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What Does Clements Do When We Receive Your Request?

Verify your identity. If we have cause to doubt your identity, we will ask for information to verify it. For example, we may ask you for a piece of information held in your records that you might reasonably be expected to know. We cannot disclose Personal Information to anyone other than the individual in question.

Collate information. We will gather any manual or electronically held information and identify any information provided by a third party or which identifies a third party. Third parties – before sharing information that relates to third parties, we will, where possible, anonymize or edit information that might affect another party’s privacy. We may also summarize information rather than provide a copy of the whole document.

Providing a Response

Once any queries around the information requested have been resolved, copies of the information will be sent to you electronically wherever possible or, if this is not technically possible, by post.

Will We Charge a Fee?

We will normally comply with your request at no cost. However, If your data Subject Access Requests are excessive or manifestly unfounded we will charge £10 to cover the administrative costs involved in dealing with your request. In extreme circumstances, we reserve the right to refuse your requests.

Circumstances in Which Your Request May Be Refused

We may refuse to deal with your Subject Access Request if it is manifestly unfounded or excessive, or if it is repetitive. Where it is our decision to refuse your request, we will contact you without undue delay, and at the latest within one month of receipt, to inform you of this and to provide an explanation. You will be informed of your right to complain to the Information Commissioner and to a judicial remedy.

We may also refuse to deal with your request, or part of it, because of the types of information requested. For example, information which is subject to legal privilege or relates to management planning is not required to be disclosed. Where this is the case, we will inform you that your request cannot be complied with and an explanation of the reason will be provided.

What is the Timeframe for Responding to a SAR?

We have one month (30 calendar days) starting from when we received the information necessary to identify you, to identify the information you requested, and provide you with the information (or explain why we were unable to provide the information). Wherever possible, we will aim to complete the request in advance of the deadline.