ClockFence Privacy Notice
Pilot version. This notice applies to the ClockFence pilot service. It has been prepared with care but has not yet been reviewed by a solicitor or data protection adviser; it will be reviewed and reissued before ClockFence is offered commercially. Questions about it are welcome at privacy@clockfence.co.uk.
Last updated: 3 November 2026
Who we are: ClockFence is provided by Meridia Projects Ltd, a company registered in England and Wales (company number 17434937) with its registered office at 4-6 Greatorex Street, London, England, E1 5NF. In this notice, "we", "us" and "Meridia" mean Meridia Projects Ltd.
Contact for privacy matters: privacy@clockfence.co.uk
1. Who this notice is for
ClockFence is a clock-in and clock-out app used by construction contractors to record when their workers arrive at and leave a site. Because of the way the service works, we handle personal data in different roles, and this notice is split into parts accordingly.
- Part A is for people who set up and manage a ClockFence account for their business (account holders, managers, supervisors and billing contacts), and for people at construction businesses we contact about ClockFence before they become customers. For this data, Meridia is the controller: we decide how and why it is used.
- Part B is for workers (employees and self-employed CIS subcontractors) who clock in and out using ClockFence. For this data, Meridia is a processor: we handle it only on the instructions of the company you work for, which is the controller.
- Part C applies to everyone.
If you are a manager who also clocks in and out on site, both Part A and Part B apply to you. If we have contacted you about ClockFence and you have not signed up, section A5 is the part written for you.
Part A: Account holders, managers and business contacts (Meridia as controller)
A1. What we collect
When a company signs up for ClockFence and while it uses the service, we collect:
| Category | Examples |
|---|---|
| Account details | Name, work email address, phone number, job title, company name and address |
| Login and security data | Hashed password or PIN, session cookie identifier, sign-in times, IP address, device and browser type |
| Billing data | Plan, invoices, payment status, VAT number. Card details are entered directly into Stripe; Meridia never sees or stores full card numbers |
| Usage data | Sites created, settings changed, exception reviews and notes written, CSV exports run, support requests |
| Communications | Emails and support messages you send us, and your marketing preferences |
| Business contact data | Where we have found your details ourselves to tell you about ClockFence, the information in section A5 |
A2. Why we use it and our lawful basis
| Purpose | Lawful basis (UK GDPR Article 6) |
|---|---|
| Creating and running your account, providing the app, sending service messages (for example, downtime notices or security alerts) | Performance of a contract with you |
| Taking payment, issuing invoices, chasing unpaid amounts, keeping tax and accounting records | Performance of a contract; legal obligation (tax and company law) |
| Answering support requests and fixing problems | Performance of a contract; legitimate interests (running a reliable service) |
| Keeping the service secure, preventing fraud and misuse, investigating suspicious activity | Legitimate interests (protecting our customers, workers and systems) |
| Improving the product using aggregated or de-identified usage statistics | Legitimate interests (understanding how the product is used) |
| Sending product news and marketing emails to account holders | Consent, or the "soft opt-in" for similar products where you gave us your details while signing up for or asking about ClockFence and did not opt out. You can opt out at any time using the link in each email or by contacting us |
| Contacting people at construction businesses who are not yet customers to tell them about ClockFence | Legitimate interests (growing a new business by telling the firms it was built for that it exists). Section A5 explains how we do this and the limits we work to |
| Establishing, exercising or defending legal claims | Legitimate interests |
Where we rely on legitimate interests, we have considered the impact on you and concluded that our use is proportionate and would be reasonably expected. You can ask for a copy of our assessment by contacting privacy@clockfence.co.uk.
A3. Who we share it with
We do not sell personal data. We share it only with:
- Service providers (sub-processors) acting on our instructions. Our current list is in section C4 below. This includes our hosting provider, our database provider (Supabase, EU region) and Stripe for payments.
- Professional advisers such as accountants, insurers and solicitors where necessary.
- Regulators, courts and law enforcement where we are legally required to do so.
- A buyer or successor if Meridia or the ClockFence business is sold or reorganised. We would tell you before your data became subject to a different privacy notice.
A4. How long we keep it
| Data | Retention |
|---|---|
| Account and profile data | For the life of the contract, then deleted 30 days after the contract ends (except as needed below) |
| Billing records and invoices | 6 years after the end of the financial year they relate to (HMRC requirement) |
| Session tokens | 90 days from issue, or earlier if you sign out |
| Support correspondence | 2 years after the ticket is closed |
| Marketing preferences | Until you withdraw consent, plus a suppression record so we do not contact you again |
| Business contact data gathered for prospecting (section A5) | 12 months from our last contact with you if there has been no reply, or 24 months from the last two-way conversation. If you tell us you are not interested we delete your details and keep only a suppression record (name, business and contact point) so we do not contact you again |
A5. Business contacts we approach about ClockFence (B2B prospecting)
ClockFence is new, and part of launching it is telling construction businesses that it exists. That means we sometimes contact people at contractors, subcontractors and groundworks firms who have not yet dealt with us. This section explains what we do, so that you are not surprised by it.
Who this covers. Owners, directors, contracts managers, site managers, office managers and similar roles at UK construction businesses that look like a fit for ClockFence (typically firms running their own labour on site).
What we collect. Your name, job title, the business you work for, your work email address, work phone number, LinkedIn profile URL, the business's trading address, website and Companies House details, and anything that helps us judge whether ClockFence is relevant (for example, the type of work the firm does and roughly how many people it puts on site). We keep a short record of each contact we make and any reply.
Where we get it. Publicly available business sources: the business's own website, Companies House, LinkedIn and other professional profiles, trade directories, and industry press. We also keep details you give us yourself, for example at an event or in a reply. We do not buy marketing lists and we do not collect anything about your personal life.
Why, and our lawful basis. We rely on legitimate interests (UK GDPR Article 6(1)(f)): the interest is making a new product known to the businesses it was built for. UK GDPR recognises direct marketing as a possible legitimate interest. We have carried out a legitimate interests assessment and concluded that a small number of relevant, clearly identified messages about a workplace tool, sent to people in their business roles, is proportionate and would be reasonably expected. You can ask for a copy of the assessment at privacy@clockfence.co.uk.
The rules we follow when we get in touch.
- Email, text and LinkedIn messages go only to corporate subscribers: limited companies, limited liability partnerships, Scottish partnerships and public bodies. The Privacy and Electronic Communications Regulations (PECR) allow this without prior consent.
- Sole traders and ordinary partnerships are treated by PECR as individuals. We do not send them unsolicited marketing emails, texts or direct messages; we only contact them where they have asked us to, or by post or a telephone call.
- Before any live telephone call we screen the number against the Telephone Preference Service and Corporate Telephone Preference Service. We do not make automated calls.
- Every message says who we are, why we are contacting you, and gives a simple way to say no. If you reply "no thanks", "stop" or "unsubscribe", or use the opt-out link, we stop and add you to our suppression list.
- We keep the volume low: a first message and, at most, two follow-ups over a few weeks, then we leave you alone unless you reply.
- We only contact you in your business role, at business contact details, about ClockFence. We do not share or sell these details to anyone else.
- We use ordinary business email and LinkedIn messaging. We do not use tracking pixels or hidden read receipts in prospecting emails.
Your rights. You have an absolute right to object to direct marketing at any time, and we will stop with no questions asked. You also have the rights set out in section C1, including the right to know what we hold about you and to have it deleted. Email privacy@clockfence.co.uk or reply to any message from us.
Where the information came from. UK GDPR requires us to tell you the source of information we did not get from you directly. If you ask, we will tell you the specific source for your record.
Who it is shared with. Only our email and hosting providers listed in section C4, acting on our instructions, and the professional advisers and authorities described in section A3.
Part B: Workers who clock in and out (Meridia as processor)
B1. Your employer or contractor is responsible
If you clock in and out using ClockFence, the company that added you to the system (your employer, or the contractor you subcontract to) is the controller of your data. They decide to use ClockFence, choose the settings that apply to you (such as whether a selfie is required), and are responsible for telling you about it and for handling your rights requests.
Meridia stores and processes your data on that company's behalf under a written data processing agreement. We do not use your data for our own purposes, and we do not share it with anyone other than the sub-processors listed in section C4 or where the law requires.
Your employer must inform you. Under UK GDPR your employer or contractor has to tell you clearly that they use ClockFence, what is recorded and why, before you start using it. The ICO's guidance on monitoring workers explains what employers must do: ICO guidance on monitoring workers. If you have not been told, ask your manager.
B2. What is collected about you
| Category | Details |
|---|---|
| Identity | Your name, trade, role and employment type (employed or self-employed CIS subcontractor), as entered by your employer |
| PIN | The 4 to 6 digit PIN you use to sign in. It is stored in hashed form, so we cannot read it back |
| Clock events | The date and time each time you press Clock In or Clock Out, including clocking out and back in for lunch where your employer uses that setting. If your employer sets an unpaid lunch break for a site, your timesheet shows the minutes taken off |
| Location at clock events | Your phone's GPS position (latitude, longitude and an accuracy figure) at the exact moment you press Clock In or Clock Out. The server compares this with the boundary your employer has drawn for the site and records the distance from the site |
| Site checks | Only if your employer has switched on spot site checks for that site. Up to twice a day while you are clocked in there, the app asks you to confirm you are still on site. We record when each check was sent and answered, your phone's GPS position and accuracy at the moment you answer, the distance from the site, and the result: on site, off site, no location, or not answered |
| Flags | Automatic markers on a clock event, such as: outside boundary, late start, early finish, no clock-out, low GPS accuracy, late sync (recorded offline and uploaded later), simulated location detected, or long lunch. A clock-out for lunch is marked as lunch so it is not counted as an early finish |
| Selfie photo | Only if your employer has switched on the selfie requirement for that site. The photo is taken at clock-in and attached to the event |
| Notes | Any free-text note you choose to add to a clock event, and any review note a manager adds when checking an exception |
| Device and session data | A session cookie so you do not have to sign in every time, and basic technical information (browser type, IP address) in server logs |
| Check alert address | Only if you turn on check alerts. An address issued by your phone's notification service (Google, Apple, Mozilla or Microsoft) so the app can tell you when a site check is waiting. It contains no location and no personal details |
B3. Location is read only when you press a button
ClockFence does not track you. It reads your location only at the moment you press Clock In or Clock Out (including clocking out and back in for lunch) or, where your employer has switched on spot site checks, the button to answer a check. Each press sends that single reading to the server, and the app does not ask for your location again until the next press. There is no background tracking, no route recording and no monitoring between these moments. If you deny location permission, the app will tell you and the clock event may be flagged for your manager to review.
Spot site checks. Your employer can choose to have the app ask you, at random times and no more than twice a day on each site, to confirm you are still there. Checks happen only while you are clocked in at that site, not in the first 45 minutes after you clock in or the last 30 minutes before the site's finish time, and never while you are clocked out or out for lunch. The check shows on the clock screen, and on your phone's notifications if you have turned on check alerts. You have 15 minutes to answer, and your phone reads your location once when you press the button. You can answer without sharing a location, but your manager will see that. If you do not answer in time, or the reading is outside the site boundary, your manager sees it as an exception to review, in the same way as an off-site clock-in.
We treat location data as intrusive even though it is not "special category" data under UK GDPR, which is why we collect it only at the moments needed to confirm attendance: clocking in, clocking out and, where your employer uses them, answering a site check.
B4. Why your employer uses this data
Typically your employer uses ClockFence to:
- keep accurate records of hours worked for payroll, CIS returns and HMRC record-keeping;
- confirm that workers were on the correct site and, where spot site checks are switched on, that they were still there during the paid day;
- apply unpaid lunch breaks consistently;
- produce weekly timesheets and export them for payroll or invoicing;
- review exceptions (for example, a clock-in far outside the site boundary) and record the outcome;
- meet health and safety duties to know who is on site.
Your employer must identify its own lawful basis for this. Meridia cannot do that for them.
B5. How long your data is kept
The retention periods below are Meridia's defaults. Your employer can shorten some of them and may have its own reasons to keep records longer.
| Data | Default retention |
|---|---|
| Clock events and timesheets, including the location coordinates and flags attached to each event, and site check results | 6 years, to meet HMRC and CIS record-keeping duties and the time limits for employment claims |
| Selfie photos | 90 days, then deleted automatically. Your employer can set a shorter or longer period |
| Session tokens | 90 days, or earlier if you sign out |
| Check alert address | Deleted as soon as your phone's notification service tells us it no longer works (for example after you block notifications for ClockFence or remove it from your phone), and in any case when your employer's account is closed |
| Your worker profile (name, trade, role, hashed PIN) | Until your employer removes you, and in any case within 30 days of the end of their contract with us, subject to the timesheet retention above |
B6. How to exercise your rights
Because your employer is the controller, please send access, correction, deletion or objection requests to them in the first instance. They can pull your full record from ClockFence using built-in export tools. If you contact us directly, we will pass your request to your employer promptly and tell you we have done so, unless we are legally required to act ourselves.
Part C: Information that applies to everyone
C1. Your rights
Under UK GDPR you have the right to:
- Access the personal data held about you and receive a copy.
- Rectification of inaccurate or incomplete data.
- Erasure of your data in certain circumstances (for example, where it is no longer needed).
- Restriction of processing while a dispute about accuracy or use is resolved.
- Object to processing based on legitimate interests, and to direct marketing at any time. Objections to direct marketing are always upheld.
- Data portability of data you provided to us that we process by automated means under a contract or consent.
- Withdraw consent at any time where consent is the basis for processing, without affecting earlier processing.
- Not be subject to solely automated decisions with legal or similarly significant effects. ClockFence's flags (such as "outside boundary") are prompts for a human manager to review; they do not by themselves make decisions about pay or discipline.
To exercise these rights with Meridia as controller, email privacy@clockfence.co.uk. We will respond within one month. We may ask for proof of identity. If a request is complex we may extend by up to two further months and will tell you why.
C2. Complaints
If you are unhappy with how we have handled your data, please contact us first at privacy@clockfence.co.uk so we can try to put things right. You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection regulator, at ico.org.uk, by telephone on 0303 123 1113, or by post to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
C3. Where your data is stored and international transfers
ClockFence is hosted on cloud infrastructure located in the United Kingdom or the European Economic Area (EEA). Our managed database is hosted by Supabase in an EU region. Transfers between the UK and the EEA are permitted under the UK's adequacy regulations.
Some of our sub-processors (for example, Stripe) are part of groups headquartered outside the UK and may provide support from other countries. Where personal data is transferred outside the UK to a country not covered by UK adequacy regulations, we rely on the ICO's International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, together with a transfer risk assessment. You can request details of the safeguards in place by emailing privacy@clockfence.co.uk.
C4. Sub-processors
| Sub-processor | Purpose | Location |
|---|---|---|
| Supabase, Inc. | Managed PostgreSQL database holding all account, worker and clock-in data, including selfie photos, and nightly backups | United Kingdom (AWS London region) |
| Perplexity AI, Inc. | Application hosting for the pilot service (the app server that processes requests; no customer data is stored at rest beyond short-lived server logs). To be replaced by UK/EU hosting before general release | United States, under the UK Addendum to the EU Standard Contractual Clauses |
| Resend, Inc. | Transactional email: account invitations, password resets and backup delivery | EU region (Ireland) |
| Stripe Payments Europe Ltd | Payment processing and invoicing for customer accounts. Stripe handles card details directly; Meridia never sees them | Ireland (with group support outside the UK under appropriate safeguards) |
We will update this list and give customers at least 30 days' notice before adding or changing a sub-processor.
Check alerts. If a worker turns on check alerts, we send an empty alert through the notification service run by the maker of their phone or browser (Google, Apple, Mozilla or Microsoft). The alert carries no name, location or message text; the wording shown is stored on the phone itself.
C5. Cookies
ClockFence uses one strictly necessary cookie, named __Host-onsite. It keeps you signed in and is marked HttpOnly and Secure so it cannot be read by scripts or sent over an unencrypted connection. It expires after 90 days or when you sign out. Because it is essential to provide the service you have asked for, consent is not required under the Privacy and Electronic Communications Regulations. We do not use analytics, advertising or tracking cookies. If we introduce any non-essential cookies in future we will ask for your consent first.
C6. Security
We use encryption in transit (TLS) for all connections, hashed storage of PINs and passwords, sign-in lockout after repeated failed attempts, role-based access so that managers see only their own company's data, encrypted backups, and an audit trail of manager reviews. No system is completely secure, and if we become aware of a breach affecting your data we will act in line with our breach procedure and, where required, notify the controller and the ICO.
C7. Children
ClockFence is a workplace tool and is not intended for anyone under 16. We do not knowingly collect data about children. If you believe a child's data has been entered into ClockFence, contact privacy@clockfence.co.uk and we will work with the controller to remove it.
C8. Changes to this notice
We may update this notice from time to time. Minor changes will be shown by updating the date at the top. For significant changes we will email account holders and, where we are the controller, give reasonable notice before the change takes effect. Controllers using ClockFence are responsible for passing on relevant changes to their workers. Previous versions are available on request.
C9. Contact
Meridia Projects Ltd 4-6 Greatorex Street, London, England, E1 5NF Email: privacy@clockfence.co.uk
We have not appointed a statutory Data Protection Officer because we do not meet the criteria that make one mandatory. The privacy@ mailbox is monitored by the person responsible for data protection at Meridia.