Envirotech Group of Companies takes privacy very seriously. We are committed to protecting and respecting your personal information and privacy. We promise that we will not sell your data or release your personal details to any outside company for their mailing or marketing purposes.
This privacy notice sets out the basis on which any personal data we collect from you, or that you provide to us, when you use our website, receive any services and/or through other interactions and communications you have with any companies within the Envirotech Group, and how this information may be processed by us. This may include subcontractor questionnaire, credit account form or otherwise and that we obtain through third party sources, including how we share it with third parties.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using our products and/or services, you are accepting and consenting to the practices described in this notice.
You may withdraw your consent to this processing at any time by contacting the Data Protection Officer (DPO), as detailed below. If you do withdraw your consent, we will be unable to provide services to you or process your application to register for services.
If you are unhappy with the way in which we are processing your personal data under this notice, then please contact the DPO to discuss this further.
When you use the services or enquire for information from any company within the Envirotech Group of Companies, through consulting with our team by phone, email, through our website or otherwise, you’re voluntarily giving us information which is required to open an account or receive a quotation/information. The information we usually require will include full names, email address, company address, telephone number, company registration number, unique tax reference, bank account details, competency certification and other relevant documentation.
We will take reasonable steps to ensure that the personal information we collect is accurate, complete, up- to-date and relevant. We encourage you to help us by telling us immediately if you change your contact details (such as your phone number or address). After notice from you, we will take reasonable steps to correct any of your information which is inaccurate, incomplete or out of date.
If you wish to have your personal information deleted please let us know and we will delete that information wherever practicable. We may refuse your request to access, amend or delete your personal information in certain circumstances. If we do refuse your request, we will give you reasons for our decision.
We will take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure.
We will only use your personal information for the following purposes:
In connection with these purposes, we may share your personal information with third parties that perform services on our behalf, such as business partners (including insurance providers, third party IT and software providers and credit reference agencies), fraud sharing organisations, and to other companies in our group, in each case within the European Economic Area and the UK.
We may also disclose your personal information to third parties in other circumstances:
Our legal basis for these uses of your personal information may include that (a) it is necessary for our legitimate interests in operating our business and/or providing you with goods and services; and/or (b) it is necessary for the performance of contracts to which you are a party with us.
All information you provide to us is held on secure servers or in the cloud. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
You have various rights under data protection law regarding the processing of your personal information, including the right to:
You can make a request to us in relation to these rights at any time by contacting the DPO, as detailed below. Any information to which you are entitled will be provided within a reasonable timeframe, subject to the exemptions stipulated in application data protection laws.
We will keep your personal data for as long as is necessary for the provision and administration of the relevant services being provided; taking into consideration account information needed for product guarantee or recall purposes, applicable legal requirements and limitation periods.
Our partners will keep any of your data stored on their systems for as long as is necessary to provide the relevant services to you.
If you have any queries about how we use your personal information or would like to withdraw your consent, or advise you data is incorrect, please contact the Data Protection Officer (DPO) via the following means:
Post: Deborah Ingley, Envirotech Group of Companies, 26 Roman Way, Coleshill, Birmingham, B46 1HQ
Telephone: 0845 671 8271
Please check back frequently to see any updates or changes to this privacy notice.
Envirotech Group of Companies is committed to protecting the rights and freedoms of data subjects and safely and securely processing their data in accordance with all our legal obligations. We hold personal data about our employees, clients, suppliers and other individuals for a variety of business purposes. The group is not required to register as a data controller with the Information Commissioners Office (ICO).
This policy sets out how we seek to protect personal data and ensure that our staff understand the rules governing their use of the personal data to which they have access in the course of their work. In particular, this policy requires staff to ensure that the Data Protection Officer (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.
|Business purposes||The purposes for which personal data may be used by us:
Personnel, administrative, financial, regulatory, payroll and business development purposes.
Business purposes include the following:
– Compliance with our legal, regulatory and corporate governance obligations and good practice.
– Gathering information as part of investigations 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 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 and disciplinary matters.
– Marketing our business.
– Improving services.
|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.
|Special categories of personal
|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.
|Data controller||‘Data controller’ means the person or organisation 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.
|‘Processor’ means a natural or legal person, public authority, agency or other body which processes
personal data on behalf of the controller.
|Processing||‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means or manually.
This may include collecting, recording, organising, structuring, storing, adapting, retrieving, consulting,
using, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing or destroying.
This policy applies to all employees, who must be familiar with this policy and comply with its terms. Failure to do so may result in disciplinary action. This policy also extends to external organisations and individuals working on behalf of Envirotech Group of Companies.
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 all employees and uploaded on Access HR.
As our data protection officer (DPO), Deborah Ingley, has overall responsibility for the day-to-day implementation of this policy. You should contact the DPO for further information about this policy if necessary.
DPO Contact Details
Post: Deborah Ingley, Envirotech Group of Companies, 26 Roman Way, Coleshill, Birmingham, B46 1HQ
Phone: 0845 671 8271
Envirotech Group of Companies shall comply with the principles of Data Protection Act (DPA) 2018 and the General Data Protection Regulation (GDPR). We will make every effort possible in everything we do to comply with these principles.
The Principles are:
To comply with data protection laws and the accountability and transparency Principle of GDPR, we must demonstrate compliance.
Envirotech Group of companies is committed to ensure all employees understand the responsibilities to ensure the following data protection obligations are meet:
Fair and lawful processing
Envirotech Group of Companies will 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.
If you are in any doubt about how we handle data, contact the DPO for clarification.
Lawful basis for processing data
Envirotech Group of Companies must establish a lawful basis for processing data. Ensuring that any data the group is responsible for managing has a written lawful basis approved by the DPO. It is the individual’s responsibility to check the lawful basis for any data they are working with and ensure all actions comply with the lawful basis. At least one of the following conditions must apply whenever personal data is processed:
Individual’s making an assessment of the lawful basis, must first establish that the processing is necessary. This means the processing must be a targeted, appropriate way of achieving the stated purpose. Lawful basis cannot be relied upon if you can reasonable achieve the same purpose by some other means.
Remember that more than one basis may apply, and the best fit for the purpose should be relied upon, not what is easiest. The following factors should be considered and documented:
Our commitment to the first Principle requires us to document this process and show that we have considered which lawful basis best applies to each processing purpose, and fully justify these decisions.
The Privacy Statement informs individuals of the lawful basis for processing their data, as well as the intended purpose. This applies whether we have collected the data directly from the individual, or from another source.
Employees who are responsible for making an assessment of the lawful basis and implementing the privacy notice for the processing activity, must have approval from the DPO.
Special categories of personal data
Previously known as sensitive personal data, this means data about an individual which is more sensitive, so requires more protection. This type of data could create more significant risks to a person’s fundamental rights and freedoms, for example by putting them at risk of unlawful discrimination. The special categories include information about an individual’s:
In most cases where we process special categories of personal data we will require the data subject’s explicit consent to do this unless exceptional circumstances apply, or we are required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work). Any such consent will need to clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed.
The condition for processing special categories of personal data must comply with the law. If we do not have a lawful basis for processing special categories of data that processing activity must cease.
Envirotech Group of Companies responsibilities:
Responsibilities of the Data Protection Officer:
Responsibilities of the IT Manager:
Accuracy and relevance
We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.
Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform the DPO.
Personal data must be kept securely. Individuals have a responsibility to ensure date is not unauthorised, unlawfully accessed, altered, mislaid, lost, misused, destroyed or damaged. Where other organisations process personal data as a service on our behalf, the DPO will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.
Storing data securely
We must retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each case, taking into account the reasons that the personal data was obtained, but should be determined in a manner consistent with our data retention guidelines.
Transferring data internationally
There are restrictions on international transfers of personal data. You must not transfer personal data abroad, or anywhere else outside of normal rules and procedures without express permission from the DPO.
Right of individuals
Individuals have rights to their data which we must respect and comply with to the best of our ability. We must ensure individuals can exercise their rights in the following ways:
Subject Access Requests
An individual has the right to receive confirmation that their data is being processed, access to their personal data and supplementary information that Envirotech Group of Companies hold on them.
We will provide an individual with a copy of the information the request, free of charge. This must occur without delay, and within one month of receipt. We endeavour to provide data subjects access to their information in commonly used electronic formats, and where possible, provide direct access to the information through a remote accessed secure system. Employees can access information held by the company through the Access HR system.
If complying with the request is complex or numerous, the deadline can be extended by two months, but the individual must be informed within one month. You must obtain approval from the DPO before extending the deadline.
If any person receives a subject request for any company named under Envirotech Group of Companies, the request must be immediately forwarded to the DPO.
We can refuse to respond to certain requests, and can, in circumstances of the request being manifestly unfounded or excessive, charge a fee. If the request is for a large quantity of data, we can request the individual specify the information they are requesting. This can only be done with express permission from the DPO.
Once a subject access request has been made, you must not change or amend any of the data that has been requested. Doing so is a criminal offence.
Data portability requests
We must provide the data requested in a structured, commonly used and machine-readable format. We must provide this data either to the individual who has requested it, or to the data controller they have requested it be sent to. This must be done free of charge and without delay, and no later than one month. This can be extended to two months for complex or numerous requests, but the individual must be informed of the extension within one month and you must receive express permission from the DPO first.
Right to erasure
Individuals have a right to have their data erased and for processing to cease in the following circumstances:
We can only refuse to comply with a right to erasure in the following circumstances:
If personal data that needs to be erased has been passed onto other parties or recipients, they must be contacted and informed of their obligation to erase the data. If the individual asks, we must inform them of those recipients.
The right to object
Individuals have the right to object to their data being used on grounds relating to their particular situation. We must cease processing unless:
We may only carry out automated profiling or decision making that has a legal or similarly significant effect on an individual in the following circumstances:
In these circumstances, we must:
Using third party controllers and processors
As a data controller we must have written contracts in place with any third-party data controllers and/or data processors that we use. The contract must contain specific clauses which set out our and their liabilities, obligations and responsibilities.
As a data controller, we must only appoint processors who can provide sufficient guarantees under GDPR and that the rights of data subjects will be respected and protected.
Our contracts must comply with the standards set out by the ICO and, where possible, follow the standard contractual clauses which are available. Our contracts with data controllers and/or data processors must set out the subject matter and duration of the processing, the nature and stated purpose of the processing activities, the types of personal data and categories of data subject, and the obligations and rights of the controller.
At a minimum, our contracts must include terms that specify:
Criminal offence data
Any criminal record checks are justified by law. Criminal record checks cannot be undertaken based solely on the consent of the subject. We cannot keep a comprehensive register of criminal offence data. All data relating to criminal offences is considered to be a special category of personal data and must be treated as such. You must have approval from the DPO prior to carrying out a criminal record check.
The DPO will conduct regular data audits to manage and mitigate risks. This inform will be recorded on the data register. This contains information on what data is held, where it is stored, how it is used, who is responsible and any further regulations or retention timescales that may be relevant.
Everyone must observe this policy and comply with this policy fully at all times. The DPO has overall responsibility for this policy. Envirotech Group of Companies will keep this policy under review and amend or change it as required. You must notify the DPO of any breaches of this policy.
All employees are provided with data protection training as part of their induction. If employees take on new roles or responsibilities, they are responsible for requesting new data protection training relevant to the new role or responsibilities.
If you require additional training on data protection matters, contact the DPO.
Any breach of this policy or of data protection laws must be reported as soon as you have become aware of a breach or as soon as is practically possible, to the DPO.
All employees have an obligation to report actual or potential data protection compliance failures. This allows us to:
Any employee who fails to notify of a breach or is found to have known or suspected a breach has occurred but has not followed the correct reporting procedures may be liable to disciplinary action.
Envirotech Group of Companies has a legal obligation to report any data breaches to ICO within 72 hours. The DPO process the notification via the ICO website.
The DPO will alert any reported breaches to the Directors.
The DPO will investigate the report and determine whether a breach has occurred. The DPO will consider whether personal data had been accidentally or unlawfully:
The DPO will make all reasonable efforts to contain and minimise the impact of the breach, assisted by relevant employees and/or third-party providers, where necessary.
The DPO will assess the potential consequences, based on how serious the breach is and how likely they are to reoccur.
The DPO will decide whether the breach must be reported to the ICO. This will be determined on a case by case basis, by considering if the breach is likely to negatively affect people’s rights and freedom or cause people any physical, material or non-material damage (emotional stress), through:
If it is likely that there will be a risk to people’s rights and freedoms, the DPO must notify the ICO.
The findings of the investigation and the decision must be documented and stored. This is in case it is challenged by the ICO or an individual affected at a later date.
The DPO will assess the risk to each individual concerned based on the severity of the breach and the likelihood of potential or actual impact. If this risk is high, the DPO will notify all individuals concerned, in writing, immediately.
The DPO will notify any third-parties who can assist to mitigate the risk/loss to individuals. These may include:
The Directors will review each case as soon as reasonably possible, to understand what happened and changes will be implemented to mitigate future breaches.
Failure to comply
We take compliance with this policy very seriously. Failure to comply puts Envirotech Group of Companies and all known associates at risk; including all employees. The importance of this policy means that failure to comply with any requirement may lead to disciplinary action under our procedures which may result in dismissal.
If you have any questions or concerns about anything in this policy, do not hesitate to contact the DPO.