Terms and Policies
We may have to collect and use information about contacts, clients, subcontractors with whom we work. This personal information must be handled and dealt with properly, however it is collected, recorded and used, and whether it be on paper, in computer records or recorded by any other means.
We regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining confidence between us and those with whom we carry out business. We will ensure that we treat personal information lawfully and correctly.
To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR).
This policy applies to the processing of contact and client data in manual and electronic records kept by us in connection with our human resources function as described below. It also covers our response to any data breach and other rights under the GDPR.
This policy applies to the personal data of existing and former clients, professional contacts, subcontractors and self-employed contractors. These are referred to in this policy as relevant individuals.
“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data.
“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
DATA PROTECTION PRINCIPLES
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
processing will be fair, lawful and transparent
data be collected for specific, explicit, and legitimate purposes
data collected will be adequate, relevant and limited to what is necessary for the purposes of processing
data will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
data is not kept for longer than is necessary for its given purpose
data will be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
we will comply with the relevant GDPR procedures for international transferring of personal data
TYPES OF DATA HELD
We keep several categories of personal data on our existing and former clients, professional contacts, subcontractors and self-employed contractors clients / subcontractors in order to carry out effective and efficient processes. We keep this data on a secure server within our computer systems.
Specifically, we hold the following types of data:
personal details such as name, address, phone numbers
information gathered via the subcontractor approval process such as that entered into a CV such as details on your education and employment history etc, references from former clients, details of Health & Safety Staff, Business Insurances and official memberships,
All of the above information is required for our processing activities. More information on those processing activities are included in our privacy notice for employees, which is available from your manager.
In order to protect the personal data of relevant contacts, clients and subcontractors those within our business who must process data as part of their role have been made aware of our policies on data protection.
We have also appointed employees with responsibility for reviewing and auditing our data protection systems.
LAWFUL BASES OF PROCESSING
We acknowledge that processing may be only be carried out where a lawful basis for that processing exists and we have assigned a lawful basis against each processing activity.
Where no other lawful basis applies, we may seek to rely on the contacts, clients or subcontractors consent in order to process data.
However, we recognise the high standard attached to its use. We understand that consent must be freely given, specific, informed and unambiguous. Where consent is to be sought, we will do so on a specific and individual basis where appropriate. Contacts, clients and subcontractors will be given clear instructions on the desired processing activity, informed of the consequences of their consent and of their clear right to withdraw consent at any time.
ACCESS TO DATA
As stated above, contacts, clients and subcontractors have a right to access the personal data that we hold on them. To exercise this right, contacts, clients and subcontractors should make a Subject Access Request. We will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.
No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the employee making the request. In these circumstances, a reasonable charge will be applied.
Further information on making a subject access request is contained in our Subject Access Request policy.
The company may be required to disclose certain data/information to any person. The cirucumstances leading to such disclosures include:
- To assist law enforcement or a relevant authority to prevent or detect crime or prosecute offenders or to assess or collect any tax or duty.
Employees are aware of their roles and responsibilities when their role involves the processing of data. All employees are instructed to store files or written information of a confidential nature in a secure manner so that are only accessed by people who have a need and a right to access them and to ensure that screen locks are implemented on all PCs, laptops etc when unattended. No files or written information of a confidential nature are to be left where they can be read by unauthorised people.
Where data is computerised, it should be coded, encrypted or password protected both on a local hard drive and on a network drive that is regularly backed up. If a copy is kept on removable storage media, that media must itself be kept in a locked filing cabinet, drawer, or safe.
Employees must always use the passwords provided to access the computer system and not abuse them by passing them on to people who should not have them.
Personal data relating to contacts, clients and subcontractors should not be kept or transported on USB sticks, or similar devices, unless prior authorisation has been received. Where personal data is recorded on any such device it should be protected by:
ensuring that data is recorded on such devices only where absolutely necessary.
using an encrypted system — a folder should be created to store the files that need extra protection and all files created or moved to this folder should be automatically encrypted.
ensuring that USB drives or similar devices are not left where they can be stolen.
Failure to follow the Company’s rules on data security may be dealt with via the Company’s disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure.
THIRD PARTY PROCESSING
Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain the Company’s commitment to protecting data.
INTERNATIONAL DATA TRANSFERS
The Company may be required to transfer personal data to a country/countries outside of the EEA. Transfers may take place for issuance of travel, visas, accommodation etc. Where this occurs, the following safeguards are adopted, all documents are kept on a secure server, and all e-mail accounts are password protected any information sent is sent directly to the client contact, or Visa company (CIBT).
REQUIREMENT TO NOTIFY BREACHES
All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.
More information on breach notification is available in our Breach Notification policy which can be provided on request.
All employees receive training covering basic information about confidentiality, data protection and the actions to take upon identifying a potential data breach.
The nominated data controller/auditors/protection officers for the Company are trained appropriately in their roles under the GDPR.
All employees who need to use the computer system are trained to protect individuals’ private data, to ensure data security, and to understand the consequences to them as individuals and the Company of any potential lapses and breaches of the Company’s policies and procedures.
The Company keeps records of its processing activities including the purpose for the processing and retention periods in its HR Data Record. These records will be kept up to date so that they reflect current processing activities.
DATA PROTECTION COMPLIANCE
Our appointed compliance officer in respect of our data protection activities is:
We will not sell data about our users to any third party, but if you are concerned about third parties collecting information via cookies we recommend using a tool designed to control your cookie usage.
ClearLead Consulting Limited is fully committed to ensuring the delivery of a high-quality service to all our clients. It is our aim to establish and maintain a reputation as a leading provider of advice on energy, sustainability and environmental legal compliance, both in the UK and internationally.
It is our policy to:
Strive to meet and exceed our compliance obligations including customer expectations, statutory obligations and the requirements of interested parties.
Present a practical, business-orientated approach to our clients, involving them at each stage in the project and thereby establishing mutually beneficial long-term relationships and partnerships.
Set appropriate quality objectives and targets as part of our Integrated Management System (IMS) which meets the requirements of ISO 9001:2015.
Develop and foster a culture in our management system that promotes continuous improvement in our business to enhance quality, performance and customer satisfaction.
Understand the risks and opportunities that need to be addressed to give assurance that the management system can be effective in achieving these objectives.
Ensure adequate financial, physical and human resources are committed by the company to allow staff to undertake their duties regarding quality matters, including for the continuous professional development of our staff.
Continuously evolve our services to ensure we meet our client’s future requirements, and adapt processes and procedures to ensure that changes are fully adopted.
Environment & Sustainability Policy
ClearLead Consulting Ltd is fully committed to promoting good environmental and sustainability practice within our own organisation and that of our clients and partners. Our aim is to play a proactive role in contributing to sustainable development where we have influence.
Furthermore, we recognise that in undertaking our work we have potential environmental impacts and therefore we have a duty to ensure that we proactively manage these to protect the environment and prevent pollution.
It is our policy to:
Use leadership to create an organisational culture which integrates environmental and sustainability into our everyday activities, working environment and business processes.
Identify potential environmental and sustainability issues and impacts and assess key risks and opportunities to prioritise those requiring action as part of our objectives and targets.
Understand the needs and expectations of our stakeholders and interested parties and communicate with them in a transparent and ethical manner, including communicating the requirements of this policy.
Ensure continuous improvement in our integrated management system to enhance environmental and sustainability performance.
Meet all applicable compliance obligations including environmental legislation and the expectations of our interested parties, including customer’s expectations.
Develop our employees to ensure that they are fully aware of the environmental and sustainability issues to be considered as part of our project delivery.
Manage our office activities to source materials sustainably, minimise waste generation, maximise recycling and use of resources efficiently.
Minimise the carbon emissions related to transport through minimising business travel, using public transport as a first choice and facilitating home working where appropriate.
Support local communities through providing work experience placements, sourcing locally for relevant products and services and supporting charitable causes.
Work with our clients and partners to ensure that sustainability is embedded within the projects we deliver.
Adequate financial, physical and human resources are to be committed by the company to allow staff to undertake their duties regarding environmental and sustainability matters.
Health, Safety and Wellbeing Policy
ClearLead Consulting Ltd is fully committed to protecting the safety, health and wellbeing of all employees. Our health, safety and welfare policy is to:
Prevent accidents and cases of work-related ill health by managing the health and safety risks in the workplace. This will be done through the completion of relevant risk assessments and implementation of actions arising out of those assessments. Risk assessments will be reviewed when working habits or conditions change. We will work closely with clients, suppliers and contractors to ensure protection of health, safety and welfare.
As a minimum comply with applicable legal and other requirements. This will be done through the identification of relevant compliance obligations related to our health and safety hazards and keeping up to date with any changes. We will also regularly evaluate our compliance status against these requirements.
Provide clear instructions and information, and adequate training, to ensure employees are competent to do their work. Staff and subcontractors are given necessary health and safety information and provided with appropriate training and personal protective equipment. We will ensure that suitable arrangements are in place to cover employees engaged in work remote from the main company office.
Engage and consult with employees on day-to-day health and safety conditions. Staff will be routinely consulted on health and safety matters as they arise and also regularly consulted during team meetings and at annual Review meetings, or sooner if required.
Implement emergency procedures – evacuation in case of fire or other significant incident. A fire risk assessment has been completed and escape routes are kept clear at all times. Evacuation plans are tested from time to time and updated as necessary.
Maintain safe and healthy working conditions. A system is in place for routine inspections and testing of office infrastructure and equipment and for ensuring that action is promptly taken to address any defects.
Develop a productive workforce through encouraging healthy lifestyles and supporting staff to achieve a happy work life balance. This will be achieved through fostering an open and supportive culture where employees at all levels feel valued and empowered to contribute in achieving company goals, personal wellbeing and ultimately making a difference to our clients.
Ensure continuous improvement in our health and safety performance: This will be done through the implementation of an OHSAS 18001 compliant integrated management system (IMS) and the setting and reviewing of annual objectives and targets.
Our Health, Safety and Wellbeing Policy applies to:
All employees (including Directors), whether working in the UK or overseas;
Those potentially affected by ClearLead Consulting activities (including clients, suppliers and contractors);
All work activities, whether in the office, on-site or elsewhere;
All systems and places of work; and
All materials (including hazardous substances) and equipment used for, or encountered during normal work activities.
The health and safety law poster is displayed in our office. A first aid kit and accident book are also kept within our office.
The Directors have ultimate responsibility for health, safety and welfare and has day-to-day responsibility for ensuring this policy is put into practice with the assistance of a qualified Health and Safety Advisor.