The following is a broad description of the way Cruinn Associates as a registered data controller (ICO Reg. No. ZA158102) processes personal information. To understand how your own personal information is processed you may need to refer to any personal communications you have received, check any privacy notices the organisation has provided or contact the organisation to ask about your personal circumstances.

Reasons/purposes for processing information
We process personal information to enable us to provide consultancy and advisory
services, to promote our services, to maintain our own accounts and records and to
support and manage our employees, associates or partners.

Type/classes of information processed
We process information relating to the above reasons/purposes. This information
may include:
􀂇 personal details
􀂇 family, lifestyle and social circumstances
􀂇 business activities of the person whose personal information we are processing
􀂇 goods and services provided
􀂇 financial details
􀂇 education details
􀂇 employment details

We also process sensitive classes of information that may include:
􀂇 physical or mental health details
􀂇 offences and alleged offences
􀂇 racial or ethnic origin
􀂇 religious or other beliefs of a similar nature


Who the information is processed about
We process personal information about our customers, clients and employees,
complainants and enquirers, suppliers, advisers and other professional experts.


Who the information may be shared with
We sometimes need to share the personal information we process with the
individual themself and also with other organisations. Where this is necessary we
are required to comply with all aspects of the Data Protection Act (DPA). What
follows is a description of the types of organisations we may need to share some of
the personal information we process with for one or more reasons.


Where necessary or required we share information with:
􀂇 business associates and other professional advisers
􀂇 family, associates and representatives of person whose personal data we are processing
􀂇 financial organisations
􀂇 current, past or prospective employers
􀂇 educators and examining bodies
􀂇 suppliers and services providers
􀂇 traders in personal data


Trading and sharing personal information
Personal information is traded and shared as a primary business function. For this
reason the information processed may include name, contact details, family details,
financial details, employment details, and goods and services. This information may
be about customers and clients. The information may be traded or shared with
business associates and professional advisers, agents, service providers, customers
and clients, and traders in personal data.

Undertaking research
Personal information is also processed in order to undertake research. For this
reason the information processed may include name, contact details, family details,
lifestyle and social circumstances, financial details, good and services. The sensitive
types of information may include physical or mental health details, racial or ethnic
origin and religious or other beliefs. This information is about survey respondents.
Where necessary or required this information may be shared with customers and
clients, agents, service providers, survey and research organisations.

Consulting and advisory services
Information is processed for consultancy and advisory services that are offered. For
this reason the information processed may include name, contact details, family
details, financial details, and the goods and services provided. This information may
be about customers and clients. Where necessary this information is shared with
the data subject themselves, business associates and other professional advisers,
current, past or prospective employers and service providers.

Transfers
It may sometimes be necessary to transfer personal information overseas. When
this is needed information is only shared within the European Economic Area (EEA).
Any transfers made will be in full compliance with all aspects of the Data Protection Act.

Data Controller
Cruinn Associates
Titanic Suites
55-59 Adelaide Street
Belfast BT2 8FE
Email: contactus@cruinn.co.uk