1. Who we are
Capline (“we”, “us”) provides guidance and services to help smaller suppliers respond to sustainability and ESG questionnaires from their customers, banks and investors.
We are the data controller for the personal data described in this notice. That means we decide why and how it is used, and we are responsible for looking after it.
| Contact | hello@capline.co.uk |
|---|---|
| Registered address | To be added on incorporation |
| Company number | To be added on incorporation |
| ICO registration | Registration in progress |
2. The short version
We ask our clients for totals, not people. The sustainability disclosures we help with require aggregated figures — total headcount, the number of workplace accidents, average training hours, average hourly pay by gender. None of that requires a named individual, so we do not ask for employee records, payroll files or accident reports.
The result is that we hold very little personal data: business contact details, and the email addresses of people who ask us for our free guide. We would rather design the problem away than manage it.
3. What we collect, and why
a. If you request our free guide
We collect the email address you enter, and the date you submitted it. We use it to send you the guide, and occasionally to send related material we think will be useful. Every message includes a one-click unsubscribe.
Lawful basis: consent, which you give by submitting the form and can withdraw at any time.
b. If we contact you first
We sometimes approach businesses we believe are affected by supplier sustainability questionnaires. Where we do, we use business contact details from publicly available sources such as company websites, Companies House and professional networks. We contact people in their professional capacity, at their work address, about a matter relevant to their role.
Lawful basis: legitimate interests — our interest in offering a relevant service to businesses likely to need it, balanced against your interests. You can object at any time and we will stop and remove your details.
c. If you become a client
We collect the business contact details we need to deliver the work: name, job title, work email, work telephone number, and correspondence with you.
Lawful basis: performance of a contract, and our legitimate interest in keeping proper business records.
d. The sustainability information clients send us
This is normally not personal data at all — energy bills, waste transfer notes, water readings, purchase records and aggregated workforce figures.
We ask clients not to send individual employee records. If personal data reaches us anyway, inside a document that was not filtered before sending, we will tell the client, use only what is necessary, and delete the rest. We do not ask for, and do not want, health or accident records relating to identifiable individuals.
Lawful basis: performance of a contract with the client. Where a client sends us personal data about their own staff, the client is the controller and we act as their processor.
e. When you visit the website
Our site is a single page with no analytics, no advertising trackers and no cookies set by us. Our hosting provider processes technical information such as IP address and browser type in order to serve the page and protect against attacks.
The site loads typefaces from Google Fonts. This means your IP address is processed by Google in order to deliver the fonts. If you would prefer we removed this, tell us — we are happy to serve the fonts ourselves instead.
Lawful basis: legitimate interests — running a secure, working website.
4. Who else handles your data
We use a small number of established suppliers to run the business. They act on our instructions and are not permitted to use your data for their own purposes.
| Supplier | What they do |
|---|---|
| Formspree | Receives submissions from the form on our website |
| Zoho | Our email service |
| Cloudflare | Domain, website hosting and security |
Some of these organisations are based outside the UK. Where personal data is transferred outside the UK, it is protected by an adequacy decision or by standard contractual clauses. We keep records of these arrangements and will share the detail on request.
We do not sell personal data, and we do not share it for anyone else’s marketing.
We may disclose information if the law requires it, or to establish or defend a legal claim.
5. How long we keep it
| What | How long |
|---|---|
| Guide request email addresses | Until you unsubscribe, or after two years with no engagement |
| Prospect contact details | Removed on objection, or after 12 months with no response |
| Client records and correspondence | Six years after the end of the relationship, to meet tax and legal record-keeping requirements |
| Client source documents | Returned or deleted on request; otherwise deleted 12 months after the work concludes |
6. Keeping it safe
We use reputable providers with encryption in transit and at rest, multi-factor authentication on every account, and access limited to those who need it. We ask for aggregated figures rather than personal records, which means there is far less to protect in the first place. No system is perfectly secure, but we take this seriously and review it as the business grows.
7. Your rights
Under UK data protection law you have the right to:
- ask what personal data we hold about you, and get a copy
- have inaccurate data corrected
- ask us to delete data, in certain circumstances
- ask us to restrict how we use it, in certain circumstances
- object to processing based on legitimate interests, including our marketing
- ask us to transfer data to you or another provider, in certain circumstances
- withdraw consent at any time, where consent is the basis we rely on
To exercise any of these, email hello@capline.co.uk. We will respond within one month. There is no charge.
8. Complaints
If you are unhappy with how we have handled your data, please tell us first — we would like the chance to put it right. You also have the right to complain to the Information Commissioner’s Office at any time.
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Helpline 0303 123 1113. ico.org.uk
9. Changes to this notice
We will update this notice when our practices change. The date at the top shows the current version. If a change materially affects you, we will tell you directly.