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Data Protection Policy

About This Policy:

  • Renewr Ltd needs to gather and use certain information about individuals.
  • This can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.
  • This Policy is designed to ensure compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and any other applicable data protection legislation.

Data Protection Law

  • The UK GDPR and the Data Protection Act 2018 describe how organisations, including Renewr Ltd, must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically or otherwise.
  • To comply with the law, personal information must be;
    • processed lawfully, fairly and in a transparent manner in relation to individuals;
    • collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be incompatible with the initial purposes;
    • adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
    • accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
    • kept in a form which permits identification of data subjects no longer than is necessary for the purposes for which the personal data is processed;
    • processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

Record Keeping:

  • A range of information must be detailed in our internal records of processing activities. Such areas include;
    • name and details of the organisation
    • details of other data controllers, the organisation’s representative and any Data Protection Officer (where applicable)
    • purposes of processing the data
    • description of the categories of individuals and the categories of personal data
    • categories of the recipients of personal data
    • details of transfers of data to third parties or abroad, including details of safety mechanisms
    • retention schedules
    • technical and organisational security measures
  • Renewr Ltd ensures that personal data will only be retained for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting and business requirements. Where applicable, customer records will normally be retained for a minimum of six years to comply with FCA record-keeping obligations and other legal requirements. Once no longer required, personal data will be securely deleted or irreversibly anonymised.

Lawful Basis For Processing Data:

  • Renewr Ltd processes personal data under one or more lawful bases depending on the nature and purpose of the processing activity. These may include Contract, Legal Obligation, Legitimate Interests, Consent and, where appropriate, Vital Interests. The applicable lawful basis is identified within our Record of Processing Activities and Privacy Notices.
  • The lawful bases for processing are set out in Article 6 of the UK GDPR. At least one of these must apply whenever Renewr Ltd process personal data:
  • Processing is lawful under UK GDPR as:
    • Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
    • Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
    • Legal obligation: processing is necessary for you to comply with the law (not including contractual obligations).
    • Vital interests: processing is necessary to protect someone’s life.
    • Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
    • Legitimate interests: processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)
  • Special categories of data may be captured by Renewr Ltd for example, information about an individual:
    • race;
    • ethnic origin;
    • health;
    • political opinions;
    • genetic data;
    • sex life;
    • trade union membership;
    • biometrics (where used for ID purposes);
  • Where Renewr Ltd processes criminal conviction data or data about offences, a lawful basis for general processing and an additional condition for processing this type of data will be identified.
  • Where criminal offence data is processed, Renewr Ltd will identify an appropriate Article 6 lawful basis together with the relevant Schedule 1 condition under the Data Protection Act 2018.

Responsibilities:

  • Although Renewr Ltd is not required to appoint a Data Protection Officer (DPO) under the UK GDPR, the Directors are responsible for overseeing compliance with data protection legislation and fulfilling the duties that would ordinarily fall within the remit of a DPO.
  • The Directors are responsible for:
    • ensuring that appropriate data protection policies, procedures and controls are implemented and maintained;
    • ensuring compliance with the UK GDPR, the Data Protection Act 2018 and other applicable data protection legislation;
    • maintaining records of processing activities where required;
    • ensuring appropriate technical and organisational security measures are in place;
    • assessing and responding to personal data breaches; and
    • ensuring staff receive appropriate data protection training and guidance.
  • All employees are responsible for:
    • complying with this Policy and any related procedures;
    • only accessing personal data where it is necessary for their role;
    • keeping personal data secure and confidential at all times;
    • promptly reporting any actual or suspected personal data breach, loss or unauthorised disclosure to the Directors;
    • ensuring personal data is processed lawfully, fairly and securely; and
    • completing any mandatory data protection training provided by Renewr Ltd.

Data Protection Impact Assesments (DPIA):

  • Renewr Ltd has a general obligation to implement technical and organisational measures to demonstrate that data protection is integrated into our processing activities. A Data Protection Impact Assessment is conducted each time Renewr Ltd consider implementing new technologies.
  • The DPIA will pertain at least;
    • a description of the processing operations and the purposes, including, where applicable, the legitimate interests pursued by the controller;
    • an assessment of the necessity and proportionality of the processing in relation to the purpose;
    • an assessment of the risks to individuals;
    • measures in place to address risk, including security and to demonstrate that you comply.

Individuals Rights:

  • Individuals now have more rights under UK GDPR, these are;
    • the Right to be Informed
    • the Right of Access
    • the Right to Rectification
    • the Right to Erasure
    • the Right to Restrict Processing
    • the Right to Data Portability
    • the Right to Object
    • rights in relation to automated decision making and profiling.
  • Renewr Ltd provide every customer with a Privacy Notice at the point data is captured.
  • The information supplied in this notice demonstrates how Renewr Ltd is transparent over our data processing. The notice is;
    • concise, transparent, intelligible and easily accessible;
    • written in clear and plain language, particularly if addressed to a child; and free of charge.
  • We include details of (but not limited to);
    • the Data Controller, the lawful reason for processing data, if any third parties have legitimate interests, categories of personal data, categories of recipients such as banks and credit unions, the data retention periods,
    • the individuals’ rights; including the right to withdraw, where the individual can complain about how the data is processed with a supervisory authority, source of data when it comes from a third party and where personal data is part of a contractual requirement or obligation.
    • The Privacy Notice is reviewed periodically to ensure it remains accurate and reflects current processing activities.

Rectification:

  • Individuals are entitled to have personal data rectified if it is inaccurate or incomplete. If Renewr Ltd has disclosed the personal data in question to third parties, then we will inform them of the rectification where possible.
  • Renewr Ltd will respond to this request within one month or extended by two months where the request for rectification is complex.

Erasure:

  • Individuals have a right to have personal data erased and to prevent processing in specific circumstances;
    • where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
    • when the individual withdraws consent.
    • when the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
    • the personal data was unlawfully processed (i.e. otherwise in breach of the UK GDPR).
    • the personal data must be erased to comply with a legal obligation.
    • the personal data is processed in relation to the offer of information society services to a child.
    • under the UK GDPR, this right is not limited to processing that causes unwarranted and substantial damage or distress. However, if the processing does cause damage or distress, this is likely to make the case for erasure stronger.
  • Renewr Ltd may refuse to comply with a request for erasure where the personal data is processed for the following reasons;
    • to exercise the right of freedom of expression and information;
    • to comply with a legal obligation for the performance of a public interest task or exercise of official authority.
    • for public health purposes in the public interest;
    • archiving purposes in the public interest, scientific research historical research or statistical purposes; or
    • the exercise or defence of legal claims.
  • If Renewr Ltd has disclosed the personal data in question to third parties, a notification will be sent, informing them about the erasure of the personal data, unless it is impossible or involves disproportionate effort to do so.

Restrict Processing:

  • Renewr Ltd will restrict the processing of personal data in the following circumstances;
    • where an individual contests the accuracy of the personal data, you should restrict the processing until you have verified the accuracy of the personal data.
    • where an individual has objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and you are considering whether your organisation’s legitimate grounds override those of the individual.
    • when processing is unlawful, and the individual opposes erasure and requests restriction instead.
    • if you no longer need the personal data but the individual requires the data to establish, exercise or defend a legal claim.
  • If any data has been disclosed to third parties, Renewr Ltd will notify them about the restriction on the processing of the personal data, unless it is impossible or involves disproportionate effort to do so.

Portability:

  • For personal data an individual has provided to a controller; where the processing is based on the individual’s consent or for the performance of a contract; and when processing is carried out by automated means, Renewr Ltd must provide the personal data in a structured, commonly used and machine-readable form. Open formats include CSV files. Machine readable means that the information is structured so that software can extract specific elements of the data. This enables other organisations to use the data.
  • Renewr Ltd must provide this service free of charge.
  • If the individual requests it, we may be required to transmit the data directly to another organisation if this is technically feasible. Renewr Ltd will respond without undue delay, and within one month or extended by two months where the request is complex or receives many requests.

Objecting:

  • If an individual has objected to processing data or direct marketing, Renewr Ltd will cease to process the data.
  • Individuals must have an objection on “grounds relating to his or her particular situation”.
  • Renewr Ltd will stop processing the personal data unless;
    • compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or
    • the processing is for the establishment, exercise or defence of legal claims.
  • This is brought to the attention of the data subject at the first point of communication and in our privacy notice. This is separated from any other information.

Direct Marketing Purposes:

  • As soon as an objection is received, Renewr Ltd will stop processing personal data for direct marketing purposes. This will be actioned at any stage and is free of charge.
  • As Renewr Ltd offer an online presence, www.renewr.earth; we offer a way for individuals to object online.

Automated Decision-Making Including Profiling:

  • Renewr Ltd understand that any form of automated processing of personal data is intended to evaluate certain personal aspects relating to a natural person, or to analyse, or predict that person’s performance at work, economic situation, location, health, personal preferences, reliability, or behaviour falls under this right. Where this is conducted, the rules and guidance of the ICO will be adhered to and followed. To date, Renewr Ltd does not conduct automated decision-making, including profiling.

Data Breaches: 

  • Any actual or suspected personal data breach must be reported immediately to the Directors. The Directors will assess whether the breach is reportable to the Information Commissioner’s Office (ICO) within 72 hours and whether affected individuals must also be informed.

Subject Access Requests (SAR):

  • Individuals who are the subject of personal data held by Renewr Ltd are entitled to;
    • confirmation that their data is being processed
    • access to their personal data; and
    • other supplementary information – this largely corresponds to the information that should be provided in a privacy notice
  • When Individuals contact Renewr Ltd requesting this information, this is called a Subject Access Request.
  • Renewr Ltd will provide a copy of the information free of charge. However, a ‘reasonable fee’ may be charged when a request is manifestly unfounded or excessive, particularly if it is repetitive.
  • A reasonable fee may also be charged to comply with requests for further copies of the same information. The fee is based on the administrative cost of providing the information only.
  • Before disclosing personal data, Renewr Ltd may request sufficient information to verify the identity of the individual making the request.
  • The information will be provided within 1 month, this will be extended to 2 months if the request is complex. Notification will be made to the individual if this is the case.

Complaints:

  • It is made clear that data subjects who wish to complain about how their personal data has been processed can raise this with Renewr Ltd complaints procedure. If the data subject is still not happy, then the complaint can be referred to the Information Commissioners Office (ICO). Renewr Ltd will advise all individuals of this right.

Data Security and Storage:

  • When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see or have access to it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason;
    • when not required, the paper or files should be kept in a locked drawer or filing cabinet.
    • employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer;
    • data printouts should be shredded and disposed of securely when no longer required.
  • When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts;
    • data should be protected by strong passwords or encryption products;
    • if data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used;
    • data should only be stored on designated drives and servers and should only be uploaded to an approved cloud computing service provider;
    • servers containing personal data should be sited in a secure location, away from general office space;
    • data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures;
    • data should never be saved directly to laptops or other mobile devices like tablets or smart phones;
    • all servers and computers containing data should be protected by approved security software and a firewall.
  • The point that personal data is accessed is when it can be at greatest risk of loss, corruption, theft, unlawful access, Renewr Ltd will;
    • When working with personal data, employees should ensure the screens of their computers are always locked when left unattended;
    • Personal data should only be transmitted electronically where appropriate safeguards are in place.
    • Where appropriate, personal data must be encrypted before electronic transmission.
    • Personal data must not be transferred outside the United Kingdom unless appropriate safeguards are in place in accordance with Chapter V of the UK GDPR.
    • Employees should not save copies of personal data on their own computers. Always access and update the central copy of any data.
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