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GDPR DATA PRIVACY AND PROCEDURE NOTICE FOR CLIENTS AND SUPPLIERS
INTRODUCTION – THE PURPOSE OF THIS PRIVACY NOTICE
E & R Owen Au Gwmni Trading As Wood
Energy Wales: is committed to protecting the privacy and security of your
personal information. Please read this privacy notice carefully in order to
understand our views and also our practices in regards to your personal data.
The notice covers how we collect and use your personal information during and
after your working relationship with us, in accordance with the General Data
Protection Regulation (GDPR). It applies to all of our clients.
DEFINITIONS
Wood Energy Wales is a “data controller”. This means we
determine the purposes and means of processing personal data.
A “data processor” is responsible for processing personal data on
behalf of a controller. We will always use data processors who are GDPR
compliant.
Personal
data is defined by the GDPR as meaning any information relating
to an identifiable person who can be directly or indirectly identified by
reference to an identifier (Article 6). For example full name, home address,
private email address or telephone number. Online identifiers include IP
addresses and cookies.
There is also special
categories of personal data, which is referred to as sensitive data
(Article 9). For example racial or ethnic origin, health data, biometrics or
political opinions. Wood Energy Wales will never store any such data.
HOW TO
CONTACT Wood Energy Wales
Wood Energy Wales is the data controller and as such,
we decide how your personal data is processed and for what purposes (as
explained in this privacy notice). Should you wish to discuss your personal
data, or any queries in regards to how we hold or process personal data, please
contact D H Owen of E & R Owen Au Gwmni - Trading as Wood Energy
Wales. D H Owen can be contacted by telephone on 07769 972556 or by
email at: huw@woodenergy.wales
DATA
PROTECTION PRINCIPLES
We will comply with data protection law (GDPR). This says
that personal information we hold about you must:
1.
Processed lawfully, fairly and in a transparent
manner;
2.
Collected for specific, explicit and legitimate
purposes;
3.
Must be adequate, relevant and limited to what
is necessary;
4.
Must be accurate and up to date;
5.
Kept in a form which permits identification of
data subjects (a natural person) for no longer than is necessary;
6.
Processed in a manner that ensures appropriate
security of the personal data.
WHY WE KEEP
AND PROCESS YOUR PERSONAL DATA
We will use your personal data for the following purposes:
1.
To meet contractual obligations
2.
To meet legal obligations
3.
Where consent has been positively given for
marketing purposes
We will only collect basic personal data to fulfill the above
purposes, and this does not include any special categories of personal
information about you. This information will include the likes of your name,
address and personal email address.
We will collect personal data from our clients themselves,
and will never accept personal data from third parties. The data will be
collected from our clients for 1 and 2 above, in order to continue our
professional relationship.
Data will be collected for 3 above, primarily for marketing
purposes and always with a GDPR complaint method (for example, MailChimp as an
emarketing solution).
WHAT IS OUR
LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?
The GDPR outlines 6 legal basis for processing personal
data. Of these six, Wood Energy Wales has identified 3 lawful basis for collecting and
processing personal data. These are:
1.
Contractual: personal information is collected
and processes where we need to perform the contract/agreement we have entered
with you
2.
Legal: where it is necessary to collect and
process personal information to comply with the law
3.
Consent: where consent has been freely given for
marketing purposes
DATA
SHARING
Wood Energy Wales will not share your data for
marketing purposes with any third parties. We will only share your personal
information with third parties when required by the law to do so, where it is
necessary to administer the working relationship with you or where we have
another legitimate interest in doing so.
DATA
STORAGE
Wood Energy Wales data is stored securely on a
standalone computer, which is fully updated and as secure as possible.
Please be aware that your information may in the future be
stored on a cloud-based system, whose servers are located outside of the EU. In
such a case Wood Energy Wales will always ensure that we use a GDPR complaint
company for such a service.
Wood Energy Wales also has access to some personal
data (your name, phone number and email address) on an encrypted mobile phone.
DATA
SECURITY
We have put in place security measures to prevent your
personal information from being accidentally lost, used or accessed in an
unauthorised way, altered or disclosed. We do not have any employees, agents or
contractors who have or would have access to your personal information.
DATA RETENTION
We will only retain your personal information for no longer
than is reasonable necessary in order to fulfil the purposes it was collected
for. To determine these lengths of time we consider the amount, nature,
sensitivity of the data, potential risk of harm from unauthorised use or
disclosure, the purposes for which we process your personal data and whether we
can achieve those purposes through other means.
YOUR RIGHTS
AND YOUR PERSONAL DATA
The GDPR provides the following rights for you as
individuals:
1.
Right to be informed about the collection and
use of your personal data
2.
Right of access (referred to as a “data subject
access request”) to your personal data
3.
Right to rectification – where personal data may
be out of date
4.
Right to erasure of your personal data when it
is no longer necessary to retain it
5.
Right to withdraw your consent at any given
time, where consent was the lawful basis for processing the data
6.
Right to restrict personal data processing
7.
Right to request the transfer of your personal
data to another data controller or processor
8.
Rights in relation to automated decision making
and profiling (not used by Wood Energy Wales).
For more information on your rights as individuals, please
visit the ICO website.
FURTHER
PROCESSING
If we wish to use your personal data for a new purpose, that
isn’t covered in this privacy notice, we will provide you with a new notice and
explanation.
CHANGES TO
OUR PRIVACY NOTICE
We reserve the right to update this privacy notice from time
to time, and we will provide you with a new privacy notice when we make any
substantial changes. Please check back frequently to see any updates or
changes.
DATA BREACH PROCEDURE
Should any data under Wood Energy Wales control be breached
in any way, E & R Owen Au Gwmni Trading as Wood Energy Wales will
immediately inform The ICO, the Police and you the client.