Question 1

What lawful basis under Article 6 of the GDPR does Clarify use to process data on behalf of customers?

Accepted Answer

Clarify has identified Legitimate Interest as the lawful basis for processing prospect data.

Question 2

Has Clarify completed a Legitimate Interest Assessment (LIA)?

Accepted Answer

Yes. Clarify has completed a Legitimate Interest Assessment. For more detail, contact data@clarifyb2b.com.

Question 3

Is Clarify a Data Controller or Data Processor?

Accepted Answer

Clarify acts as the Data Processor of customer prospects on behalf of our customers, who are the Data Controllers. Clarify is the Data Controller for its own employees and customer employees.

Question 4

What types of personal data does Clarify process on behalf of customers?

Accepted Answer

Clarify processes names, job titles, contact details (telephone numbers, email addresses, and physical work addresses), and other business information relevant to delivering our services.

Question 5

What special categories of data does Clarify process?

Accepted Answer

Clarify does not process any special categories of data on behalf of customers. Clarify may process special categories of data relating to its own employees.

Question 6

Where does Clarify store customer prospect data?

Accepted Answer

All prospect data is stored within Salesforce.com. It is password protected and accessible only to those directly involved in the programme. Some data may be shared via email in Excel or Word documents, limited and properly managed, and password protected where appropriate.

Question 7

How long does Clarify keep customer prospect data?

Accepted Answer

Clarify retains prospect data for the length of the contract plus one year to evidence delivery of service. At the end of a programme, data is archived from Salesforce.com and stored securely.

Question 8

Has Clarify updated its privacy notice in line with GDPR?

Accepted Answer

Yes. The Clarify privacy notice has been updated in line with GDPR requirements and is available at https://clarifyb2b.com/privacy-policy/.

Question 9

Does Clarify work with third-party suppliers who may process personal data?

Accepted Answer

Yes. Clarify works with third-party suppliers including Salesforce.com (data storage and processing), 4C (Salesforce instance management), Telanova (outsourced IT), and Conga (contract management). Robust policies and processes are in place to protect personal data.

Supplier	How we work with them	Supplier Privacy Notice
Salesforce.com	Storage and processing of prospect data	here
4C	Manage our Salesforce Instance – policies & Processes in place to protect personal data	here
Telanova	Outsourced IT, policies & Processes in place to protect personal data	here
Conga	Contract management	here

GDPR FAQs

What lawful basis under Article 6 of the GDPR does Clarify use to Process data on behalf of customers +

Have Clarify completed a Legitimate Interest Assessment (LIA) +

Is Clarify a Data Controller or Data Processer +

What types of personal data does Clarify process on behalf of customers +

What special categories of data does Clarify process +

Where does Clarify store customer prospect data? +

How long does Clarify keep customer prospect data? +

Have you updated your privacy notice in line with GDPR +

Does Clarify work with third party suppliers who may process personal data +