Data Protection Policy

Policy information

Organisation

The Data Controller is CLOCKHOUSE CAPITAL Limited, a limited company registered in England and Wales (registration number 08287721) the registered office of which is at Finsgate, 5-7 Cranwood Street, London, EC1V 9EE. You can contact the data controller by writing to The CEO, CLOCKHOUSE CAPITAL Ltd, Finsgate, 5-7 Cranwood Street, London, EC1V 9EE or by sending an email to info@clockhousecapital.com.

CLOCKHOUSE CAPITAL have no Data Processors, in relation to personal data, i.e. any person (other than an employee of the data controller) who processes the data on behalf of the data controller.

Policy operational date

25/05/2018

Policy prepared by

The CEO, the Data Protection Officer.

GDPR

The European General Data Protection Regulation, came into force on 25th May 2018 and is the basis of this Data Protection Policy.

Introduction

Purpose of policy

This Data Protection Policy sets out how we, CLOCKHOUSE CAPITAL Limited, collect, store and use information about you when you use our website, https://CLOCKHOUSE CAPITAL.com and where we otherwise obtain or collect information about you.

The reasons for the policy are to comply with the law, follow good practice, to protect clients, staff and other individuals and to protect the company.

Types of data

We collect individual information from our company staff and individual and company information from consumers of our research.

Policy statement

This Data Protection Policy complies with both the law and good practice and respects individuals’ rights. The company will be open and honest with individuals whose data is held and provide training and support for staff who handle personal data, so that they can act confidently and consistently.

In the event of data breaches the Supervisory Authority (the ICO) will be notified within 72 hours. In addition, for major breaches the data subjects will be notified without delay. A personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data.

Responsibilities

The Board / Company Directors

The Board has overall responsibility for ensuring that the organisation complies with its legal obligations.

Data Protection Officer

The Data Protection Officer is The CEO, CLOCKHOUSE CAPITAL. His responsibilities include:

Briefing the Board on Data Protection responsibilities
Reviewing Data Protection and related policies
Advising other staff on Data Protection issues
Ensuring that Data Protection induction and training takes place
Notification to the ICO if required
Handling subject access requests
Approving unusual or controversial disclosures of personal data
Approving contracts with Data Processors

Employees

All staff should read, understand and accept any policies and procedures that relate to the personal data they may handle in the course of their work.

Types of information collected

Individuals’ names

We record the names and contact details of the individuals within institutions with whom we have research supply agreements.

Business name and contact details

We record the names, ‘know your client’ information and contact details of the institutions with which we have research supply agreements.

Updating

We have a regular cycle of checking, updating or discarding old data on our staff and research clients.

Lawful basis for processing information

Underlying principles

The lawful basis for the personal data processed is one or more of the following, described in Article 6 (1) of the General Data Protection Regulation:

(a) Consent: the individual has given clear consent for us to process their personal data for a specific purpose.

(b) Contract: the processing is necessary for a contract we have with the individual, or because they have asked us to take specific steps before entering into a contract.

(d) Vital interests: the processing is necessary to protect someone’s life.

(e) Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.

(f) Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.)

Data collected from our clients is on the basis of (b) contracts and (f) our legitimate interests.

Withdrawing consent

Once given, consent can be withdrawn, but not retrospectively. There may be occasions where CLOCKHOUSE CAPITAL has no choice but to retain data for a certain length of time, even though consent for using it has been withdrawn.

How information is collected and stored

Web server information

We record the name, email address, postal address and telephone number of individuals filling in the form on the Contact page on the website. This information is not transferred outside the EEA and is stored on our own web server in the United Kingdom.

Cookies

We do not use cookies on our website.

Email

We collect and store emails on three personal computers and on our email server in the United Kingdom. Information is not transferred outside the EEA.

Bulk Email provider

We use a third-party provider, Squarespace, to deliver our products. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our products. For more information, please see Squarespace’s privacy notice.

Hard drive and back ups

We store information on the hard drives of computers and back it up on Dropbox, Office 365 and Google cloud-based systems.

Disclaimer

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means) you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Phone

We log all telephone calls with research clients for monitoring purposes but do not record conversations.

Paper copies

Information from compliance procedures, such as on-boarding and quarterly compliance meetings, is stored on hard copy files and kept in secure storage.

Disclosure and use of information

Commitment

CLOCKHOUSE CAPITAL is committed to ensuring that Data Subjects are aware that their data is being processed and

for what purpose it is being processed
what types of disclosure are likely, and
how to exercise their rights in relation to the data

We retain contact details of clients so that we can provide them with services in accordance with the Agreements we have with them.

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by contacting the Data Protection Officer by email at info@clockhousecapital.com, in writing to: CLOCKHOUSE CAPITAL Ltd, Finsgate, 5-7 Cranwood Street, London, EC1V 9EE:

to request access to your information and information related to our use and processing of your information;
to request the correction of your information;
or request the erasure of personal data (right to be forgotten) providing there is no overriding legitimate grounds;
to request that we restrict our use of your information;
to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller
to object to the processing of your information for certain purposes; and
to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

The controller will provide information on action taken on request to the data subject without undue delay and in any event within one month of receipt of the request.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, which is the Information Commissioner’s Office (ICO), whose website is below.

Employee training & acceptance of responsibilities

Induction

All employees of CLOCKHOUSE CAPITAL and those who have access to any kind of personal data will have their responsibilities outlined during their induction procedures.

Continuing training

Data Protection issues will be covered during employee training, team meetings, supervisions, etc.

Further information

For more information

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/