Privacy Policy

This is the privacy policy of Claymore Manning Ltd (referred to as "Claymore Manning"). It states how the company uses and protects the personal information that you provide.

Claymore Manning is committed to ensuring that your privacy is protected. Claymore Manning will be reviewing and may change this policy periodically, with the latest version available at www.claymoremanning.com/privacy-policy.

Introduction

Claymore Manning is a data controller, and can be contacted as follows:

Email: team@claymoremanning.com

Mail: Claymore Manning, Avondale House, Strathclyde Business Park, Bellshill, ML4 3NJ, UK

Claymore Manning provides ROV & Plough Operations, Logistics & Equipment Management Engineering Services to the Subsea Cable Industry.

The person responsible for data protection matters is Sam Gallaway, Director and can be contacted by email using s.gallaway@claymoremanning.com.

Your Rights

The EU General Data Protection Regulation (GDPR) sets out the following rights applicable to you as a data subject:

  • The right to be informed – when we collect your data, we will tell you what data, why we are collecting it, how we will use it and how long we will store it for

  • The right to access – you have the right to access any personal data we hold about you and relevant supplementary information, so that you can verify the lawfulness of our processing

  • The right to rectification – making sure that the data we hold about you is accurate and as complete as necessary for the purposes we hold it

  • The right to erasure – you can ask us to erase any personal data that we hold about you. This is not an absolute right, applying only in certain circumstances, but we will review any such requests and communicate with you openly about your rights and our actions

  • The right to restrict processing – you can permit us to store your data but ask us not to use it further (although again this applies only certain circumstances)

  • The right to data portability – you can request from us any data that you have provided directly that you then wish to use for your own purposes across different services

  • The right to object – you can object to processing of your personal data and we must comply unless there are compelling legitimate grounds to the contrary

Claymore Manning is committed to abiding by these rights upon request and will act accordingly to any requests made in connection with these rights.

Our Responsibilities

Claymore Manning abides by the 6 principles outlined in the GDPR:

  • processed lawfully, fairly and in a transparent manner

  • collected for specified, explicit and legitimate purposes

  • adequate, relevant and limited to what is necessary

  • accurate and, where necessary, kept up to date

  • retained only for as long as necessary

  • processed in an appropriate manner to maintain security

Data We Collect

The following is collected and retained during the application process:

  • Full Name

  • CV

  • Contact Information including email address, telephone numbers, home address, skype address

  • Nationality

  • Education history, Qualifications and Skills

  • Referees

  • Information contained in references and pre-employment checks from third parties

The following is collected in relation to project deployment:

  • Emergency Contact Information

  • Date and Place of Birth

  • Passport & Visa Details and Scans

  • Other information such as driving licence, Seamans Book, industry certifications, industry specific annual medical and data specific in the obtaining of work permits and visas

  • Travel Preferences

  • Bank Details

  • Employment related information

Processing Your Information

The processing of your personal information may include:

  • Collecting and storing your personal data, whether in manual or electronic files

  • Notifying you of potential roles or opportunities

  • Assessing and reviewing your suitability for job roles

  • Introducing and/or supplying you to actual or potential Clients

  • Engaging you for a role with us or with our Clients including any related administration e.g. timesheets, travel documents

  • Sending information to third parties with whom we have or intend to enter into arrangements which are related to your deployment on projects.

  • Providing information to regulatory authorities or statutory bodies, and our legal or other professional advisers including insurers

  • Establishing quality, training and compliance with our obligations

Lawful Basis

We will only administer personal information in accordance with the lawful basis for processing. At least one of the following will apply when we process personal data:

1) Consent:

We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you apply for a particular role you may have consented to our processing of the data that has been provided for the purpose of progressing your application and considering your suitability for that role. In other cases you may have provided your written or verbal consent to the use of your data for a specific reason.

You may withdraw your consent to our processing of your personal information for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.

2) Legitimate Interests:

In providing you with work with our clients, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which includes retaining records of our dealings and transactions and where applicable, use such records for the purposes of:

  • assess suitability, availability and contact you regarding potential opportunities

  • establishing compliance with contractual obligations with Clients or suppliers

  • making a decision about your recruitment or appointment

  • making decisions about terms and conditions, pay and other benefits

  • checking you are legally entitled to work in the location of a project

  • assessing qualifications and suitability for a particular job or task

  • complying with health and safety obligations

  • preventing fraud

  • in order to fulfil equal opportunity monitoring or reporting obligations

  • internal record keeping

  • addressing any query or dispute that may arise including establishing, exercising or defending any legal claims

  • protecting our reputation

  • maintaining a back up of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach

  • evaluating quality and compliance including compliance with this Privacy Notice

  • determining staff training and system requirements

This means that for our commercial viability and to pursue these legitimate interests, we may continue to process your personal data for as long as we consider necessary for these purposes.

Sensitive Personal Data (SPD)

Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our consideration of your suitability for a job role. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health.

Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that data for the purposes of our relationship with you or for the provision of our Services. This will be for one or more of the following reasons:

  • You have explicitly consented to the processing

  • For the purpose of our assessment of your suitability for job roles or working capacity

  • For the purpose of meeting the contractual obligations of our clients

  • Where processing is necessary for the purpose of obligations or rights under employment, social security or social protection law

  • To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defence of any legal claims

Retaining your data

In most circumstances your data will not be retained for more than 6 years from the last point at which you were last deployed or otherwise engaged and it is our policy to only store your personal data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests. However, we may retain data for longer than a 6 year period where we have a legal or contractual obligation to do so, or we form the view that there is otherwise a continued basis to do so, for example where your personal information identifies specialist skill sets which may remain in demand, or we are subject to a legal obligation which applies for a longer period.

If however you believe that we should delete your personal data at an earlier date, please inform us in writing of your reasons.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

It is our policy to ensure, in so far as is reasonably practicable, that our systems and records are secure and not accessible to unauthorised third parties in line with contemporary practice.

Provision of data to Third Parties

We shall not share your personal information unless we are entitled to do so. The categories of persons with whom we may share your personal information include:

  • Individuals, hirers and other third parties necessary for the provision of our Services

  • Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us

  • Parties who process data on our behalf , which may include

    • Employment service providers

    • Project related travel and logistics service providers

    • IT support

    • Storage service providers including cloud

    • Background screening providers

    • Legal and professional advisers

    • Insurers

Data Subject Access

A data subject may make a subject access request (SAR) at any time to find out more about the personal data which Claymore Manning holds about them. Claymore Manning is normally required to respond to SAR’s within one month of receipt.

All subject access requests can be made by contacting the operations office on +44 (0)141 214 0071 or by email team@claymoremanning.com

Claymore Manning does not charge a fee for the handling of SARs.