ClarusONE Sourcing Services

Privacy Statement

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ClarusONE Sourcing Services LLP is the controller and responsible for your personal data (hereinafter referred to as “we”, “us” and “our”).  We respect your privacy and are committed to protecting your personal data and this privacy statement describes our current policies and practices with regard to your personal data which we collect from you directly and/or in connection with your use of our website. 

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This privacy statement applies to everyone about whom we hold personal data who is not deemed current (or former) staff, an agent on our behalf or contractor or someone who has applied for a job with us.

Job applicants should refer to our Recruitment Privacy Notice, which is available at: https://www.clarusonesourcing.com/recruitment-privacy-notice

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Personal Data We Collect About You

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Personal data or personal information means any information about you from which you can be identified.  It does not include data where the identity has been removed (“Anonymous Data”).

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We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

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• Identity and Contact Data includes name, title, address, email address, telephone number and business contact information to include your role, position and/or job title within your employment, occupation and country of residence;

• 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/device you use to access this website; and

• Usage Data includes information about how you use our website.

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We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. 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 statement.

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We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. This website is not intended for children and we do not knowingly collect data relating to children.

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How Your Personal Data Is Collected

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We use different methods to collect data from and about you including through:

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• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you give us feedback or contact us.

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• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

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• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below

Technical Data and Usage Data from the following parties:

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• analytics providers such as Google Analytics

• search information providers such as Google Search.

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How Do We Use Your Personal Data?

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We process your personal data in accordance with the data protection principles as set out in the UK retained version of the General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 and other applicable data protection/privacy laws.

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Data will be processed only insofar as is necessary and permitted under data protection law, and we will process your personal data on one or more of the following legal grounds:

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• for the performance of a contract or in order to take steps prior to entering into a contract with you;

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• where it is necessary for the legitimate interests of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience (or those of a third party) and your interests and fundamental rights do not override those interests;

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• where we need to comply with a legal obligation that we are subject to; and

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• if you have expressly consented to the processing, (you may withdraw consent at any time, as detailed below).

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Purposes of Data Processing 

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We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

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Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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Change of Purpose

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We will only use your personal data for the purposes for which we collected it. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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Sharing Your Personal Data

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Your personal data will only be shared with:

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• our staff (including external consultants), professional advisers and agents;

• Internal departments or organisational units and other companies affiliated with us or our members on a confidential basis;

• External third parties which process your personal data on our behalf and who are bound by contractual obligations to keep your personal data confidential and appropriately secure; and

• Any government, regulatory agency, and law enforcement officials, if required for the purposes specified above, if mandated by law, or if required for the legal protection of our legitimate interests in compliance with applicable laws.

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International Transfers

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We may transfer the personal data we collect from you to parties based outside the UK. When we do, such transfers will only be to countries which are deemed to provide an adequate level of protection, we will rely upon the execution of approved ‘Standard Contractual Clauses’ which prescribe the level of protection to be given to that data to govern those transfers, and/or implement other safeguards that  are in line with UK data protection laws.

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If you are not based in the UK, any personal data collected from you will also be transferred to the UK, which is where ClarusONE is located.

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We will be happy to provide you with the relevant, detailed information on request.

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Data Security

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We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to staff, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality and their legal obligations under data protection laws.

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

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Data Retention

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We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

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To determine the appropriate retention period for personal data, we 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 we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

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Rights of Access, Correction, Erasure and Restriction

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You are entitled, by law to the following rights:

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• 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;

• 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;

• 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;

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data, for example if you want us to establish the data's accuracy;

• Request the transfer of your personal data to you or to a third party; and

• 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 process that personal information unless we have another legitimate basis for doing so.  An email is sufficient.

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If you wish to exercise any of the rights set out above, please contact us using our contact details below.

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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.

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We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to help speed up our response.

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Are You Required to Provide Personal Data?

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In principle, you are under no obligation to provide us with personal data. However, if you do not provide us with personal data, we cannot respond to enquiries that you send to us.

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Further Questions, Feedback or Complaints

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If you have any questions about this privacy statement or you would like to raise a complaint or comment please contact us by emailing us at Data_Governance@clarusonesourcing.com or by writing to us at: Attn: Data Protection Coordinator, ClarusONE Sourcing Services LLP, Russell Square House, 10-12 Russell Square, London, WC1B 5EH United Kingdom

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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.

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Amendments to this Privacy Statement

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We keep our privacy statement under regular review and reserve the right to amend this privacy statement at any time. Any changes will be published on our website and shall take effect immediately. Please therefore regularly check this privacy statement to make sure you are aware of the latest version.

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Last updated January 2022