Clearwater Risk Management Ltd

Privacy & Data Protection Policy

Last updated: October 2026

1. Introduction

Clearwater Risk Management Ltd ("Clearwater", "we", "us" or "our") is committed to protecting personal information and respecting the privacy of everyone who uses our website or engages with our services.

We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and other applicable data protection legislation.

This policy explains how we collect, use, store and protect personal information in connection with our health and safety consultancy, auditing and training services.

2. Information We Collect

We may collect and process the following personal information:

Names, job titles and organisational details.

Business email addresses, telephone numbers and contact information.

Information provided through website enquiries, correspondence and service requests.

Training course registrations, attendance records, assessment results and certification information.

Information required to administer contracts, bookings, payments and invoices.

Technical information relating to website use, where collected through website functionality or analytics.

We generally collect information directly from individuals or from the schools, academy trusts and organisations arranging our services.

3. How We Use Personal Information

We use personal information where necessary to:

Respond to enquiries and provide information about our services.

Arrange and deliver health and safety training, audits and consultancy services.

Administer course bookings, assessments and certification.

Maintain appropriate training and service records.

Communicate with clients and delegates about services they have requested.

Manage contractual, financial and administrative obligations.

Meet applicable legal and regulatory requirements.

Improve our services and website.

We only use personal information for legitimate business purposes and in accordance with applicable data protection legislation.

4. Lawful Basis for Processing

Depending on the circumstances, Clearwater processes personal information on one or more of the following lawful bases:

Contractual necessity: Where processing is necessary to provide services or take steps requested before entering into a contract with an individual.

Legitimate interests: Where processing is necessary for the effective operation of our business, including responding to professional enquiries, maintaining client relationships and administering our services, provided these interests are not overridden by individuals' rights.

Legal obligations: Where information must be processed or retained to comply with applicable law.

Consent: Where consent is required, including for certain marketing communications or non-essential website technologies. Consent may be withdrawn at any time.

5. Sharing Personal Information

We do not sell personal information to third parties.

Where necessary, we may share relevant information with:

IOSH and other relevant awarding or certification organisations for training administration and certification.

Approved service providers supporting our IT systems, website, communications and business administration.

Professional advisers where reasonably necessary.

Regulatory authorities or other organisations where disclosure is required by law.

We limit the information shared to what is necessary for the relevant purpose and take appropriate steps to ensure it is handled securely.

6. Information Security

Clearwater takes reasonable and proportionate technical and organisational measures to protect personal information against unauthorised access, accidental loss, misuse, alteration or disclosure.

Access to personal information is restricted to those who require it for legitimate business purposes.

We review our information-handling arrangements as appropriate to the nature and sensitivity of the information processed.

7. Retention of Personal Information

We retain personal information only for as long as necessary for the purposes for which it was collected, including applicable legal, contractual, financial and certification requirements.

Retention periods depend on the nature of the information and the relevant obligations. Information that is no longer required is securely deleted or otherwise disposed of.

8. Website Cookies and Analytics

Our website may use cookies or similar technologies to support essential website functionality and, where implemented, understand how visitors use the site.

Where consent is legally required for non-essential cookies or similar technologies, we will provide appropriate information and obtain consent before using them.

Visitors may also manage cookies through their browser settings.

9. International Data Transfers

Where personal information is processed or stored outside the United Kingdom, we will ensure that appropriate safeguards are in place in accordance with applicable data protection legislation.

10. Your Data Protection Rights

Under UK data protection legislation, individuals have rights which may include:

Accessing personal information held about them.

Requesting correction of inaccurate or incomplete information.

Requesting deletion of personal information in certain circumstances.

Requesting restriction of processing.

Objecting to certain processing activities.

Requesting data portability where applicable.

Withdrawing consent where processing relies on consent.

These rights are subject to applicable legal conditions and exemptions.

Requests relating to personal information can be made using the contact details below.

11. Marketing Communications

We may contact existing or prospective organisational clients with relevant information about our professional services where permitted by law.

Where consent is required, we will obtain it before sending marketing communications.

Recipients may opt out of marketing communications at any time by contacting us or using an unsubscribe facility where provided.

12. Third-Party Websites

Our website may contain links to external websites, including professional bodies and training-related organisations.

Clearwater is not responsible for the privacy practices or content of third-party websites. Visitors are encouraged to review the relevant privacy policies.

13. Changes to This Policy

We may update this policy periodically to reflect changes in legislation, our services or the way we process personal information.

The latest version will be published on our website.

14. Contact and Complaints

For questions about this policy or requests relating to personal information, please contact:

Clearwater Risk Management Ltd

Email: enquiries@clearwater.uk.com

If you are dissatisfied with how your personal information has been handled, you may also raise a complaint with the Information Commissioner's Office (ICO).

Website: www.ico.org.uk