Privacy Policy

Privacy Policy

We are strongly committed to keeping your personal data safe and take our responsibilities under GDPR very seriously. We do not trade data commercially and will only disclose data with your consent, or if we are required to do so by law. If you have a query or request regarding the way we handle data, please get in touch.

 

Our registered address is: Clusters, 1 Fore St Ave, London, EC2Y 9DT, UK

 

Why we process data

We think carefully about our use of personal data, and below you can find the details of what we do to protect your privacy. We believe these purposes to be justified to allow us to run and promote our business, fulfil contractual requirements and deliver services for our clients, and meet our legal obligations. We have provided details below on the types of information we hold about different groups of people, so read on if you are interested in finding out more.

 

Clients

If you are a client of ours, it is likely we will hold the following information about you:

 

  • Name and contact details.
  • Information and documents relating to the service we are providing you with, including communications with you.

 

As part of project work, we may have contact with our clients’ own customers or clients. We undertake the following procedures to ensure that we (and our clients) comply with the GDPR:

 

  • We only accept personal data that are actively needed for carrying out research on behalf of our clients. Therefore, we will ask our clients to only send us the relevant fields that we need for each potential respondent – typically this will be just an email address and a personal identifier code enabling the client to match the email address to their fuller database where relevant
  • We require personal data to be sent between Clusters and the client in a password-protected file, with the password sent separately
  • We will store these personal data in a password-protected file, with the password retained separately
  • We will delete any personal data within 2 months of the completion of the project for which these data have been used
  • We will collect only the minimum amount of personal data (if any) required to meet research objectives
  • We will ensure respondents give informed, opt-in consent for the data we collect, clearly communicating to respondents in a privacy information notice who the data controllers are; the expected length of interview; the type of data to be collected and why; their right to withdraw consent; the retention period for any personal data; and a guarantee of anonymity/confidentiality
  • We will pseudonymise data (i.e. remove personal identifiers and hold these separately to ensure data cannot be attributed to specific individuals) as soon as possible in the research process
  • We will not outsource the processing of any personal data to any sub-data processor not directly employed by Clusters without the express permission of our client
  • We will provide respondents with a quick and easy way to request their removal from our client’s marketing databases
  • We will provide our clients with lists of any respondents wishing to be removed from their marketing databases within 1 month of the close of fieldwork
  • We will liaise with clients and suppliers to ensure they are adhering to the GDPR requirements

 

Billing and payment details

We use the personal data listed above to meet our contractual requirements as part of providing a service to you. We also use the data as part of legal requirements for elements such as tax purposes. In addition, we will use your information to invoice you and to keep track of the payments you make.

 

We will hold your information for the duration of our working relationship to allow us to continually deliver our contracted services to you, and for a further 3 years once our contract comes to an end. We retain financial records for 6 years following the end of the current financial year.

 

We use the following third-party services for some of our client work and this sometimes involves the use of client data.

 

  • Google Analytics: We use Google Analytics to collect standard online log information about visitor behaviour patterns for some clients’ websites. This helps us find out things like visitor numbers. You can view Google’s privacy notice here.
  • Google Ads: We use Google Ads to run PPC, Display and Retargeting ads for clients. For some clients this will mean the use of financial data. You can view Google’s privacy notice here.
  • Google Merchant Centre: This is an extension of the Google Ads platform and can involve the use of client’s financial data. You can view Google’s privacy notice here.

 

Prospective clients

If you are a prospective client, it is likely we will hold the following information about you:

 

  • Name and contact details.
  • Information about your business activities.
  • Information and documents relating to the service we could be providing you with, including communications with you.

 

If you make an enquiry with us by phone or email, we will use that information to follow up on that enquiry to see how we can help you. We will retain that information for the duration of the enquiry, then for a period of one year should you not become a client of ours.

 

Current and former employees

If you are an employee of Clusters, it is likely that we will hold the following information about you:

Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.

 

  • Date of birth.
  • Gender.
  • Marital status and dependants.
  • Next of kin and emergency contact information.
  • National Insurance number.
  • Bank account details, payroll records and tax status information.
  • Salary, annual leave and pension information.
  • Start date.
  • Location of employment or workplace.
  • Copy of driving licence / passport.
  • Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
  • Employment records (including job titles, work history, working hours, training records and professional memberships).
  • Performance information.
  • Disciplinary and grievance information.Information about your use of our information and communications systems.

 

We may also collect, store and use the following ‘special categories’ of more sensitive personal information:

 

  • Information about your health, including any medical conditions and health and sickness records.

 

We use this personal data to perform the contract that we have entered into with you, to comply with legal obligations and where it is necessary for ours and your legitimate interests. We may also use your personal information in the following situations, which are likely to be rare:

 

  • Where we need to protect your interests or someone else’s interests.
  • Where it is needed in the public interest or for official purposes.

 

We may have to share your data with third parties, including third-party service providers. The following activities are carried out by third-party service providers: payroll, pension administration, IT services, Human Resources.

 

Your personal data will be stored by us throughout your employment and for a period of six years once your contract with us has come to an end. 

 

Job applicants

If you apply for a job with us, it is likely we will hold the following information about you:

 

  • Name and contact details.
  • The information you have provided us with as part of your CV and covering letter, including communications with you.
  • Any information you provide to us during the interview process.

 

We may also collect, store and use the following ‘special categories’ of more sensitive personal information:

 

  • Information about your health, including any medical conditions and health and sickness records.

 

We use this personal data to assess your skills, qualifications and suitability for the role, to communicate with you during the recruitment process, to keep records relating to our recruitment process, to comply with legal and regulatory requirements. We will use any information that you provide to us regarding your health and disability status to make any necessary adjustments during the recruitment and interview process.

 

If your application is not successful, we will retain your personal data for a period of 6 months after we have informed you of our decision. If you are successful, then your data will be transferred to your personnel file and handled in line with the ‘current and former employees’ section above.

 

Website visitors

When you visit https://clusters.uk.com/, we use Google Analytics (third-party service) to collect standard online log information about visitor behaviour patterns. This helps us find out things like visitor numbers to certain parts of our website. This information is processed in a way that does not identify anyone individually.

 

Our website uses session-based cookies as part of Google Analytics and these are not used for re-marketing purposes. You can view Google’s privacy notice here.

 

If you want to opt-out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

 

Social media

If you contact us via a private or direct message on social media, these will be stored within that individual social media channel. It will not be shared with any other organisation and will be deleted within 1 year.

 

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from a director at Clusters.

 

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

 

Your rights

If your data is processed by Clusters, you have the following rights:

 

  • The right to be informed, which is what this privacy policy is for.
  • The right to access what data we hold about you.
  • The right to object to direct marketing – either use the unsubscribe option or contact us directly.
  • The right to object to processing carried out on the basis of legitimate interests.
  • The right to erasure (in some circumstances).
  • The right to data portability.
  • The right to have your data rectified if it is inaccurate.
  • The right to have your data restricted or blocked from processing.

 

If you ever want to verify, update or amend your personal data, please email hello@clusters.uk.com.

You also have the right to lodge a complaint about our processing with the UK’s Information Commissioner’s Office.

 

Changes to our privacy notice

We constantly review information to ensure that we comply with GDPR requirements and, therefore, keep this privacy notice under review. This was last updated on 09/11/2020.

 

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Email us: hello@clustersinsights.com

Call us: +44(0) 20 3950 6624

Find us: 1 Fore St Ave, London, EC2Y 9DT, UK

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