1.1 Ecovair Energy Ltd. are committed to protecting the rights and freedoms of data subjects and safely and securely processing their data in accordance with all our legal obligations.
1.2 We hold personal data about our employees, clients, suppliers and other individuals for a variety of business purposes.
1.3 Ecovair Energy Ltd. will maintain relevant records of processing activities; however we employ under 250 people, with considered low risk activities.
2.1 The purposes for which personal data may be used by us:
2.2 Personnel, administrative, financial, regulatory, payroll and business development purposes.
2.3 Business purposes include the following:
- Compliance with our legal, regulatory and corporate governance obligations and good practice
- Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests
- Ensuring business policies are adhered to (such as policies covering email and internet use)
- Operational reasons, such as recording transactions, training and quality control, ensuring the confidentiality of commercially sensitive information, security vetting, credit scoring and checking
- Investigating complaints
- Checking references, ensuring safe working practices, monitoring and managing staff access to systems and facilities and staff absences, administration and assessments
- Monitoring staff conduct, disciplinary matters
- Marketing our business
- Improving services
2.4 Personal Data
‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal data we gather may include: individuals’ phone number, email address, educational background, financial and pay details, details of certificates and diplomas, education and skills, marital status, nationality, job title, and CV.
2.5 Special Categories of Personal Data
Special categories of data include information about an individual’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or condition, criminal offences, or related proceedings, and genetic and biometric information —any use of special categories of personal data should be strictly controlled in accordance with this policy.
2.6 Data Controller
‘Data controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by law.
2.7 Data Processor
‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
3. RESPONSIBILITY & SCOPE
As our data protection officer (DPO), both Directors has responsibility for the day-to-day implementation of this policy. You should contact the DPO for further information about this policy if necessary.
This policy applies to all staff, who must be familiar with this policy and comply with its terms.
This policy supplements our other policies relating to internet and email use. We may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted.
5.1 Ecovair Energy Ltd. shall comply with the principles of data protection (the Principles) enumerated in the EU General Data Protection Regulation. We will make every effort possible in everything we do to comply with these principles. The Principles are:
Lawful, fair and transparent
- Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used.
Limited for its purpose
- Data can only be collected for a specific purpose.
- Any data collected must be necessary and not excessive for its purpose.
- The data we hold must be accurate and kept up to date.
We cannot store data longer than necessary.
Integrity and confidentiality
The data we hold must be kept safe and secure.
5. ACCOUNTABILITY AND TRANSPARENCY
We must ensure accountability and transparency in all our use of personal data. We must show how we comply with each Principle. Ecovair Energy Ltd. are responsible for keeping a written record of how all the data processing activities we are responsible for comply with each of the Principles.
To comply with data protection laws and the accountability and transparency Principle of GDPR, we must demonstrate compliance. You are responsible for understanding your responsibilities to ensure we meet the following data protection obligations:
- Fully implement all appropriate technical and organisational measures
- Maintain up to date and relevant documentation on all processing activities
- Conducting Data Protection Impact Assessments
- Implement measures to ensure privacy by design and default, including:
- Data minimisation
- Allowing individuals to monitor processing
- Creating and improving security and enhanced privacy procedures on an ongoing basis
6. OUR PROCEDURES
Fair and lawful processing
We must process personal data fairly and lawfully in accordance with individuals’ rights under the first Principle. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening.
If we cannot apply a lawful basis (explained below), our processing does not conform to the first principle and will be unlawful. Data subjects have the right to have any data unlawfully processed erased.