Last updated: August 2026

1. Who we are

Clarity Umbrella Ltd (“Clarity”, “we”, “us” or “our”) is committed to protecting your personal data and respecting your privacy.

Clarity Umbrella Ltd is registered in England and Wales under company number 12210720.

Our contact details are:

Clarity Umbrella Ltd
2 Appletree Barns
Folly Lane
Copdock
Ipswich
Suffolk
IP8 3JQ

Email: info@clarityumbrella.co.uk
Telephone: 01473 845 835

For queries concerning the use of your personal data or your data protection rights, please contact us using the details above.

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 and privacy legislation, as amended from time to time, including by the Data (Use and Access) Act 2025.

2. Personal data we collect

The personal data we collect and process depends upon your relationship with us.

Where applicable, this may include:

  • your name, address and contact details;
  • date of birth;
  • National Insurance number;
  • identification and right-to-work information;
  • bank account and payment details;
  • tax information, including tax codes, P45 and P60 information;
  • employment and contractual information;
  • recruitment agency and client assignment information;
  • timesheets and records of hours worked;
  • payroll, salary, deductions, expenses and holiday-pay information;
  • pension information;
  • correspondence and records of communications with you or concerning your employment or assignment;
  • information provided by recruitment agencies, end clients and other organisations involved in your engagement;
  • records necessary for compliance with our legal, regulatory and contractual obligations;
  • records relating to queries, complaints, disputes or legal proceedings;
  • information you provide through our website, portal or registration processes;
  • IP addresses, website usage information and other technical information where applicable; and
  • other personal data which it is reasonably necessary for us to process in connection with our relationship with you.

We may also process special category personal data where necessary and where permitted by law.

3. Where we obtain your personal data

We obtain much of the personal data we process directly from you.

We may also obtain personal data from other sources where appropriate, including:

  • recruitment agencies and employment businesses;
  • end clients to whom you are assigned;
  • HM Revenue & Customs;
  • pension providers;
  • payroll and employment service providers;
  • professional advisers;
  • public authorities, regulators, courts and tribunals; and
  • other organisations where there is a lawful basis for obtaining the information.

Information may also be generated by Clarity in the course of administering your employment, payroll, assignments and our communications with you.

Where required by data protection law, we will provide appropriate information about the source of personal data obtained from third parties.

4. Why we use your personal data

We process personal data where necessary for purposes including:

  • assessing and setting up employment or engagement arrangements;
  • entering into and administering contracts of employment;
  • administering assignments arranged through recruitment agencies or end clients;
  • verifying identity and the right to work in the United Kingdom;
  • processing timesheets and calculating and making payments;
  • operating PAYE payroll and making required deductions;
  • administering holiday pay and other employment entitlements;
  • administering workplace pension obligations;
  • issuing payslips, P45s, P60s and other employment or tax documentation;
  • communicating with employees, workers, recruitment agencies, end clients and other relevant organisations;
  • maintaining employment, payroll and business records;
  • responding to queries, complaints and data protection requests;
  • establishing, exercising or defending legal claims;
  • complying with our legal, tax, employment, regulatory and reporting obligations;
  • preventing and detecting fraud or misuse of our services;
  • maintaining the security and operation of our systems; and
  • administering and improving our website and services.

5. Our lawful bases for processing

The lawful basis we rely upon depends upon the particular processing activity.

We may process personal data on the following bases:

Contract
Processing may be necessary to enter into or perform a contract with you, including administering your employment and making payments.

Legal obligation
Processing may be necessary for us to comply with legal obligations, including those relating to PAYE, tax, National Insurance, pensions, employment law and right-to-work requirements.

Legitimate interests
Processing may be necessary for our legitimate business interests or those of a third party, provided those interests are not overridden by your data protection rights. This may include operating and administering our business, communicating with recruitment agencies and end clients, maintaining appropriate records, protecting our systems and establishing, exercising or defending legal claims.

Consent
Where consent is the appropriate lawful basis, we will ask for your consent. Where processing is based upon consent, you may withdraw that consent at any time.

Other lawful bases may apply where permitted or required by law.

Where we process special category personal data, we will only do so where an appropriate lawful basis and condition under applicable data protection legislation applies.

6. Who we share personal data with

Where necessary and lawful, we may share personal data with organisations including:

  • recruitment agencies and employment businesses;
  • end clients;
  • HM Revenue & Customs and other government bodies;
  • pension providers;
  • banks and payment service providers;
  • payroll, accounting, HR, IT, cloud storage and software service providers;
  • insurers and benefits providers, where applicable;
  • professional advisers, including accountants, auditors and legal advisers;
  • courts, tribunals, regulators and public authorities; and
  • other service providers who process personal data on our behalf.

Our service providers include systems and services used for payroll, customer relationship management, email, document storage, pension administration and banking.

We only disclose personal data where there is an appropriate lawful basis for doing so and only to the extent reasonably necessary for the relevant purpose.

Where another organisation processes personal data on our behalf, we put in place appropriate contractual and security arrangements as required by data protection law.

Some recipients, such as HM Revenue & Customs and pension providers, may process personal data as controllers in their own right for their own statutory or regulatory purposes.

7. International transfers

Some of the third-party service providers we use may process, store or access personal data outside the United Kingdom.

Where personal data is transferred outside the United Kingdom, we take steps to ensure that the transfer is made in accordance with applicable data protection law.

Depending upon the circumstances, this may include transferring personal data to a country covered by UK adequacy regulations, putting in place appropriate contractual safeguards, or relying upon another lawful transfer mechanism.

Some organisations to which we provide personal data, such as pension providers, may also process personal data outside the United Kingdom in accordance with their own legal and data protection obligations.

Further information about the safeguards applicable to international transfers of your personal data is available on request.

8. How long we keep personal data

We retain personal data only for as long as is reasonably necessary for the purposes for which it was collected or subsequently processed, and to meet applicable legal, tax, employment, regulatory and accounting requirements.

Different categories of personal data are retained for different periods.

In determining the appropriate retention period, we take into account:

  • the purpose for which the information is held;
  • applicable legal and regulatory requirements;
  • tax and accounting requirements;
  • the nature and sensitivity of the information;
  • applicable limitation periods; and
  • whether the information may reasonably be required in connection with a complaint, dispute, investigation or legal proceedings.

Where information is relevant to an actual or reasonably anticipated legal claim, complaint, regulatory investigation or other dispute, we may retain the relevant information for longer where this is necessary and lawful.

Further information about the retention period or criteria applicable to particular categories of personal data is available on request.

9. How we protect personal data

We take appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

These measures include appropriate administrative, technical and physical safeguards having regard to the nature of the personal data and the risks associated with its processing.

Access to personal data is restricted to employees, contractors and service providers who require access for legitimate purposes.

10. Your data protection rights

Depending upon the circumstances and the lawful basis for processing, you may have the right to:

  • request access to your personal data;
  • request correction of inaccurate or incomplete personal data;
  • request erasure of your personal data;
  • request restriction of processing;
  • object to the processing of your personal data;
  • request the transfer of certain personal data to you or another organisation;
  • withdraw consent where we rely upon consent as the lawful basis for processing; and
  • raise concerns about how we process your personal data.

These rights are subject to conditions and exemptions contained in data protection legislation and do not apply in all circumstances.

If you wish to exercise your data protection rights, please contact:

info@clarityumbrella.co.uk

We may need to request information reasonably necessary to confirm your identity before acting upon a request.

11. Subject Access Requests

You have the right to request access to personal data which we process about you and to receive the supplementary information required by applicable data protection legislation.

A Subject Access Request may be made by contacting:

info@clarityumbrella.co.uk

You do not need to use any particular wording or form to make a Subject Access Request.

We will respond to Subject Access Requests in accordance with the timescales and requirements of applicable data protection legislation.

There is normally no charge for making a Subject Access Request. However, data protection law permits a reasonable fee to be charged, or a request to be refused, in certain limited circumstances.

12. Automated decision-making

Clarity Umbrella Ltd does not make decisions about individuals based solely on automated processing, including profiling, which produce legal effects or similarly significant effects.

13. Cookies and website information

Our website may use cookies and similar technologies to operate the website, remember preferences, understand how visitors use the website and improve our services.

Some cookies are necessary for the operation of the website. Where required by law, non-essential cookies will only be used with your consent.

Further information about the cookies and analytics technologies used on our website and how you can manage your preferences is available through our cookie settings or cookie notice.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our processing activities, services, suppliers or applicable law.

The latest version will be published on our website and the date on which it was last updated will be shown at the top of this policy.

15. Complaints

If you have concerns about how we process your personal data, please contact us in the first instance at:

info@clarityumbrella.co.uk

We will investigate data protection complaints and respond in accordance with applicable data protection legislation.

You also have the right to complain to the Information Commissioner’s Office (“ICO”), the UK’s independent data protection regulator.

Further information about your rights and how to make a complaint is available from the Information Commissioner’s Office at www.ico.org.uk.