Version 2026-11-02.1
Privacy notice
Clarity-OO Ltd — Clarity CDM Academy privacy notice — version 2026-11-02.1
This notice explains what personal information Clarity-OO Ltd ("Clarity", "we", "us") holds about people who buy or take a course at Clarity CDM Academy (academy.cdm2015.co.uk), why we hold it, who else handles it, and your rights. It forms part of our course terms.
Who we are. Clarity-OO Ltd, registered in England and Wales, company number 17484245. Registered office: 2b Henry Street, Blackburn, BB1 4JJ, United Kingdom. Contact: support@clarity-oo.com. Clarity-OO Ltd is registered with the Information Commissioner's Office (ICO), registration number ZC267390.
We are the controller of everything described here: we decide what is collected and why. (Our Clarity account products have their own privacy notice; this one is about the Academy only.)
1. Where we get information
- From you, when you buy a course, set your password, sign in, take a course, sit an exam, write a note, change your account, or contact us.
- From the business that bought your place, if your employer or client paid: your name and email address, given at checkout. The first email we send you links to this notice, and you accept the course terms and see this notice when you set your password.
- From Stripe, when a payment is made: that it succeeded, the billing name and address, and any company name and VAT number given, so we can issue a VAT invoice.
- Automatically, when you use the Academy: your IP address, your browser, the pages you requested, and how long a lesson is open on your screen.
To take a course we need the learner's name, email address and password, and the buyer's billing address. Without them we cannot sell or run a course.
2. What we hold, why, and on what basis
| Information | Why | Legal basis |
|---|---|---|
| Learner's name and email address | To run your account, sign you in, email you about your course, and print your name on your certificate | Contract |
| Password (stored only as a one-way hash), and the one-time sign-in and reset links we email you (stored hashed, used once) | To make sure it is you signing in | Contract, and legitimate interests in keeping accounts secure |
| Age confirmation: that the buyer confirmed the learner is 18 or over, and when | Because we choose to sell only to adults | Legitimate interests (we choose to sell only to adults) |
| Purchase and invoice records: course bought, order reference, date, price, VAT, billing name and address, company name and VAT number if given, Stripe references, and the version of our terms you agreed to. We never see or store card details: Stripe holds them | Billing, VAT invoices, and proving the contract | Contract, and legal obligation to keep accounting and VAT records |
| Whether you bought as a consumer or a business, when you started the course, and whether you pressed "Start the course now" (the date, time and the exact words you were shown) | To apply the right rules on cancellation and refunds, and to show what was agreed | Contract, and legitimate interests in showing that we met the consumer-cancellation rules and in defending any claim (the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, regulations 16 and 37, set the rules we must be able to show we followed) |
| Your acceptance of the course terms when you set your password, if a business bought your place: the date and the terms version | To show that you agreed to the terms that apply to you as the learner | Contract |
| Adjustment requests (section 4A of the terms), which may include information about your health or a disability | To agree and apply your adjustment, for example extra exam time | Explicit consent (UK GDPR Article 9(2)(a)) and our duties under the Equality Act 2010. Kept while you have access, then deleted |
| Your progress: which modules and checks you have passed, your check answers, and where you left off | To run the course ladder and save your place | Contract |
| Your exam attempts: when you started and submitted, every answer you gave (including written answers and the practical piece), the marks, pass or fail, and the written feedback | To mark your exam, decide whether you have passed, issue your certificate, show you your result, and deal with any review or dispute | Contract. Human review of an automated result: legal obligation (UK GDPR Article 22) |
| Study time: how many seconds each lesson is open on your screen while you are signed in | To show you your own study time, and to see where our time estimates for a lesson are wrong so we can improve the course | Legitimate interests |
| Your notes in the Academy notebook | So you can keep and search them | Contract |
| Certificates: the award, your name, course, CPD hours, issue and valid-until dates, a unique code and fingerprint, and whether it has been revoked or replaced | To issue your certificate, let anyone you give the code to verify it on our public page, and remind you before it expires | Contract, and legitimate interests (yours, in a certificate others can check; ours, in the integrity of our certificates) |
| Marketing choice: whether you ticked "Don't send me tips and offers" when you bought, or ticked the opt-in box when you set your password, when, and whether you later unsubscribed | To know whether we may email you news and offers, and to make sure we stop when you ask | Legitimate interests (buyers) or consent (learners whose place a business bought), within the rules in section 9 |
| Emails we send you (set your password, reset, receipt, new course, the "you have started" confirmation, certificate, expiry reminder): the kind, subject, date and whether it was delivered, with your address stored only as a scrambled hash | To run the service and fix delivery problems | Contract, and legitimate interests |
| Failed sign-ins (email address and IP address) | Stopping password guessing | Legitimate interests |
| Refused automated form submissions and the stamps our forms use to tell people from bots (nothing that identifies you) | Keeping out spam and bots | Legitimate interests |
| Web server logs (IP address, browser, pages requested) | Security and fixing faults | Legitimate interests |
| Support messages sent through our support form or by email: what you write, your name and email address, and the course or order it is about | Answering you | Legitimate interests |
| Your account data download, if you ask for it | To give you a copy of your information | Legal obligation |
Where we rely on legitimate interests, we have weighed them against your interests and rights. You can ask us about that balance.
We do not sell personal information, use it for advertising, or profile you. One decision about you is made by automated means: your exam mark (section 3), and you can ask a person to review it.
3. AI marking and your right to a human review
Some exam questions have no fixed answer: written answers, "true or false - give your reason" answers, and the practical piece of a Full Course. These are marked automatically by an artificial-intelligence (AI) service, Anthropic, which we use as our processor. This is how it works:
- What is sent to Anthropic: the question, our marking rubric, and the text you typed as your answer. Nothing else: not your name, email address, account details or other answers. The exchange is encrypted.
- What you should not type: please do not put your own or anyone else's personal details (names, addresses, health or similar) into an exam answer. The questions never ask for them. If you do, they will be sent for marking like the rest of your text.
- What comes back: a score against the rubric and a short written feedback note, which we store with your attempt and show you with your result. The feedback is generated by the AI from your text and our rubric.
- What Anthropic does with it: marks it and returns the result. Under our agreement with Anthropic it does not use your text to train its models. Anthropic may keep the text for a short time for safety monitoring under its commercial terms. Anthropic processes in the United States; section 6 explains the safeguard.
- Pass or fail is decided automatically from your total mark, so your result is not held up waiting for a tutor. A tutor can see every mark. (UK GDPR Article 22, as amended by the Data (Use and Access) Act 2025.)
- Your right to a human review. You can ask a person to look at any mark by emailing support@clarity-oo.com with your attempt reference and what you think was marked wrongly. We ask you to do this within 30 days of your result so the attempt is fresh; a later request is still considered, but the review may be limited to what we still hold. A tutor reads your answers against the rubric, can change the mark, and tells you the outcome within 14 days. You can also simply retake the exam, free, as often as you like while you have access.
Marking of multiple-choice, numeric, sequence, drag-and-drop and hotspot questions is done by our own software against fixed answers and nothing is sent to anyone.
4. Your certificate on our public page
Anyone who has your certificate's code can enter it at academy.cdm2015.co.uk/verify and see: the award, your name, the course, CPD hours, the issue and valid-until dates, and whether it is Current, Expired, Revoked or Withdrawn. The code is long and random, so a page cannot be found by guessing, and these pages are marked so that search engines do not index them. You choose who you give your code to. If you ask us to erase your data (section 10), the page shows the certificate as Withdrawn, with no name.
5. Cookies and your browser's storage
- The Academy sets one cookie, to keep you signed in. It is strictly necessary, so we do not ask for consent. It is deleted when you sign out, and it expires on its own if you do not. (Privacy and Electronic Communications (EC Directive) Regulations 2003, regulation 6(4).)
- Your browser's own storage (on your device, never read by our server) keeps a few things the Academy needs to work as you expect: a copy of your exam answers and the exam clock while you sit an exam (so a refresh does not lose them; cleared when the exam is submitted), your place in each lesson and whether you read it as one page, the lesson study timer when the server's figure is not to hand, whether the notes panel is open, your answers to a lesson's practice questions, and whether you have dismissed the "install as an app" card and its one-time tip. Our cookies page lists each one. All of them are strictly necessary for what you are doing.
- If you install the Academy as an app, your browser keeps a copy of the app's own files (styles, scripts, the offline page) so it opens quickly. It holds nothing about you.
- There are no analytics or advertising cookies on the Academy, and nothing tracks you across other websites. If we ever add analytics, we will ask your consent first with a banner, and this notice will change.
- Stripe's checkout page (checkout.stripe.com), where you pay, is Stripe's own site and sets Stripe's own cookies under Stripe's privacy notice (stripe.com/privacy).
Our cookies page says the same in short.
6. Who else handles it
| Organisation | What it does | Its role | Where |
|---|---|---|---|
| Heart Internet Ltd | Hosts our server | Processor | United Kingdom |
| Amazon Web Services (Simple Email Service) | Sends the Academy's emails: set your password, receipts, certificates, reminders, and our news and offers | Processor | United Kingdom (London region, our choice). AWS's UK GDPR Addendum applies to any transfer |
| Stripe | Takes payments, issues the VAT invoice, and emails payment receipts | Processor for our payments. Independent controller for its own purposes, such as fraud prevention and its legal obligations. See stripe.com/privacy | UK, EU and US |
| Anthropic | Marks written answers and the practical piece (section 3) | Processor, under Anthropic's commercial terms and data processing addendum | United States (see section 7) |
| Microsoft (Microsoft 365) | Our support mailbox, and storage (SharePoint) for a daily encrypted copy of our database | Processor | United Kingdom (Microsoft's committed data location for our account) |
| Our Clarity account system (ours, at account.clarity-oo.com) | Stores the messages sent through the Academy's support form so we can answer them | Same controller (Clarity-OO Ltd), a different system of ours | United Kingdom |
Each processor works under a contract that requires it to protect the information. We do not share your information with anyone else, except where the law requires, or with a business that takes over the Academy (our terms say we will tell you).
Copies on our own equipment. A daily copy of our database is kept on a company computer in the UK, on a drive with its own hardware encryption and password, and synced to our Microsoft 365 storage. That copy is itself encrypted before it leaves the computer.
If your employer or client paid for your place, we tell them nothing about your progress, answers or marks. They have the invoice, which names you as the learner. You may share your certificate with them yourself.
7. Transfers outside the UK
Our server is in the UK. Stripe and Anthropic process in the United States, and some other suppliers may reach information from outside the UK for support. Where that happens, the transfer is protected by UK adequacy regulations (including the UK Extension to the EU-US Data Privacy Framework, where the supplier is certified) or by the UK International Data Transfer Addendum to the EU standard contractual clauses, which is built into the supplier's data processing terms. Email us for details of the safeguards.
8. How long we keep it
- Your certificates and the marks behind them, with your name and email address: while you have access to any course, and for 6 years after your last access ends, so we can answer any question or claim about a certificate (the limitation period for contract claims, Limitation Act 1980). Then your name, email address and other personal details are erased or redacted; only the anonymous order totals, and the certificate's code and dates (shown as Withdrawn), remain.
- Your progress, notes and study time: deleted 12 months after your last access ends. They serve no purpose once you can no longer open a course.
- Exam answers and feedback: while the enrolment they belong to lasts (that is, until your access to that course ends). Then your written answers are replaced by "[erased]"; your marks and pass or fail are kept with your learner record.
- Purchase and invoice records: 6 years from the end of the accounting year they fall in, as tax law requires (Value Added Tax Act 1994, Schedule 11; Finance Act 1998, Schedule 18).
- Adjustment requests: while you have access, then deleted.
- Marketing list: until you unsubscribe or your record is erased. After that we keep only a scrambled hash of your email address and the date, so that we never email you again by mistake.
- Emails we sent you (the log, not the content): 90 days.
- Failed sign-ins: no more than a day.
- Web server logs: 10 days.
- Support messages: 2 years after the conversation ends.
- Backups: on our servers, deleted within about 90 days (14 daily and 13 weekly copies). The daily copy on our own computer is deleted within 8 weeks, but its Microsoft 365 copy stays recoverable for up to 93 days after that. So every copy is gone within about 5 months. Every backup is encrypted.
If you delete your account (section 10), the shorter periods apply at once: your personal details are erased straight away, and only what tax law and certificate integrity require is kept, as the first point above describes.
9. Marketing emails
- If you bought the course yourself, you can tick "Don't send me tips and offers" at checkout. If you do not, we take it that, as a customer, you are content to hear from us about changes to the CDM Regulations and HSE guidance, new courses, and offers on our courses. This is the "soft opt-in" the law allows for existing customers. (Privacy and Electronic Communications (EC Directive) Regulations 2003, regulation 22(3).)
- If your employer or client bought your place, the buyer's choice does not count for you. We email you news and offers only if you switch news and offers on yourself, on your account page. It is off until you do. You can switch it off again at any time (section 10).
- Every such email has an unsubscribe link, and you can also switch marketing off on your account page or by emailing us. We stop at once.
- Emails about your order, sign-in, exam result, certificate and its expiry are part of the service, not marketing, and are sent whatever you choose. Service emails never contain offers or promotions.
- We send marketing to learners only, never to a business's billing contact unless they are also a learner, and we do not pass the list to anyone. News and offers go out from our own email system on our UK server (the one that also runs our cdm2015.co.uk website and its newsletter), sent through Amazon SES like every other Academy email (section 6). Your email address, name, which of our courses you hold or have passed, and your marketing choice are copied there, and kept in step: when you switch marketing off, unsubscribe or delete your account here, the same happens there.
10. Your rights
Under UK data protection law you can ask us to:
- access: give you a copy of your information. You can download it yourself from your account page at any time, including your answers, marks and feedback;
- rectification: correct it. You can change your name yourself until a certificate is issued; after that, email us;
- erasure: delete it. You can delete your account yourself from your account page. We erase your name, email address, password, notes, sessions and written answers at once. We must keep purchase and invoice records for tax law, and we keep your certificate's code and dates so that a certificate already given to others shows as Withdrawn rather than disappearing; both are stripped of anything that identifies you;
- restriction: limit how we use it;
- objection: stop using it, where we rely on legitimate interests. We will stop unless we have compelling grounds to continue. You can always object to marketing (section 9);
- portability: give it to you, or to someone else, in a common format. Your account download is JSON;
- withdraw consent: where we rely on your consent (marketing to a learner whose place a business bought; an adjustment request), you can withdraw it at any time, and we stop. Withdrawing does not affect what was done before;
- a human review of an automated decision: section 3.
Not every right applies in every case. For example, we must keep invoice records even if you ask us to delete them, and we will explain if a right does not apply. We cannot erase your record while an exam of yours is being marked; please try again in an hour.
To ask, email support@clarity-oo.com from the address on your account. We answer within one month. This can be extended by up to two more months for complex requests, and we will tell you if it is. We do not normally charge.
11. Keeping it safe
- Everything travels encrypted (HTTPS).
- Passwords are stored only as one-way hashes. Sign-in and reset links are random, stored hashed, and work once.
- Your email address is masked in our logs and stored only as a hash in our email log.
- The marking rubrics and model answers never leave our server to a learner.
- Our server is in the UK, kept up to date, and backed up nightly to a second UK server. Backups are encrypted and the key that opens them is kept offline.
- Sign-in is by email and password; there is no two-step sign-in for learners. Repeated failed sign-ins lock the account for a while. Use a password you use nowhere else.
12. Complaints
If you are unhappy with how we have handled your information, please tell us at support@clarity-oo.com. We will acknowledge your complaint within 2 working days, look into it properly, and tell you the outcome within one month.
You can also complain to the Information Commissioner's Office: ico.org.uk, 0303 123 1113. The ICO may ask whether you have complained to us first.
13. Changes
If we change this notice in a way that matters, we will tell learners by email before the change takes effect, and show the new version at academy.cdm2015.co.uk/legal/privacy. The version date is at the top.
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