Privacy Policy

1. INTRODUCTION

SEaO Shipping Limited, registered in Cyprus under company number HE 446177, respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

2. IMPORTANT INFORMATION AND WHO WE ARE

This privacy notice aims to give you information on how SEaO Shipping Limited collects and processes your personal data, including any data you may provide.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them SEaO Shipping Limited is the controller and responsible for your personal data (collectively referred to as “the Company”, “we”, “us” or “our” in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Name: SEaO Shipping Limited

Email address: info@seaoshipping.com

Postal address: Platinum Crest, 18 Loizou Askani Street, Limassol CY- 3110, Cyprus.

Telephone number: +357 99333 695

You have the right to make a complaint at any time to the Commissioner for the Protection of Personal Data ‘the Commissioner’ (www.dataprotection.gov.cy), the Cyprus supervisory authority for data protection issues. We would however, appreciate the chance to deal with your concerns before you approach the Commissioner, so please contact us in the first instance.

3. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 20th April 2023.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

4. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes [first name, maiden name, last name, username or similar identifier, title].
Contact Data includes [billing address, delivery address, email address and telephone numbers].
Financial Data includes [bank account and payment card details].
Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us].
Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website].
Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].
Usage Data includes [information about how you use our website, products and services].
Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, attendance at a conference). In this case, we may have to cancel your booking with us but we will notify you if this is the case at the time.

5. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you :
Create an account on our website;
Subscribe to our service or publications;
Request marketing to be sent to you;
Enter a competition, promotion or survey; or
Give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.

Use of cookies

We use a number of different cookies on our site. If you do not know what cookies are, or how to control or delete them, then we recommend you visit http://www.aboutcookies.org for detailed guidance.
The list below describe the cookies we use on this site and what we use them for. Currently we operate an ‘implied consent’ policy which means that we assume you are happy with this usage. If you are not happy, then you should either not use this site, or you should delete the cookies having visited the site, or you should browse the site using your browser’s anonymous usage setting (called “Incognito” in Chrome, “InPrivate” for Internet Explorer, “Private Browsing” in Firefox and Safari etc.)

First Party Cookies

These are cookies that are set by this website directly.
Google Analytics: We use Google Analytics to collect information about visitor behaviour on our website. Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. This Analytics data is collected via a JavaScript tag in the pages of our site and is not tied to personally identifiable information. We therefore do not collect or store your personal information (e.g. your name or address) so this information cannot be used to identify who you are.
You can find out more about Google's position on privacy in regards to its analytics services at http://www.google.com/intl/en_uk/analytics/privacyoverview.html WordPress: Our websites runs using the popular CMS, HubSpot, and cookies are used to store basic data on your interactions with HubSpot, and whether you have logged into HubSpot. We use a session cookie to remember your log-in for you if you are a registered user and we deem these as being strictly necessary to the working of the website. If these are disabled then various functionality on the site will be broken.
More information on session cookies and what they are used for at http://www.allaboutcookies.org/cookies/session-cookies-used-for.html

Third Party Cookies

These are cookies set on your machine by external websites whose services are used on this site. Cookies of this type are the sharing buttons across the site allow visitors to share content onto social networks. Cookies are currently set by LinkedIn, Twitter, Facebook, Google+ and Pinterest. In order to implement these buttons, and connect them to the relevant social networks and external sites, there are scripts from domains outside of our website. You should be aware that these sites are likely to be collecting information about what you are doing all around the internet, including on this website. You should check the respective policies of each of these sites to see how exactly they use your information and to find out how to opt out, or delete, such information.

6. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.

6.1. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(f) Performance of a contract with you

(g) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

Performance of a contract with you

Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

6.2. CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please Contact us.

9.1. NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

9.2. WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9.3. TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Privacy Policy for Surveyors

Data Protection

This Privacy Standard sets out how we handle the personal data of our surveyors and sub-contractors.

This Privacy Standard applies to all personal data that we process regardless of the media on which that data is stored or whether it relates to past or present surveyors or sub-contractors.

This Privacy Standard applies to all of our surveyors and sub-contractors

Interpretation

Definitions:

Automated Decision-Making (ADM): when a decision is made which is based solely on Automated Processing (including profiling) which produces legal effects or significantly affects an individual. The EU GDPR prohibits Automated Decision-Making (unless certain conditions are met) but not Automated Processing.

Automated Processing: any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of Automated Processing.

Surveyor: A contractor with SEaO Shipping Limited maritime surveyors who receives “enquiries” to submit a bid to inspect a vessel and perform an Inspection.

Consent: agreement which will be freely given, specific, informed and be an unambiguous indication of the Data Subject's wishes by which they, by a statement or by a clear positive action, signifies agreement to the Processing of Personal Data relating to them.

Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the EU GDPR. We are the Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes.

Criminal Convictions Data: means personal data relating to criminal convictions and offences.

Data Subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.

Data Privacy Impact Assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing activity. DPIA can be carried out as part of Privacy by Design and should be conducted for all major system or business change programs involving the Processing of Personal Data.

Data Protection Controller (DPC): this term means a data protection manager or other voluntary appointment of a DPC or refers to the Company data privacy team with responsibility for data protection compliance.

EEA: the 27countries in the EU, and Iceland, Liechtenstein and Norway.

Explicit Consent: consent which requires a very clear and specific statement (that is, not just action).

General Data Protection Regulation (GDPR): The General Data Protection Regulation ((EU) 2016/679).

Personal Data: any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Special Categories of Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person's actions or behaviour.

Personal Data Breach: any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach.

Privacy by Design: implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the GDPR.

Privacy Notices (also referred to as Fair Processing Notices) or Privacy Policies: separate notices setting out information that may be provided to Data Subjects when we collect information about them. These notices may take the form of general privacy statements applicable to a specific group of individuals (for example, employee privacy notices or the website privacy policy) or they may be stand-alone, one-time privacy statements covering Processing related to a specific purpose.

Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.

Pseudonymisation or Pseudonymised: replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure.

Related Policies: the Company's policies, operating procedures or processes related to this Privacy Standard and designed to protect Personal Data.

Special Categories of Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.

Scope

We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times. The Company is exposed to potential fines of up to EUR20 million (approximately £18 million) or 4% of total worldwide annual turnover, whichever is higher and depending on the breach, for failure to comply with the provisions of the EU GDPR.

All individual business areas are responsible for ensuring all Company Personnel comply with this Privacy Standard and need to implement appropriate practices, processes, controls and training to ensure such compliance.

The DPC is responsible for overseeing this Privacy Standard and, as applicable, developing Related Policies and Privacy Guidelines. That post is held by Kyriakos Neophytou kneophytou@seaoshipping.com

Please contact the DPC with any questions about the operation of this Privacy Standard or if We have any concerns that this Privacy Standard is not being or has not been followed.

Personal data protection principles

We adhere to the principles relating to Processing of Personal Data set out in the GDPR which require Personal Data to be:

Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).
Collected only for specified, explicit and legitimate purposes (Purpose Limitation).
Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation).
Accurate and where necessary kept up to date (Accuracy).
Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation).
Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality).
Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).
Made available to Data Subjects and Data Subjects allowed to exercise certain rights in relation to their Personal Data (Data Subject's Rights and Requests).
We are responsible for and will be able to demonstrate compliance with the data protection principles listed above (Accountability).

Lawfulness, fairness, transparency

Personal data will be Processed lawfully, fairly and in a transparent manner in relation to the Data Subject.

We may only collect, Process and share Personal Data fairly and lawfully and for specified purposes. The EU GDPR restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent Processing, but ensure that we Process Personal Data fairly and without adversely affecting the Data Subject.

The EU GDPR allows Processing for specific purposes, some of which are set out below:

the Data Subject has given his or her Consent;
the Processing is necessary for the performance of a contract with the Data Subject;
to meet our legal compliance obligations;
to protect the Data Subject's vital interests; or
to pursue our legitimate interests for purposes where they are not overridden because the Processing prejudices the interests or fundamental rights and freedoms of Data Subjects. The purposes for which we process Personal Data for legitimate interests need to be set out in applicable Privacy Notices.

We will identify and document the legal ground being relied on for each Processing activity [in accordance with the Company's guidelines on Lawful Basis for Processing Personal Data].

Consent

A Controller will only process Personal Data on the basis of one or more of the lawful bases set out in the EU GDPR, which include Consent.

A Data Subject consents to Processing of their Personal Data if they indicate agreement clearly either by a statement or positive action to the Processing. Consent requires affirmative action so silence, pre-ticked boxes or inactivity are unlikely to be sufficient. If Consent is given in a document which deals with other matters, then the Consent will be kept separate from those other matters.

Data Subjects will be easily able to withdraw Consent to Processing at any time and withdrawal will be promptly honoured. Consent may need to be refreshed if We intend to Process Personal Data for a different and incompatible purpose which was not disclosed when the Data Subject first consented.

Unless we can rely on another legal basis of Processing, Explicit Consent is usually required for Processing Special Categories of Personal Data and Criminal Convictions Data, for Automated Decision-Making and for cross border data transfers. Usually we will be relying on another legal basis (and not require Explicit Consent) to Process most types of Special Categories of Personal Data and Criminal Convictions Data. Where Explicit Consent is required, We will issue a Privacy Notice to the Data Subject to capture Explicit Consent.

We will need to evidence Consent captured and keep records of all Consents in accordance with Related Policies and Privacy Guidelines so that the Company can demonstrate compliance with Consent requirements.

Transparency (notifying data subjects)

The EU GDPR requires Data Controllers to provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. Such information will be provided through appropriate Privacy Notices which will be concise, transparent, intelligible, easily accessible, and in clear and plain language so that a Data Subject can easily understand them.

Whenever we collect Personal Data directly from Data Subjects, including for human resources or employment purposes, we will provide the Data Subject with all the information required by the EU GDPR including the identity of the Controller and DPC, how and why we will use, Process, disclose, protect and retain that Personal Data through a Privacy Notice which will be presented when the Data Subject first provides the Personal Data.

When Personal Data is collected indirectly (for example, from a third party or publicly available source), we will provide the Data Subject with all the information required by the EU GDPR as soon as possible after collecting/receiving the data. We will also check that the Personal Data was collected by the third party in accordance with the EU GDPR and on a basis which contemplates our proposed Processing of that Personal Data.

Purpose limitation

Personal Data will be collected only for specified, explicit and legitimate purposes. It will not be further Processed in any manner incompatible with those purposes.

We cannot use Personal Data for new, different or incompatible purposes from that disclosed when it was first obtained unless We have informed the Data Subject of the new purposes and they have Consented where necessary.

Data minimisation

Personal Data will be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed.

We may only Process Personal Data when it is required. We cannot Process Personal Data for any reason unrelated to your job duties.

We may only collect Personal Data that we require for our work or contract for us: we do not collect excessive data. We will Ensure any Personal Data collected is adequate and relevant for the intended purposes.

We will ensure that when Personal Data is no longer needed for specified purposes, it is deleted or anonymised in accordance with the Company's data retention guidelines.

Accuracy

Personal Data will be accurate and, where necessary, kept up to date. It will be corrected or deleted without delay when inaccurate.

We will check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. We will take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.

Storage limitation

Personal Data will not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed.

We will not keep Personal Data in a form which permits the identification of the Data Subject for longer than needed for the legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements.

The Company will maintain retention policies and procedures to ensure Personal Data is deleted after a reasonable time for the purposes for which it was being held, unless a law requires such data to be kept for a minimum time.

We will ensure Data Subjects are informed of the period for which data is stored and how that period is determined in any applicable Privacy Notice.

Security integrity and confidentiality

Protecting Personal Data

Personal Data will be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.

We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Pseudonymisation where applicable). We will regularly evaluate and test the effectiveness of those safeguards to ensure security of our Processing of Personal Data. We are responsible for protecting the Personal Data we hold. We will implement reasonable and appropriate security measures against unlawful or unauthorised Processing of Personal Data and against the accidental loss of, or damage to, Personal Data. We will exercise particular care in protecting Special Categories of Personal Criminal Convictions Data from loss and unauthorised access, use or disclosure.

We will follow all procedures and technologies we put in place to maintain the security of all Personal Data from the point of collection to the point of destruction. We may only transfer Personal Data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested.

We will maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:

Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it.

Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed. Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes.

We will comply with and not attempt to circumvent the administrative, physical and technical safeguards we implement and maintain in accordance with the EU GDPR and relevant standards to protect Personal Data.

Reporting a Personal Data Breach

The EU GDPR requires Controllers to notify any Personal Data Breach to the applicable regulator and, in certain instances, the Data Subject.

We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.

If We know or suspect that a Personal Data Breach has occurred, it will be investigated by our DPC. We should preserve all evidence relating to the potential Personal Data Breach.

Transfer limitation

The GDPR restricts data transfers to countries outside the EEA in order to ensure that the level of data protection afforded to individuals by the GDPR is not undermined. We transfer Personal Data originating in one country across borders when We transmit, send, view or access that data in or to a different country.

We may only transfer Personal Data outside the EEA if one of the following conditions applies:

the European Commission has issued a decision confirming that the country to which we transfer the Personal Data ensures an adequate level of protection for the Data Subjects' rights and freedoms;
appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved by the European Commission, an approved code of conduct or a certification mechanism, a copy of which can be obtained from the DPC (if applicable);
the Data Subject has provided Explicit Consent to the proposed transfer after being informed of any potential risks; or
the transfer is necessary for one of the other reasons set out in the EU GDPR including the performance of a contract between us and the Data Subject, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital interests of the Data Subject where the Data Subject is physically or legally incapable of giving Consent and, in some limited cases, for our legitimate interest.

Data Subject's rights and requests

Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:

withdraw Consent to Processing at any time;
receive certain information about the Data Controller's Processing activities;
request access to their Personal Data that we hold;
prevent our use of their Personal Data for direct marketing purposes;
ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;
restrict Processing in specific circumstances;
challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;
request a copy of an agreement under which Personal Data is transferred outside of the EEA;
object to decisions based solely on Automated Processing, including profiling (ADM);
prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;
be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;
make a complaint to the supervisory authority; and
in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine-readable format.

We will verify the identity of an individual requesting data under any of the rights listed above (do not allow third parties to persuade us into disclosing Personal Data without proper authorisation).

We will immediately forward any Data Subject request We receive to the DPC.

Accountability

The Controller will implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. The Controller is responsible for, and will be able to demonstrate, compliance with the data protection principles.

The Company will have adequate resources and controls in place to ensure and to document EU GDPR compliance including:

appointing a suitably qualified data protection officer (where necessary) and an executive accountable for data privacy;
implementing Privacy by Design when Processing Personal Data and completing DPIAs where Processing presents a high risk to rights and freedoms of Data Subjects;
integrating data protection into internal documents including this Privacy Standard or Privacy Notices;
regularly training Company Personnel on the GDPR and the DPA 2018, this Privacy Standard, Related Policies and Privacy Guidelines and data protection matters including, for example, Data Subject's rights, Consent, legal basis, DPIA and Personal Data Breaches. The Company will maintain a record of training attendance by Company Personnel; and
regularly testing the privacy measures implemented and conducting periodic reviews and audits to assess compliance, including using results of testing to demonstrate compliance improvement effort.

Record keeping

The EU GDPR requires us to keep full and accurate records of all our data Processing activities.

We will keep and maintain accurate corporate records reflecting our Processing including records of Data Subjects' Consents and procedures for obtaining Consents.

These records should include, at a minimum, the name and contact details of the Controller and the DPC, clear descriptions of the Personal Data types, Data Subject types, Processing activities, Processing purposes, third-party recipients of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data's retention period and a description of the security measures in place. In order to create such records, data maps should be created which should include the detail set out above together with appropriate data flows.

Training and audit

We are required to ensure all Company Personnel have undergone adequate training to enable them to comply with data privacy laws. We will also regularly test our systems and processes to assess compliance.

We will regularly review all the systems and processes under we control to ensure they comply with this Privacy Standard and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data.

Privacy by Design and Data Protection Impact Assessment (DPIA)

We are required to implement Privacy by Design measures when Processing Personal Data by implementing appropriate technical and organisational measures (like Pseudonymisation) in an effective manner, to ensure compliance with data privacy principles.

We will assess what Privacy by Design measures can be implemented on all programs/systems/processes that Process Personal Data by taking into account the following:

the state of the art;
the cost of implementation;
the nature, scope, context and purposes of Processing; and
the risks of varying likelihood and severity for rights and freedoms of Data Subjects posed by the Processing.

Data controllers will also conduct DPIAs in respect to high risk Processing.

We should conduct a DPIA (and discuss our findings with the DPC) when implementing major system or business change programs involving the Processing of Personal Data including:

use of new technologies (programs, systems or processes), or changing technologies (programs, systems or processes);
Automated Processing including profiling and ADM;
large scale Processing of Special Categories of Personal Data or Criminal Convictions Data; and
large scale, systematic monitoring of a publicly accessible area.

A DPIA will include:

a description of the Processing, its purposes and the Data Controller's legitimate interests if appropriate;
an assessment of the necessity and proportionality of the Processing in relation to its purpose;
an assessment of the risk to individuals; and
the risk mitigation measures in place and demonstration of compliance.

Automated Processing (including profiling) and Automated Decision-Making

Generally, ADM is prohibited when a decision has a legal or similar significant effect on an individual unless:

a Data Subject has Explicitly Consented;
the Processing is authorised by law; or
the Processing is necessary for the performance of or entering into a contract.

If certain types of Special Categories of Personal Data or Criminal Convictions Data are being processed, then grounds (b) or (c) will not be allowed but such Special Categories of Personal Data and Criminal Convictions Data can be Processed where it is necessary (unless less intrusive means can be used) for substantial public interest like fraud prevention.

If a decision is to be based solely on Automated Processing (including profiling), then Data Subjects will be informed when We first communicate with them of their right to object. This right will be explicitly brought to their attention and presented clearly and separately from other information. Further, suitable measures will be put in place to safeguard the Data Subject's rights and freedoms and legitimate interests.

We will also inform the Data Subject of the logic involved in the decision making or profiling, the significance and envisaged consequences and give the Data Subject the right to request human intervention, express their point of view or challenge the decision.

A DPIA will be carried out before any Automated Processing (including profiling) or ADM activities are undertaken.

Direct marketing

We are subject to certain rules and privacy laws when marketing to our customers.

For example, a Data Subject's prior consent is required for electronic direct marketing (for example, by email, text or automated calls). The limited exception for existing customers known as "soft opt in" allows organisations to send marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the details and in every subsequent message.

The right to object to direct marketing will be explicitly offered to the Data Subject in an intelligible manner so that it is clearly distinguishable from other information.

A Data Subject's objection to direct marketing will be promptly honoured. If a customer opts out at any time, their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future.

In this specific circumstance, the Data Controller uses a Data Subject's personal contact data to provide the Data Subject with alerts regarding available inspections, and from time to time, will communicate new literature, important ale

Privacy Policy

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