Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“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”.
Nu-Wey Limited?
Nu-Wey is primarily an innovation consultancy within the energy efficiency sector, assisting companies and partners in the analysis of their products, testing and analysis, ultimately providing a solution for the end user.
When we are developing a product or process that is innovative, we will carry out relevant testing and trial the product. The data that is collected is analysed and performance conclusions are drawn.
As every product or process is different we look to develop them in best possible way. Each product is assessed and trialled individually. In order to carry out trials we need to collect some of your personal information and share this with other organisations. We will only collect and use personal data in ways that are described here, in a way that is consistent with our objectives for the product or process and your rights under the law.
Nu-Wey is committed to an operating philosophy based on openness in communication, integrity in serving our customers, fairness and concern for our employees and responsibility to the communities within which we operate. Our vision is to exceed customer expectations for quality, safety, sustainability, cost, delivery and value.
Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:
The personal data we collect and use
We collect your data directly and this data may include:
· Your name, address, your date of birth, and your general energy usage methods;
· Proof of identity (which may be collected to evidence a supporting component for the test/trial);
· Copies of documents showing proof of benefits and income utility charges supplied to you by the Department for Work and Pensions and HMRC;
· Your phone number and email address (so you can be contacted as necessary for the Purpose outlined in this notice);
Providing your personal data
We will tell you if providing some of your personal data is optional. In all other cases you must provide your personal data or we will be unable to carry out the testing required for new products and processes.
Using your personal data (legal basis and Purpose)
We will process your personal data:
· As necessary to fulfil our contract with you, eg.
o to manage and undertake the contract (including the installation of a product or process into your property and trialling its performance).
· As necessary to pursue our legitimate interests, eg.
o to check you are eligible for the trial;
o to share your data with third parties who administer, support or enforce the trial (as specified under ‘Sharing your personal data’).
o to collect the financial amount you have contributed towards the cost of the product if applicable.
· As necessary to comply with a legal obligation, eg.
o where you exercise your rights to make requests under data protection law.
In some circumstance we may need to process special categories of data (eg. Information related to your health and your daily energy usage). In these cases, we will provide you with separate information showing you how we will process your data and the legal basis under which we are processing it.
Consent
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.
Consent is required for NU-Wey to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
You may withdraw consent at any time by completing a Data Subject Consent Withdrawal Form (GDPR REC 4.6A) that was provided at the time of signing the consent form. If you do not have a copy of the withdrawal form, you can obtain one by emailing Dr Chandni Patel [cp@nu-wey.co.uk] or requesting via post, our address is:
92 Station Road, Clacton On Sea, Essex, England, CO15 1SG
All requests will be handled in line with Withdrawal of Consent Procedure [GDPR DOC 2.7A] which can be provided upon request.
Disclosure
We will share your personal data with:
· If necessary the Department for Work and Pensions will profile your data in order to provide a YES/NO response via the Energy Saving Trust to verify whether or not you receive the relevant benefits to be eligible for the trial;
· Ofgem and BEIS will:
o use and share your information in order to fulfil its statutory duties;
o if requested, share your information with the installer of the product;
o if necessary, share your information with auditors contracted to ensure the integrity of the scheme.
o when required, disclose your personal information to the Secretary of State of the Department of Business, Energy and Industrial Strategy. They may use some of the data for research and statistical purposes and may, for these purposes, link the data with other data sources they hold.
· The partners (who will make a contribution towards the cost of the measure; and will process data as necessary to comply with a legal obligation and in accordance with their own privacy policies);
· Relevant companies supporting the installation:
o the installer (who installs the measure);
o the installer’s certification body (who monitor a sample of installations to ensure they meet the correct standards);
o technical monitoring agents (who monitor a sample of installations to ensure they meet the correct standards);
o external auditing agencies (who provide assurance that the data being processed is correct);
o building control inspectors (who check installations are installed in accordance with building regulations);
o guarantee companies (who provide warranties for some measures such as wall insulation);
o the property owner, social housing provider, local authority or managing agent (as and where applicable);
o software providers (who process your data).
· Anyone else where it is required by law, or we have your consent.
· The information you provide may be transferred to 3rd parties outside of the European Union. However, this will only take place where this is necessary for the Purpose outlined above. We will ensure all appropriate safeguards, including those set out by the ICO, are in place to protect your data before any transfer takes place.
Retention period
Nu-Wey will process personal data for the sole purpose of the trial, and no longer, and will store the personal data for seven years. For further information regarding the retention period, refer to GDPR DOC 2.3 Retention Period Procedure.
· Retention for measures we may retain your personal data for up to twenty-five years;
· Retention for all other measures: we may retain your personal data for up to seven years after the trial ends, in line with HM Revenue & Customs record management
· The Department for Business, Energy and Industrial Strategy, will hold some information, including your address, but not your name or other personal information, for up to 25 years for statistical purposes.
Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
· Right of access – you have the right to request a copy of the information that we hold about you.
· Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
· Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
· Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
· Right of portability – you have the right to have the data we hold about you transferred to another organisation.
· Right to object – you have the right to object to certain types of processing such as direct marketing.
· Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
· Right to judicial review: in the event that Nu-Wey Limited refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
· Right to complain to the Information Commissioner’s Office - who can investigate compliance with data protection law. See https://ico.org.uk/concerns/
All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.
Can I find out the personal data that Nu-Wey holds about me?
Nu-Wey at your request, can confirm what information we hold about you and how it is processed. If Nu-Wey does hold personal data about you, you can request the following information:
· Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
· Contact details of the data protection officer, where applicable.
· The purpose of the processing as well as the legal basis for processing.
· If the processing is based on the legitimate interests of Nu-Wey or a third party, information about those interests.
· The categories of personal data collected, stored and processed.
· Recipient(s) or categories of recipients that the data is/will be disclosed to.
· If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
· How long the data will be stored.
· Details of your rights to correct, erase, restrict or object to such processing.
· Information about your right to withdraw consent at any time.
· How to lodge a complaint with the supervisory authority.
· Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
· The source of personal data if it wasn’t collected directly from you.
· Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
Your request will be managed in line with our Subject Access Request Procedure [GDPR DOC 2.2], a copy of which will be provided upon request. In order to process your request, you will be required to provide a form of identification, for instance a passport or driving license, to confirm your identity.
Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Nu-Wey (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Nu-Wey’s data protection representatives Data Protection Officer / GDPR Owner.
The details for each of these contacts are:
Supervisory Authority: Information Commissioner’s office, telephone: 0303 123 1113
Nu-Wey: Dr Chandni Patel (Director), [92 Station Road, Clacton On Sea, Essex, England, CO15 1SG], cp@nu-wey.co.uk
You may request a copy of our Privacy Notice via email
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