8 Bearl Farm, Stocksfield, Northumberland, NE43 7AL

Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the Data Protection Act 2018 and the UK General Data Protection Regulation, (UK GDPR) which applies in the United Kingdom, and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Clifford James Consultants Limited, a member of the Clifford James group of companies (Clifford James Group)
Our data protection officer	Mr Stewart Fairhurst stewart.fairhurst@clifford-james.com
Personal information	Any information relating to an identified or identifiable individual
Special category personal information	Personal information relating to Racial or ethnic origin, Political opinions, Religious or philosophical beliefs, Trade union membership, Genetic data, Biometric data, Health data, Sex life or sexual orientation.

Personal information we collect about you

We may collect and use the following personal information about you:

your name and contact information, including email address and telephone number and company details
Information to enable us to check and verify your identity, e.g. your date of birth
your gender information, if you choose to give this to us
location data, if you choose to give this to us
your billing information, transaction and payment card information
your personal or professional interests
your professional online presence, e.g. LinkedIn profile
information from accounts you link to us, e.g. Facebook
information to enable us to undertake credit or other financial checks on you
Information about how you use our website, IT, communication and other systems
your responses to surveys, competitions and promotions

This personal information is required to provide products and/or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and/or services to you.

How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

to comply with our legal and regulatory obligations;
for the performance of our contract with you or to take steps at your request before entering into a contract;
for our legitimate business interests or those of a third party; or
where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide products and/or services to you	For the performance of our contract with you or to take steps at your request before entering into a contract, to decide if we can offer you insurance and if so on what terms, to administer any policy of insurance, to handle any claims and manage any renewals
To prevent and detect fraud against you or us	For our legitimate interests or those of a third party, i.e. to detect, prevent or minimise fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. rules issued by the Financial conduct Authority	To comply with our legal and regulatory obligations and to manage claims
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information. To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you. To comply with our legal and regulatory obligations
Updating customer records	For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of selected third parties to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
Credit reference checks via external credit reference agencies	For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services
External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations

Special category personal data will only be processed where a condition under Article 9 UK GDPR and Schedule 1 of the Data Protection Act 2018 applies. This may include where processing is necessary for the establishment, exercise or defence of legal claims, for insurance underwriting or claims handling purposes, to comply with employment law obligations, or where explicit consent has been obtained where required.

Promotional communications

We may use your personal information to send you updates about our legal services, insurance products, and related services by email, text message, telephone, or post.

Electronic Marketing (Email and Text)

Where we send marketing communications by electronic means (such as email or text message), we will do so in accordance with the Privacy and Electronic Communications Regulations (PECR).

We will send electronic marketing communications to individuals only:

Where you have provided your consent; or
Where you are an existing customer and we are marketing similar services, and you have been given a clear opportunity to opt out at the time your details were collected and in every subsequent communication (known as the “soft opt-in”).

You may withdraw your consent or opt out of marketing communications at any time.

Business-to-Business Communications

Where marketing is sent to corporate subscribers (for example, generic business email addresses), we may rely on our legitimate interests, provided such communications are lawful and proportionate.

Postal Marketing and Telephone Calls

We may send marketing communications by post where we have a legitimate interest to promote our services, unless you have asked us not to do so.

We will make live marketing telephone calls in accordance with applicable regulations and will not contact individuals who have registered with the Telephone Preference Service (TPS) unless we have consent to do so.

Your Right to Opt Out

You can opt out of receiving marketing communications at any time by:

Contacting us at stewart.fairhurst@clifford-james.com
Using the “unsubscribe” link in emails
Replying “STOP” to text messages
Informing us during any telephone call

We will process opt-out requests promptly.

We will never sell your personal information to third parties for marketing purposes.

Who we share your personal information with

We routinely share personal information with:

companies within the Clifford James Limited group
third parties we use to help deliver our products and/or services to you, e.g. payment service providers;
other third parties we use to help us run our business, e.g. website hosts;
third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
credit reference agencies;
our insurers and brokers;
our banks;
our professional advisers.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO or Investors in People accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Where your personal information is held

Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the UK and EEA’.

How long your personal information will be kept

We will keep your personal information while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:

to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly;
to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

Transferring your personal information out of the UK and EEA

To deliver our legal and insurance-related services, it may sometimes be necessary for us to transfer your personal information outside the United Kingdom and/or the European Economic Area (EEA). For example:

Where you or a party to a legal matter is located outside the UK/EEA;
Where insurers, brokers, reinsurers, or service providers are located overseas;
Where we use secure cloud-based IT or case management systems that store or process data outside the UK;
Where there is an international dimension to the services we are providing.

Such transfers are subject to specific protections under UK data protection law.

How We Protect Your Information

Where personal information is transferred outside the UK, we ensure that one of the following safeguards applies:

Adequacy Regulations

We may transfer personal data to countries that have been formally recognised by the UK Government as providing an adequate level of data protection.

Appropriate Safeguards

Where there is no adequacy decision, we will implement appropriate safeguards, which may include:

The UK International Data Transfer Agreement (IDTA);
The UK Addendum to the EU Standard Contractual Clauses (SCCs);
Binding Corporate Rules (where applicable);
Other lawful transfer mechanisms permitted under UK GDPR.

Where required, we conduct a Transfer Risk Assessment (TRA) to assess whether the destination country’s laws may impact the effectiveness of those safeguards.

Legal Claims and Insurance Context

In certain circumstances, personal data may be transferred outside the UK where this is necessary for the establishment, exercise, or defence of legal claims, or in connection with insurance underwriting, claims handling, or reinsurance arrangements involving overseas entities.

Exceptional Circumstances

In limited cases, we may rely on a specific statutory exemption under Article 49 UK GDPR, such as where:

The transfer is necessary for the performance of a contract with you;
The transfer is necessary for important reasons of public interest;
You have provided explicit consent to the transfer after being informed of the potential risks.

If you would like more information about the safeguards used for international transfers, you may contact us using the details provided below.

Your rights

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal information (the right of access)
Rectification	The right to require us to correct any mistakes in your personal information
To be forgotten	The right to require us to delete your personal information—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Data portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: —at any time to your personal information being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

complete a data subject request form—available from the ICO; or
email, call or write to our Data Protection Officer—see below: ‘How to contact us’; and
let us have enough information to identify you (e.g. your full name, address and customer or matter reference number);
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
let us know what right you want to exercise and the information to which your request relates.

Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was published on 01 August 2020 and last updated on 16 February 2026.

We may change this privacy notice from time to time—when we do we will inform you via our website or other means of contact such as email.

How to contact us

Please contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our Data Protection Officer’s contact details

Stewart Fairhurst

Unit 8 Bearl Farm, Stocksfield, Northumberland, NE43 7AL

stewart.fairhurst@clifford-james.com

0344 880 5088