1. About Waterlip Electrical Contracting Limited
“Waterlip Electrical Contracting Limited” is a trading name (“WEC,” “we,” or “us”), registration number 9695832, having their registered offices 136a High Street, Street, Somerset. Trading address 1 & 2 Centurion Business Park, Fosse Lane, Shepton Mallet, Somerset.
3. Scope and Application of Law
This Policy covers all sensitive, private, and proprietary information that is both internally and externally transmitted, irrespective of the medium of storage or transfer. Types of data covered by this Policy may include but are not limited to, client data, personal information, confidential legal data, confidential client data, non-public financial data and proprietary research data. Collectively, these data types are referred to as “confidential data.” This Policy applies to all WEC employees and others performing work for the Company who may handle and store confidential data on behalf of WEC, its Customers or Suppliers.
B. Application of Laws
This Policy comprises the internationally accepted data privacy principles without replacing the existing national laws. It supplements the national data privacy laws. The relevant national law will take precedence if it conflicts with this Policy, or it has stricter requirements than this Policy. The content of this Policy must also be observed in the absence of corresponding national legislation. The reporting requirements for data processing under national laws must be observed.
At a high level, data processing principles that WEC will comply with include:
4.1. Fairness and lawfulness: When processing personal data, the individual rights of the data subjects must be protected. Personal data must be collected and processed in a legal and fair manner.
4.2. Restriction to a specific purpose: Personal data can be processed only for the purpose that was defined before the data was collected. Subsequent changes to the purpose are only possible to a limited extent and require substantiation.
4.3. Transparency: The data subject must be informed of how his/her data are being handled. In general, personal data must be collected directly from the individual concerned. When the data are collected, the data subject must either be aware of, or informed of: the identity of the Data Controller; the purpose of data processing; and third parties or categories of third parties to whom the data might be transmitted.
4.4. Data reduction and data economy: Before processing personal data, you must determine whether and to what extent the processing of personal data is necessary to achieve the purpose for which it is undertaken. Where the purpose allows and where the expense involved is in proportion with the goal being pursued, anonymized or statistical data must be used. Personal data may not be collected in advance and stored for potential future purposes unless required or permitted by national law.
4.5. Deletion: Personal data that is no longer needed after the expiration of legal or business process- related periods must be deleted. In some cases, there may be an indication of interests that merit protection or historical significance of this data in individual cases.
4.6. Factual accuracy: Personal data on file must be correct, complete, and (if necessary) kept up to date. Suitable steps must be taken to ensure that inaccurate or incomplete data are deleted, corrected, supplemented or updated.
4.7. Confidentiality and data security: Personal data are subject to data secrecy. It must be treated as confidential on a personal level and secured with suitable organizational and technical measures to prevent unauthorized access, illegal processing or distribution, as well as accidental loss, modification or destruction.
5. Reliability of Data Processing
Collecting, processing and using personal data is permitted only under the following legal basis.
A. Consent given to process data
Data can be processed following consent by the data subject. Before giving consent, the data subject must be informed in accordance with this Policy. The declaration of consent must be obtained in writing or electronically for the purposes of documentation. In some circumstances, such as telephone conversations, consent can be given verbally. The granting of consent must be documented.
B. Data processing pursuant to legal authorization
The processing of personal data is also permitted if national legislation requests, requires or allows this. The type and extent of data processing must be necessary for the legally authorized data processing activity, and must comply with the relevant statutory provisions.
C. Processing of sensitive data
Sensitive personal data can be processed only if the law requires this or if the data subject has given consent for the same. This data can also be processed if it is mandatory for asserting, exercising or defending legal claims regarding the data subject. If there are plans to process sensitive data, the CRCO or the Corporate Data Protection Officer (DPO) must be informed in advance.
D. Legitimate Interest
In some circumstances WEC will rely on the legitimate interest concept to justify our processing of personal data but only in circumstances where such processing should be reasonably expected by the Data Owner. The below Section is not exhaustive list of these circumstances and therefore we suggest you consult your WEC representative in case of doubt.
6. Customer Data
A. Processing of an Order
WEC will process a customers order and personal data with the intention of fulfilling the order request.
B. Business Development
WEC will store business network contact information, with the intention of engaging the network with information about WEC’s products and services. Examples of such engagements include:
- WEC employees managing their own personal contact list with the intention of engaging the contact to develop business for WEC’s enterprises
- WEC marketing teams making direct contact with customers whom have provided consent, to inform them of products and services that may be of interest to them
E. Profiling of Customers
WEC will process customer data and profile customer segments with the intention of enhancing the relevance of WECs products and services to the electrical network.
7. Rights of the Data Subject
Every data subject has the following rights
7.1. The data subject may request information on which personal data relating to him/her has been stored, how the data was collected, and for what purpose. If there are further rights to view the employer’s documents (e.g. personnel file) for the employment relationship under the relevant employment laws, these will remain unaffected.
7.2. If Personal Data are transmitted to third parties, information must be given about the identity of the recipient or the categories of recipients.
7.3. If Personal Data are incorrect or incomplete, the data subject can demand that it be corrected or supplemented.
7.4. The data subject can object to the processing of his or her data for purposes of advertising or market research. The data must be blocked from these types of use.
7.5. The data subject may request his/her data to be deleted if the processing of such data has no legal basis, or if the legal basis has ceased to apply. The same applies if the purpose behind the data processing has lapsed or ceased to be applicable for other reasons. Existing retention periods and conflicting interests meriting protection must be observed.
7.6. The data subject generally has a right to object to his/her data being processed, and this must be considered if the protection of his/her interests takes precedence over the interest of the data controller owing to a particular personal situation. This does not apply if a legal provision requires the data to be processed.
7.7. Additionally, every data subject can assert the rights as per national privacy laws.
7.8. When a data subject makes an application to exercise his/her data subject rights, the application must be handled immediately by the Corporate Data Protection Officer.
8. Appendix A: Terms and Definitions
- Personal Information is information that can be used to distinguish or trace an individual’s identity, such as name, social security number, or biometric records, either alone or when combined with other personal or identifying information that is linked or linkable to a specific individual, such as date and place of birth, mother’s maiden name, etc.
- Data are anonymized if personal identity can never be traced by anyone, or if the personal identity could be recreated only with an unreasonable amount of time, expense and labor.
- Consent is the voluntary, legally binding agreement to data processing.
- Data breach incidents are events where there is justified suspicion that Personal Data are being illegally captured, collected, modified, copied, transmitted or used.
- Data subject under this Policy is a natural person whose data can be processed. In some countries, legal entities can be data subjects as well.
- Sensitive data are data about racial and ethnic WEC, political opinions, religious or philosophical beliefs, union membership or the health and sexual life of the data subject. Under certain national laws, other data categories can be considered sensitive or the content of the data categories can be structured differently.
- Personal Data are all information about certain or definable natural persons. A person is definable for instance if the personal relationship can be determined using a combination of information with even incidental additional knowledge.
- Processing personal data means any process, with or without the use of automated systems, to collect, store, organize, retain, modify, query, use, forward, transmit, disseminate or combine and compare data. This also includes disposing of, deleting and blocking data and data storage media. Processing personal data is required if the permitted purpose or justified interest could not be achieved without the personal data, or only with exceptionally high expense.
- Data Controller is a natural or legal person, alone or jointly with others, who determine the purposes and means of the processing.
- Data Processor is a natural or legal person, who processes personal data on behalf of the data controller.
B. THE INFORMATION THE COMPANY COLLECTS AND HOW THE COMPANY USES IT
9.3. When you visit the Website or obtain any Services offered on the Website, the Company may collect information including your name, postal address, e-mail address, telephone number, credit card number and expiry date, type of Services obtained and such other relevant information which the Company deems necessary to process your order in respect of the Services. Where necessary, the information collected is transmitted in a secure manner to third parties to assist the Company to provide you with the Services requested by you and to maintain the support services of the Company. Information collected under this clause 2.1 is collected is processed by us.
9.5. The Company may also use aggregate information and statistics, (but, which will not contain your identifying information) for the purposes of monitoring your usage of the Website in order to help the Company develop the Website and the Services offered by the Company. The Company may provide such aggregate information to third parties.
9.6. The Company may collect information which is based upon your behavior and navigation on the Website. This information allows the Company to carry out internal research on the users’ interest, demographics and behavior so that the Company can better understand, and in turn provide better information, products and services to you and other customers.
9.7. The Company may also wish to provide you with information about special features featured on the Website or any other service or products the Company thinks may be of interest to you.
9.8. The Company may also want to provide you with related information from third parties which it thinks may be of interest to you.
If you do not wish the Company to send you any information set out in Clauses 2.5 to 2.6 above, please send an e-mail to email@example.com.
9.9. If you contact the Company, the Company may keep record of that correspondence.
9.10. The Company uses ‘cookies’ and other technologies to collect information on site to assist the Company in monitoring the Company’s web page flow, promotional effectiveness as well as to promote trust and safety.
9.11. Certain features on the Website are only available if you enable the cookie. The Company also uses a cookie to assist it to provide information which is relevant to your interest.
9.12. You are free to decline the Company’s cookies although that may impair certain features on the Website.
9.13. You can delete any cookies from your computer – refer to your internet browser’s help files.
D. PROTECTING YOUR INFORMATION
9.16. The internet is not a secure medium. However, the Company has put in place various security procedures and strict policy rules to safeguard and protect your information from unauthorized and unlawful access and use. These security procedures and policy which are of the highest standards are continuously improved.
9.17. Notwithstanding the above, it should be appreciated that no system is entirely fool-proof and you should be careful when you reveal any confidential information to any third party.
E. SECURITY AND WHERE WE STORE YOUR PERSONAL DATA
9.18. We are committed to protecting the security of your Data. We use a variety of security technologies and procedures to help protect your Data from unauthorized access and use. We have implemented strict internal guidelines to ensure that your privacy is safeguarded at every level of our organization. We will continue to update policies and implement additional security features as new technologies become available. Although we will do our best to protect your Data, we cannot guarantee the security of your Data transmitted to our Site. Any transmission of Data is at your own risk. Once we receive your Data, we will use appropriate security measures to seek to prevent unauthorized access or disclosure.
F. RETENTION PERIOD(S)
9.19. The retention period for your data depends on the relationship with us, we need to retain customer and client data for a period of 7 years, for non customer / client data we retain this information for a period of 30 months. We will respond to your request in writing as soon as practicable and in any event within one month of receipt of your request. We may request proof of identification to verify your request. All requests should be addressed to our office manager. You may also use the above contact information if you think any information about you is inaccurate, incomplete, or if you want to change the sort of information about you that AEI may have collected. You have the right to lodge a complaint with the Data Protection Commissioner if you are unhappy with how we are processing your Data.
G. SALE OF COMPANY
9.20. If the Company and/or this part of its business is sold or integrated with another business, your details may be disclosed to the Company’s advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the Company or this part of its business (as the case may be).
H. UPDATING YOUR DETAILS
9.21. If any of the information that you have provided to the Company changes, for example if you change your e-mail address, name or payment details please let the Company know the correct details by sending an e-mail to firstname.lastname@example.org
I. YOUR PRIVACY
9.22. As an existing or potential client of WEC, we believe you to have a legitimate interest in receiving information about our products, services and events. You have the option to opt-out or unsubscribe from this marketing at any time by sending an e-mail to email@example.com
9.23. We will never knowingly sell your data to any third-party supplier without your consent.
J. OTHER TERMS
9.27. You have the right at any time to ask the Company not to process your personal data for marketing purposes.
K. CHANGES TO THIS PRIVACY STATEMENT