Privacy Notice (also known as “Fair Processing Notice”)
Data Controller
Create Solutions Limited
Holmrook Hall Cottage, Holmrook, Cumbria, CA19 1UJ
Tel: 0161 870 6637
Email: info@createsolutions.co.uk
How will we use the information you give us?
We will use your information to provide compliance consultancy to your firm, or a firm acting on your behalf who use our services. We will also use your information to provide training services to your firm.
- If you are a director, shareholder, approved person, senior manager, employee, or potential employee of a firm we provide services to, or a customer of such a firm, it will be on the basis that processing your data is necessary for the performance of a contract for compliance or training.
We may need to obtain special category data from or about you, such as health or criminal conviction information.
- If you are a director, shareholder, approved person, senior manager, employee or potential employee of a firm we provide services to, it will be on the basis that processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment.
- If you are a customer of such a firm, it will be on the basis that processing your data is necessary for reasons of substantial public interest. We do so on the basis that it is in the public interest for insurance to be available to you, and to fight crime.
- It will be on the basis of consent for training courses.
We also have a legitimate interest in using your data for business operations to ensure we can continue to provide our services. We may use your data to send you marketing information. This will either be on the basis that we have a legitimate interest to do so, or where you have consented. You will be able to withdraw your consent or unsubscribe easily at any time from these communications.
We also need to use your information to process payments or collect debits.
| Purpose of Processing | Types of Personal Data | Lawful Basis |
|---|---|---|
| Compliance & Training Services | Personal details, Identification documents, Financial details, Employment & Directorships, Audio & Video | Performance of a Contract |
| Compliance Services | Special Categories including Health and Criminal Convictions | Employment |
| Training Services | Special Categories including Health | Consent |
| Compliance Services (Customers) | Personal details, Insurance details | Performance of a Contract |
| Compliance Services (Customers) | Special Categories including Health and Criminal Convictions | Substantial Public Interest |
| Business operations and administration | Names, Addresses, Risk Information | Legitimate Interest |
| Business operations and administration | Special Categories including Health and Criminal Convictions | Substantial Public Interest |
| Marketing | Names, Contact Details, Marketing Preferences | Recognised Legitimate Interest or Consent |
| Payments, debts, Premium Finance | Name, Address, Bank Details & Credit/Debit Card, Credit History |
Who will we share your data with?
To provide Compliance Services, these firms will be your employer, your insurance broker or claims management company, the FOS, the FCA, HMRC, other regulators, or other compliance companies.
To provide Training Services, these firms will be your employer, other compliance and training providers, and venues.
To help run our operations including marketing, they include firms that provide information technology support to us. For payments, this includes accountancy providers and payment services providers.
We may record online training sessions that include video and audio of your likeness and voice. You will have the choice to opt out of such recordings prior to a record being made. Such recordings may be shared with our clients including insurance brokers and claims management companies.
Who will we share your data with?
To provide Compliance Services, these firms will be your employer, your insurance broker or claims management company, the FOS, the FCA, HMRC, other regulators, or other compliance companies.
To provide Training Services, these firms will be your employer, other compliance and training providers, and venues.
To help run our operations including marketing, they include firms that provide information technology support to us. For payments, this includes accountancy providers and payment services providers.
We may record online training sessions that include video and audio of your likeness and voice. You will have the choice to opt out of such recordings prior to a record being made. Such recordings may be shared with our clients including insurance brokers and claims management companies.
Do we send your information outside the UK, EEA or EU?
If we have to transfer information to a third country outside the UK/EEA/EU, we will only do so if a similar level of protection applies. We have an International Data Transfer Agreement with ClassMarker Pty Ltd in Australia.
How long will we keep your information?
We will only collect what is necessary and will only keep it for as long as we are required to do in line with our data retention policy.
| Type of Data | Reason for Retention | Retention Period |
|---|---|---|
| All | Future services | 7 years from end of contract |
What are my legal rights?
- You have the right to complain to the Information Commissioner at ico.org.uk or by calling 0303 123 11132.
- You can obtain a copy of your personal information from us without charge by contacting us at the address above. This may include the right to transfer information to other providers.
- You have the right to ask us to correct information.
- You have the right to ask us to delete your information or stop using it, unless it is necessary for us to retain it as set out in our retention policy.
- You may have the right to be informed about, respond to, contest, and request human intervention if decisions about you are made solely by a computer.
This Privacy Notice was last updated on 07/07/25 (v4)