Tietosuojaseloste
Policy version: [21/12/2022]
This privacy policy tells you what to expect us to do with your personal information when you make contact with us or use our services.
Who are we?
Clevry (our website) is operated by CLEVRY UK LTD trading as “Clevry” (‘we’, ‘our’ or ‘us’).
The roles of data controller and data processor depends on whose process you take part in:
- When you take part in Clevry’s process, we are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
- When you take part in our Customer’s process (who are using our assessment platform in their process), our Customer is the controller of personal data obtained via our website, meaning our Customer is the organisation legally responsible for deciding how and for what purposes it is used. Clevry is the processor of personal data.
Clevry is a company incorporated and based in England with company registration number 3443538. Our registered office address is Floor 1 Century House, 15-19 Dyke Road, Brighton, BN1 3FE, UK.
Clevry has offices in Sweden and Finland, and their details are shown here. They form part of our group offices (“our Group”).
We are a leading provider of business psychology products, technologies, and talent advisory and acquisition services for more than 30 years. We specialise in delivering flexible psychometric technologies, versatile 360 feedback services and innovative assessment activities.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA).
18 or under
This version of our privacy policy is primarily written for adults (in the UK, an adult is 18 years old or over 18 years old), including parents and guardians of child users. If you are a child (under 18 years old) you are welcome to read this policy if you find it useful, but please obtain your parent or guardian’s permission before you provide us with your information and/or to register with us.
We do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our website, please let us know so that we can delete that data.
Contents of this page
This privacy policy is divided into the following sections:
- What this Policy applies to
- Personal data we collect about you
- How your personal data is collected
- How and why we use your personal data
- Marketing
- Who we share your personal data with
- How long your personal data will be kept
- Transferring your personal data out of the UK and EEA
- Cookies and other tracking technologies
- Your rights
- Keeping your personal data secure
- How to complain
- Changes to this privacy policy
- How to contact us
What this Policy applies to
This privacy policy relates to your use of our website (including but not limited to our online application and platforms) only.
Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you. Those third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third-party websites, please consult their privacy policies as appropriate.
Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:
Contact data & your profile
- your name, address and contact information, including email address and telephone number and company details;
- your account details, such as username and login details;
- information to check and verify your identity;
- your gender, if you choose to give this to us;
- location data, if you choose to give this to us;
- your ethnicity and/or cultural background, if you choose to give this to us;
- your career profile, e.g. work history and qualifications;
- your professional online presence, e.g. LinkedIn profile;
- details of any information, feedback or other matters you give to us by phone, email, post or via social media;
- your billing information (if applicable); and
- bank account and payment details (if applicable).
In addition to above personal data, we also collect and process the following personal data we may have on you.
Soft skills data
- your aptitudes;
- your personal traits;
- your motivations;
- your working style ;
- your behavioural approaches;
- your thinking styles;
- your personal and/or career interests;
- your virtual assessment scores;
- your responses to our online psychometric exercises and survey you complete;
Website usage data
- your activities on, and use of, our website;
- your contact history, purchase history and saved items;
- information about the services we provide to you; and
- information about how you use our website and technology systems.
If you do not provide personal data we ask for where it is indicated to be ‘required’ at the point of collection, it will delay or prevent us from providing services to you as explained in the relevant forms or our platform on which such data is collected.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
How your personal data is collected
We collect personal data from you:
- directly, when you enter or send us information, such as when you register with us, participate in an assessment via our platform and/or mobile application, contact us (including via email), send us feedback, use our services via our website, post material to our website and complete surveys or participate in competitions via our website, and
- indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explain in the section on ‘Cookies and other tracking technologies’ below
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, for example:
- where you have given consent
- to comply with our legal and regulatory obligations
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
WHAT WE USE YOUR PERSONAL DATA FOR | OUR REASONS |
Create and manage your account with us | For our legitimate interests, that is to be as efficient as we can so we can deliver the best service to you at the best price |
Providing our services to you – for example, to let you take a range of assessments/tests/ questionnaires, to provide a personalised report for you, and to enable you to find matching jobs | To perform what we agree to provide our services (a contract with you) or to take steps at your request before entering into a contract |
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us | To comply with our legal and regulatory obligations AND to minimise fraud that could be damaging for you and/or us |
To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances:
|
Customise our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website | Depending on the circumstances:
If you have provided such a consent you may withdraw it at any time by changing the setting on the cookies tool (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn) |
Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended | Depending on the circumstances:
If you have provided such a consent you may withdraw it at any time by dropping a line to [email protected] (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn) |
Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices | Depending on the circumstances:
|
Protecting the security of systems and data used to provide the services | To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
Statistical analysis to help us understand our customer/client base | For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
Updating and enhancing candidate/ customer/ client records | Depending on the circumstances:
|
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, for example, to record and demonstrate evidence of your consents where relevant | To comply with our legal and regulatory obligations |
Marketing our services to existing and former customers, candidates and/or clients | For our legitimate interests, i.e. to promote our business to existing and former customers See ‘Marketing’ below for further information |
The audit and our own qualify checks | For our legitimate interests, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards |
To share your personal data with members of our Group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary | Depending on the circumstances:
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How and why we use your personal data – in more detail
More details about how we use your personal data and why are set out in the table below.
PURPOSE | PROCESSING OPERATION | LAWFUL BASIS RELIED ON UNDER THE UK GDPR | RELEVANT CATEGORIES OF PERSONAL DATA |
Communications with you not related to marketing, including about changes to our terms or policies or changes to our services or other important notices | Addressing and sending communications to you as required by the UK GDPR or Data Protection Act 2018
| Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) |
|
Addressing and sending communications to you to perform a contract with you or to take steps at your request before entering a contract | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) |
| |
Addressing and sending communications to you about changes to our terms or policies or changes to the services or other important notices (other than those addressed above) | Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you |
| |
Communications with you to inform certain career development and/or job opportunities that match your aspirations and your strength | Addressing and sending communications to you to perform a contract with you | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) |
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How and why we use your personal data – Special category personal data
Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:–
- include as relevant to the data collected: personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
- include as relevant to the data collected: genetic data
- include as relevant to the data collected: biometric data (when used to uniquely identify an individual)
Where we process such special category personal data, we will also ensure we are permitted to do so under data protection laws.
How and why we use your personal data – sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by either:
- contacting us via email to: [email protected]
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts, or
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never share it to other organisations other than our Partnership companies for marketing purposes. To see the details of our Partnership Companies, please click here.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
Who we share your personal data with
We routinely share personal data with:
- any of our Group (please see: here for our offices);
- our Partnership Companies (please see here for details);
- third parties we use to help deliver our services to you, for example, payment service providers;
- other third parties we use to help us run our business, for example, our website hosts and website analytics providers;
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above occasionally also share personal data with:
- our and their external auditors, in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency – usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations
We will not share your personal data with any other third party.
Who we share your personal data with – further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used. Different retention periods apply for different types of personal data.
Details as to how long we retain what data are set out in the table below:
RECORD | RETENTION PERIOD | STORAGE FORMAT | REFERENCE |
If you are only taking our assessments and/or tests on our platform:- Contact details Assessment and psychometric test results | 12 months after the last contact was made between you and Clevry | Electric | ICO Employment Practices Code para 1.7
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As a candidate and your job application being unsuccessful:- Contact details Application letters or forms CVs References Interview notes Assessment and psychometric test results | 12 months Application forms should give applicants the opportunity to object to their details being retained | Paper or electronic | ICO Employment Practices Code para 1.7 Equality Act 2010, s 123 |
Application records of successful candidates, including:- Application letters or forms Copies of academic and other training received References Correspondence concerning employment CVs Interview notes and evaluation forms Assessment and psychometric test papers and results | 12 months after when we have last provided our services for you | Paper or electronic | ICO Employment Practices Code para 1.7
|
Criminal records information (if any):- Criminal records requirement assessments for a particular post Criminal records information forms the Disclosure and Barring Service (DBS) check forms DBS certificates | Criminal records requirement assessments for a particular post – 12 months after the assessment was last used All other information in this category – as soon as practicable after the check has been completed and the outcome recorded (ie whether satisfactory or not) | Paper or electronic | DBS guidance for employers: Duration of criminal record check validity ICO Employment Practices Code Nov 2011, part 1.7.4 |
Employment contracts (if we receive them), including: Personnel and training records Written particulars of employment Changes to terms and conditions | Seven years after employment ceases, unless document executed as a deed, in which case 13 years after employment ceases | Paper or electronic | LA 1980, ss 5, 8 |
Directors’ service contracts and any variations (if we receive them) | Seven years from termination or expiry of the contract, unless executed as a deed, in which case 13 years from termination or expiry | Paper or electronic | LA 1980, ss 5, 8 Companies Act 2006, ss 227, 228 |
Copies of identification documents (eg passports) | Not less than two years from date of termination of employment | Paper or electronic | Immigration (Restrictions on Employment) Order, SI 2007/3290, Art 6(1)(b) |
Identification documents of foreign nationals (including right to work) | Two years and six months from date of termination of employment | Paper or electronic | Immigration (Restrictions on Employment) Order, SI 2007/3290, art 6(1)(b) |
Records concerning a temporary worker | Seven years after employment ceases | Paper or electronic | LA 1980, s 5 |
If you stop using your account we will delete or anonymise your account data after 12 months.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
Transferring your personal data out of the UK and EEA
Other countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
The UK data protection law is known as the UK GDPR, derives from the EU GDPR. But the EU GDPR no longer applies to the UK.
We are based in the UK and have customers in the UK, the EEA and also outside these areas. It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
We may transfer your personal data to:
- our Group offices located in Sweden and Finland,
- our Partnership Companies located in the EEA countries.
As we are based in the UK, we may also need to transfer your personal data from the EEA to the UK.
If you or our Customer is located outside the UK or the EEA countries, we may transfer your personal data to our local Customer or Partnership Company handling the process.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
- in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. We rely on adequacy regulations for transfers to the following countries: countries in the EEA
- in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. Details of the European Commission’s adequacy decisions are available here. We rely on adequacy decisions for transfers to the countries outside the EEA.
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
- a specific exception applies under relevant data protection law
Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
Cookies and other tracking technologies
A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website.
For further information on cookies and other tracking technologies we use, please see our Cookies Policy.
Your rights
You generally have the following rights, which you can usually exercise free of charge:-
Access to a copy of your personal data | The right to be provided with a copy of your personal data |
Correction (also known as rectification) | The right to require us to correct any mistakes in your personal data |
Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, for example, if you contest the accuracy of the data |
Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party (in certain situations) |
To object to use | The right to object:-
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Not to be subject to decisions without human involvement | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by our website |
The right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by contacting us to [email protected] or on (+44)1273734000 Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email, call or write to us. Please see below: ‘How to contact us’. When contacting us please:
- provide enough information to identify yourself, for example, your full name, email address, user/account number and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
- the Information Commissioner in the UK; and
- a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA
The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
For a list of EEA data protection supervisory authorities and their contact details see here.
Changes to this privacy policy
We may change this privacy policy from time to time – when we make significant changes we will take steps to inform you, via email and on our website.
How to contact us
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Our contact details | |
Postal Address: Email: Telephone: | Clevry UK Ltd, Century House, 15-19 Dyke Road, Brighton BN1 3FE, UK (44) 1273 734 000 |
Policy version: [15/12/2021]
This privacy policy tells you what to expect us to do with your personal information when you make contact with us or use our services.
Who are we?
Clevry (our website) is operated by CLEVRY UK LTD trading as “Clevry” (‘we’, ‘our’ or ‘us’).
We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
Clevry is a company incorporated and based in England with company registration number 3443538. Our registered office address is Floor 1 Century House, 15-19 Dyke Road, Brighton, BN1 3FE, UK.
Clevry has offices in Sweden and Finland, and their details are shown here. They form part of our group offices (“our Group”).
We are a leading provider of business psychology products, technologies, and talent advisory and acquisition services for more than 30 years. We specialise in delivering flexible psychometric technologies, versatile 360 feedback services and innovative assessment activities.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA).
18 or under
This version of our privacy policy is primarily written for adults (in the UK, an adult is 18 years old or over 18 years old), including parents and guardians of child users. If you are a child (under 18 years old) you are welcome to read this policy if you find it useful, but please obtain your parent or guardian’s permission before you provide us with your information and/or to register with us.
We do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our website, please let us know so that we can delete that data.
Contents of this page
This privacy policy is divided into the following sections:
- What this Policy applies to
- Personal data we collect about you
- How your personal data is collected
- How and why we use your personal data
- Marketing
- Who we share your personal data with
- How long your personal data will be kept
- Transferring your personal data out of the UK and EEA
- Cookies and other tracking technologies
- Your rights
- Keeping your personal data secure
- How to complain
- Changes to this privacy policy
- How to contact us
What this Policy applies to
This privacy policy relates to your use of our website (including but not limited to our online application and platforms) only.
Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you. Those third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third-party websites, please consult their privacy policies as appropriate.
Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:
Contact data & your profile
- your name, address and contact information, including email address and telephone number and company details;
- your account details, such as username and login details;
- information to check and verify your identity;
- your gender, if you choose to give this to us;
- location data, if you choose to give this to us;
- your ethnicity and/or cultural background, if you choose to give this to us;
- your career profile, e.g. work history and qualifications;
- your professional online presence, e.g. LinkedIn profile;
- details of any information, feedback or other matters you give to us by phone, email, post or via social media;
- your billing information (if applicable); and
- bank account and payment details (if applicable).
In addition to above personal data, we also collect and process the following personal data we may have on you.
Soft skills data
- your aptitudes;
- your personal traits;
- your motivations;
- your working style ;
- your behavioural approaches;
- your thinking styles;
- your personal and/or career interests;
- your virtual assessment scores;
- your responses to our online psychometric exercises and survey you complete;
Website usage data
- your activities on, and use of, our website;
- your contact history, purchase history and saved items;
- information about the services we provide to you; and
- information about how you use our website and technology systems.
If you do not provide personal data we ask for where it is indicated to be ‘required’ at the point of collection, it will delay or prevent us from providing services to you as explained in the relevant forms or our platform on which such data is collected.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
How your personal data is collected
We collect personal data from you:
- directly, when you enter or send us information, such as when you register with us, participate in an assessment via our platform and/or mobile application, contact us (including via email), send us feedback, use our services via our website, post material to our website and complete surveys or participate in competitions via our website, and
- indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explain in the section on ‘Cookies and other tracking technologies’ below
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, for example:
- where you have given consent
- to comply with our legal and regulatory obligations
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
WHAT WE USE YOUR PERSONAL DATA FOR | OUR REASONS |
Create and manage your account with us | For our legitimate interests, that is to be as efficient as we can so we can deliver the best service to you at the best price |
Providing our services to you – for example, to let you take a range of assessments/tests/ questionnaires, to provide a personalised report for you, and to enable you to find matching jobs | To perform what we agree to provide our services (a contract with you) or to take steps at your request before entering into a contract |
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us | To comply with our legal and regulatory obligations AND to minimise fraud that could be damaging for you and/or us |
To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances:
|
Customise our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website | Depending on the circumstances:
If you have provided such a consent you may withdraw it at any time by changing the setting on the cookies tool (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn) |
Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended | Depending on the circumstances:
If you have provided such a consent you may withdraw it at any time by dropping a line to [email protected] (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn) |
Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices | Depending on the circumstances:
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Protecting the security of systems and data used to provide the services | To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
Statistical analysis to help us understand our customer/client base | For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
Updating and enhancing candidate/ customer/ client records | Depending on the circumstances:
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Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, for example, to record and demonstrate evidence of your consents where relevant | To comply with our legal and regulatory obligations |
Marketing our services to existing and former customers, candidates and/or clients | For our legitimate interests, i.e. to promote our business to existing and former customers See ‘Marketing’ below for further information |
The audit and our own qualify checks | For our legitimate interests, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards |
To share your personal data with members of our Group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary | Depending on the circumstances:
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How and why we use your personal data – in more detail
More details about how we use your personal data and why are set out in the table below.
PURPOSE | PROCESSING OPERATION | LAWFUL BASIS RELIED ON UNDER THE UK GDPR | RELEVANT CATEGORIES OF PERSONAL DATA |
Communications with you not related to marketing, including about changes to our terms or policies or changes to our services or other important notices | Addressing and sending communications to you as required by the UK GDPR or Data Protection Act 2018
| Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) |
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Addressing and sending communications to you to perform a contract with you or to take steps at your request before entering a contract | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) |
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Addressing and sending communications to you about changes to our terms or policies or changes to the services or other important notices (other than those addressed above) | Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you |
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Communications with you to inform certain career development and/or job opportunities that match your aspirations and your strength | Addressing and sending communications to you to perform a contract with you | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) |
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How and why we use your personal data – Special category personal data
Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:–
- include as relevant to the data collected: personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
- include as relevant to the data collected: genetic data
- include as relevant to the data collected: biometric data (when used to uniquely identify an individual)
Where we process such special category personal data, we will also ensure we are permitted to do so under data protection laws.
How and why we use your personal data – sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by either:
- contacting us via email to: [email protected]
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts, or
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell it to other organisations other than our Partnership companies for marketing purposes. To see the details of our Partnership Companies, please click here.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
Who we share your personal data with
We routinely share personal data with:
- any of our Group (please see: here for our offices);
- our Partnership Companies (please see here for details);
- third parties we use to help deliver our services to you, for example, payment service providers;
- other third parties we use to help us run our business, for example, our website hosts and website analytics providers;
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above occasionally also share personal data with:
- our and their external auditors, in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency – usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations
We will not share your personal data with any other third party.
Who we share your personal data with – further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used. Different retention periods apply for different types of personal data.
Details as to how long we retain what data are set out in the table below:
RECORD | RETENTION PERIOD | STORAGE FORMAT | REFERENCE |
If you are only taking our assessments and/or tests on our platform:- Contact details Assessment and psychometric test results | 12 months after the last contact was made between you and Clevry | Electric | ICO Employment Practices Code para 1.7
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As a candidate and your job application being unsuccessful:- Contact details Application letters or forms CVs References Interview notes Assessment and psychometric test results | 12 months Application forms should give applicants the opportunity to object to their details being retained | Paper or electronic | ICO Employment Practices Code para 1.7 Equality Act 2010, s 123 |
Application records of successful candidates, including:- Application letters or forms Copies of academic and other training received References Correspondence concerning employment CVs Interview notes and evaluation forms Assessment and psychometric test papers and results | 12 months after when we have last provided our services for you | Paper or electronic | ICO Employment Practices Code para 1.7
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Criminal records information (if any):- Criminal records requirement assessments for a particular post Criminal records information forms the Disclosure and Barring Service (DBS) check forms DBS certificates | Criminal records requirement assessments for a particular post – 12 months after the assessment was last used All other information in this category – as soon as practicable after the check has been completed and the outcome recorded (ie whether satisfactory or not) | Paper or electronic | DBS guidance for employers: Duration of criminal record check validity ICO Employment Practices Code Nov 2011, part 1.7.4 |
Employment contracts (if we receive them), including: Personnel and training records Written particulars of employment Changes to terms and conditions | Seven years after employment ceases, unless document executed as a deed, in which case 13 years after employment ceases | Paper or electronic | LA 1980, ss 5, 8 |
Directors’ service contracts and any variations (if we receive them) | Seven years from termination or expiry of the contract, unless executed as a deed, in which case 13 years from termination or expiry | Paper or electronic | LA 1980, ss 5, 8 Companies Act 2006, ss 227, 228 |
Copies of identification documents (eg passports) | Not less than two years from date of termination of employment | Paper or electronic | Immigration (Restrictions on Employment) Order, SI 2007/3290, Art 6(1)(b) |
Identification documents of foreign nationals (including right to work) | Two years and six months from date of termination of employment | Paper or electronic | Immigration (Restrictions on Employment) Order, SI 2007/3290, art 6(1)(b) |
Records concerning a temporary worker | Seven years after employment ceases | Paper or electronic | LA 1980, s 5 |
If you stop using your account we will delete or anonymise your account data after 12 months.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
Transferring your personal data out of the UK and EEA
Other countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
The UK data protection law is known as the UK GDPR, derives from the EU GDPR. But the EU GDPR no longer applies to the UK.
We are based in the UK and have customers both in the UK and in the EEA. It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
We may transfer your personal data to:
- our Group offices located in Sweden and Finland,
- our Partnership Companies located in the EEA countries, and
- our Partnership Companies located outside the EEA countries, such as South Africa, Canada and/or Brazil.
As we are based in the UK we may also need to transfer your personal data from the EEA to the UK.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
- in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. We rely on adequacy regulations for transfers to the following countries: countries in the EEA
- in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. Details of the European Commission’s adequacy decisions are available here. We rely on adequacy decisions for transfers to the countries outside the EEA.
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
- a specific exception applies under relevant data protection law
Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
Cookies and other tracking technologies
A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website.
For further information on cookies and other tracking technologies we use, please see our Cookies Policy.
Your rights
You generally have the following rights, which you can usually exercise free of charge:-
Access to a copy of your personal data | The right to be provided with a copy of your personal data |
Correction (also known as rectification) | The right to require us to correct any mistakes in your personal data |
Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, for example, if you contest the accuracy of the data |
Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party (in certain situations) |
To object to use | The right to object:-
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Not to be subject to decisions without human involvement | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by our website |
The right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by contacting us to [email protected] or on (+44)1273734000 Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email, call or write to us. Please see below: ‘How to contact us’. When contacting us please:
- provide enough information to identify yourself, for example, your full name, email address, user/account number and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
- the Information Commissioner in the UK; and
- a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA
The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
For a list of EEA data protection supervisory authorities and their contact details see here.
Changes to this privacy policy
We may change this privacy policy from time to time – when we make significant changes we will take steps to inform you, via email and on our website.
How to contact us
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Our contact details | |
Postal Address: Email: Telephone: | Clevry UK Ltd, Century House, 15-19 Dyke Road, Brighton BN1 3FE, UK (44) 1273 734 000 |
