Data for up to seven years (e.g. generally invoices for 6 years plus the relevant financial year in which the invoice was issued) from the end of the calendar year in which the engagement between the data subject and Clearway has ended; except that we only retain recruitment related information for up to 6 months and CCTV footage for 1 month and our Cookie Notice has more information about retention of technical device information. In some circumstances, these storage periods may however be exceeded where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or to establish, exercise, or defend legal claims. In specific circumstances we may also retain your Personal Data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.
5) Your rights and how to exercise them
You have several rights in relation to your Personal Data set out in this section. In certain circumstances these rights might not be absolute, as they depend on our reason for processing your personal data. You are not required to pay any charge for exercising your rights, although we may charge a reasonable fee if your request is unfounded, repetitive or excessive. We have one month to respond to you (unless you have made a number of requests or your request is complex, in which case we may take up to an extra two months to respond).
Please note that, where we ask you for proof of identification, the one-month time limit does not begin until we have received this. If we require any clarification and/or further information on the scope of the request, the one-month deadline is paused until we receive that information.
Right to information
You have the right to request confirmation if your Personal Data is processed. When we process your Personal Data, you have a right to information about this Personal Data and for a copy of this information. For more information on your right to information, see Art. 15 of the GDPR.
Right to rectification
You have the right to request the rectification of incorrect Personal Data concerning you without delay. Taking into account the purposes of processing, you have the right to request the completion of incomplete Personal Data. For more information on your right to rectification, see Art. 16 of the GDPR.
We strive to ensure the accuracy of your Personal Data. We therefore ask you to notify us immediately of any changes to your data (such as changes in address), so that we can ensure that your Personal Data is up-to-date.
Right to erasure
If the legal requirements are met, you may request us to erase your Personal Data immediately. This shall be the case, in particular, where:
We would like to point out that your right to erasure is subject to restrictions. For example, we may not erase any Personal Data that we have to keep further due to legal requirements. Data that we need in order to assert, exercise or defend legal claims are also excluded from your right to erasure. For more information on your right to erasure, see Art. 17 of the GDPR.
Right to restriction
If the legal requirements are met, you may request a restriction on the processing of your Personal Data. This is particularly the case where:
For more information on your right to restriction of processing, see Art. 18 of the GDPR.
Right to data portability
You have the right to receive the Personal Data you have provided us and which we process for the fulfilment of the contract, on the basis of your consent or by automated procedures, in a structured, customary and machine-readable format. You also have the right to ask us to transmit this data directly to a third party, if this is technically feasible. For more information on your right to data portability, see Art. 20 of the GDPR.
Right to complain
If you consider that the processing of your Personal Data violates applicable data protection laws, you may lodge a complaint with your local supervisory authority for data protection issues, which for example in the UK is the Information Commissioner’s Office (ICO) at: https://ico.org.uk, and in France is Commission Nationale de l’Informatique et des Libertés (CNIL) at www.cnil.fr. We would, however, appreciate the chance to deal with your concerns before you approach your local supervisory authority, so please contact us in the first instance using the contact details at the start of this Privacy Notice.
Withdrawal of consent
If you have given your consent to the processing of your Personal Data, you can revoke it at any time with effect for the future. The lawfulness of the processing of your data before this remains unaffected.
Right to object
|Right to object to the processing of your Personal Data during processing based on our legitimate interests.|
If we process data on the basis of a legitimate interest, you can object to the processing at any time for reasons that arise from your particular situation. We will no longer process your Personal Data unless we can demonstrate compelling legitimate grounds for processing that override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
For more information on your right of objection, see Art. 21 of the GDPR.
Right to determine the faith of your personal data (applicable in France)
You have the right to set out instructions (general or specific) about what happens to your Personal Data after your death.
We take steps to limit direct marketing to a reasonable and proportionate level and to send you communications which we believe may be of interest or relevance to you, based on the information we have about you. You may change your marketing preferences at any time by contacting us. In particular, for email marketing communications, you can always opt-out by clicking the “unsubscribe” link at the bottom of marketing emails, or by contacting the contact details provided in section 1. With postal and telephone marketing communications, you may opt-out by contacting the contact details in section 1.
When you choose to unsubscribe, your data is automatically moved to a suppression list to prevent your email address being accidentally added to our database again. If you wish your data to be fully deleted from our systems we will do so at your request but, if your email address is at any point added back in to our newsletter database, by you or on your behalf, there will be no automated process in place to prevent a newsletter being emailed to you again. Please note that where we have another lawful basis for processing, we will continue to process personal data for other purposes – for example, we may process information based on contract necessity. You may also receive indirect marketing from us by way of online advertisements or general marketing communications.
7) Any questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your Personal Data and your rights to control it. If you have any questions that have not been covered, please contact our Data Protection Officer who will be pleased to help you via email firstname.lastname@example.org.
This Privacy Notice was last updated on 25 April 2023.