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Privacy Policy

Privacy Statement

Updated July 2024

 

Introduction

At Clear Voice we are committed to protecting your privacy and being transparent about how we use your data. We will only use the information we collect about you lawfully in accordance with UK Data Protection Law which includes the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA). This Privacy Policy, together with our website Terms and Conditions, tells you what personal information we collect and how we use and store your that personal information. For the purposes of this notice, Clear Voice acts as a data controller.

Clear Voice is the trading name of Migrant Help Trading Limited which for the purposes of the law is the data controller. This limited company is wholly owned by the charity Migrant Help. All Migrant Help Trading Limited’s profits are donated to its parent charity, supporting the vital work it undertakes.

Where Clear Voice provides its services to customers, it may act as a data processor in accordance with the UK GDPR article 28 clauses. These clauses can be found in our Terms and Conditions and the purposes for processing the personal data can be found in Annex A of those terms.

 

How we collect information from you

We may collect information from you as a result of the following activities:

  • Using any of our products and services
  • Making payments
  • Contacting us by email
  • Contacting us through our website, by submitting a contact form
  • Visiting our website (for example generating cookies and recording your IP address and other browser data for analytics purposes)

Some of the information you give to us will be held on central systems and accessed by authorised staff only.

We may also process personal data of our contractors and those that apply to work for us and staff members.

 

Transferring data outside the UK

Where data is transferred from the UK to an adequate country or to a third country, in accordance with the UK adequacy regulations (details of which can be found on the ICO’s website), we will ensure such transfers are protected by suitable and appropriate safeguards such as the UK International Data Transfer Agreement. This may be subject to a Transfer Risk Assessment. Any changes to these requirements in the UK will be reflected in updated versions of this notice so please revisit this site to ensure you are informed of any amendments we may make.

 

How we obtain and treat any information about you

Any information we collect about you will:

  • Be obtained and processed fairly and lawfully and shall not be processed unless certain conditions are met
  • Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with that purpose
  • Be adequate, relevant and not excessive for those purposes
  • Be accurate and kept up to date
  • Not be kept for longer than is necessary for that purpose
  • Be processed in accordance with the data subject's rights
  • Be kept safe from unauthorised access, accidental loss or destruction
  • Not be transferred to a country outside the European Economic Area, unless that country has equivalent levels of protection for personal data or where suitable safeguards exist. The type and quantity of information we collect and how we use it depends on why you are providing it.

The type and quantity of information we collect and how we use it depends on why you are providing it.

 

Customers and potential customers

Customers procuring a service from Clear Voice must complete an Account Registration form or in some cases sign a contract. If you receive a quote, book, use or purchase a service with Clear Voice, we will collect and store this information in our secure database.

 

Suppliers

New suppliers will complete a Contract of Supply. The Contract, application forms, references, contact details and bank details are kept electronically. Suppliers may act as a data processor to Migrant Help Trading Limited, with Migrant Help Trading Limited acting as the data controller.

 

Retention

We are required to retain records of our business activities, and this may include personal data. The retention of personal data is likely to be governed by a statutory obligation. Where this is not the case, we may retain the information in accordance with our records of processing activity and internal procedures.

Data and documentation will be retained for a period of seven years beyond the last date of entry on the records. Any paper documentation is disposed of by secure shredding. Electronic files will be deleted securely by the IT Department.

Other retention periods may apply. If you would like further details about this, please contact us at [email protected] 

 

Making a complaint

Clear Voice has a complaints procedure for their services. Formal complaints must be reported in writing either via an email or by using the dedicated complaints contact form available on our website.

You may also complain to the Information Commissioner’s Office (ICO) who regulate information rights in the UK. For further details about this please visit their website.

If you reside outside of the UK, you will need to consult your local regulator.

 

How we keep your data safe and who has access

Clear Voice ensures that there are appropriate technical controls in place to protect your personal details. For example, our online forms are always encrypted, and our network is protected and routinely monitored.

We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained personnel.

We may use external companies to collect or process personal data on our behalf. We do comprehensive checks on these companies before we work with them and put a contract in place that sets out our expectations and requirements, especially regarding how they manage the personal data they have collect or have access to.

If you have any queries about this statement, please contact us at Clear Voice, 128 City Road, London, EC1V 2NX or email [email protected] 

 

Your right to know what data we keep, how to make changes or ask us to stop using your data 

Customers have the right to access any personal data that is being kept about them by Clear Voice.

  • Any private client who wishes to exercise this right should contact the Director in writing using [email protected] 
  • The organisation aims to comply with requests for access to personal information as quickly as possible but will ensure that it is provided within one month as per the UK GDPR guidelines. This can be extended where requests are complex or numerous, but the individual must be notified within one month of the receipt of the request and given an explanation for why the extension is needed.

Other important information rights include: 

  • The right to erasure. This right enables you to request us to delete your records. Some exclusions may apply. 
  • The right to be informed. You have the right to know what data we are processing and why. 
  • The right to question an automated decision made about you. We do not currently make such decisions. 
  • The right to have inaccuracies concerning your personal data rectified. If you believe any of the information we hold about you is inaccurate, please get in touch with us at [email protected]
  • The right to object. You have the right to object to our handling of your personal data. If you have any concerns, please get in touch.

 

Lawful Basis

Under the DPA we process data under the “conditions for processing”. Under the UK GDPR, this is our “lawful basis” for processing personal data. This policy documents our lawful basis.

The lawful basis for processing data can include:

  1. Consent of the data subject
  2. Processing is necessary for compliance with a legal obligation
  3. Processing is necessary to protect the vital interests of a data subject or another person
  4. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
  5. Processing is necessary for purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject.

The conditions for special categories of data, formerly known as sensitive data, are:

  1. Explicit consent of the data subject, unless reliance on consent is prohibited by UK Data Protection law
  2. Processing is necessary for carrying out obligations under employment, social security, social protection law or a collective agreement. This includes where we engage contractors to provide us with a service.
  3. Processing necessary to protect the vital interests of a data subject where the subject is incapable of giving consent
  4. Processing is necessary for the establishment, exercise or defence of legal claims
  5. Processing is necessary for reasons of substantial public interest
  6. Processing is necessary for the assessing the working capacity of the employee
  7. Processing is necessary for reasons of public interest in the area of public health.

 

Legal basis for processing

We rely on the following lawful basis for processing personal data where we act as a data controller:

  • Provide services to customers – Contractual obligation/legitimate interest
  • Evaluate service delivery – Legitimate interest
  • Market to potential customers – Legitimate interest or consent

In regard to special categories, we will seek consent to collect, store and process their data unless we rely upon schedule 1 or 2 of the Data Protection Act 2018. Where required an appropriate policy document may be in force.

Where we act as a data processor and on behalf of our customer acting as the data controller, we will rely upon the lawful basis we are instructed to use to process the personal data.

In addition, in regard to special categories, processing is necessary for the establishment exercise or defence of legal claims.

Wherever we may use our legitimate interest to process personal data, you may object to such processing. If you wish to object, please contact us at [email protected]

 

Using our website

What are cookies? 

Our website uses cookies to collect information. Cookies are small data files which are placed on your device when you browse a website. Cookies are essential to the effective operation of our website and improve the performance and your experience of using our website. They may be essential to some aspects of the website for example if you are required to register to attend an event or purchase a service.

 

Information collected 

Some cookies may collect information about browsing behaviour from the same device. This includes information about pages viewed. We do not use cookies to collect or record personal information such as name, address or other contact details.

 

How do I disable cookies?

The Clear Voice website implements the cookie consent solution CookieYes to give you itemised control over the cookies used. A cookie consent banner will be displayed on your first visit to the website, allowing you to set your cookie permissions. These settings can be adjusted at any time by clicking or tapping on the CookieYes icon which is visible on every page of the Clear Voice website.

If you want to completely disable cookies you need to change your website browser settings to prevent cookies being stored.

 

What happens if I disable cookies?

This depends on which cookies you disable, but the site may not function fully if cookies are completely disabled.

 

IP addresses

IP addresses may be collected when connecting to our website and are not linked to individuals.