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Privacy Policy

The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Directive (Directive 95/46/EC).

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The General Data Protection Regulation builds on previous legislation but enhances privacy rights for individuals.  The GDPR will apply in the UK from 25th May 2018.

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Despite the UK’s intention to leave the European Union in March 2019 the GDPR will still apply in accordance with the Information Commissioner’s Office (ICO) guidance to continue a similar level of regulation post March 2019 together with a new Data Protection Act.

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SOA Energy is dedicated to being responsible when collecting and using your personal data. The privacy policy below outlines how we will adhere to the GDPR. Your GDPR specific rights will come into effect once the GDPR becomes law on 25th May 2018.

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This policy will outline:

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  • The details of the Data Controller and how to contact the Data Protection Officer(DPO)

  • The types of personal data we collect and how we use it

  • Our purpose and legal basis for processing your data

  • How and when we share data with SOA Energy suppliers and partners

  • How and when we use your data for marketing purposes

  • Our use of cookies and your preferences with use of cookies

  • Your rights to request your personal data and how to do so

  • How you can raise a complaint with the ICO

 

Who controls my personal data?

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  • The Data Controller is SOA Energy 

  • SOA Energy is a UK registered company 

  • The registered address is 1st Floor, 25 Berkeley Square, London, W1J 6HN

  • The Data Controller’s representative is the Data Protection Officer (DPO)

  • You can contact the DPO by email dpo@soaenergy.com 

 

What data will you give to us or will we collect from you?

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  • You provide us with your personal data by filling in forms, by corresponding with us by phone, e-mail or otherwise, by subscribing to our services, sharing your details at meetings with us, attending our events, participating in discussion boards or other social media functions on our website or online, by entering a competition, promotion, or survey or by reporting a problem with our site or by voluntarily providing your personal information directly to SOA Energy Management at any other time e.g. giving us your business card

  • The types of personal data we collect may vary according to its purpose, we typically collect information such as: your full name, telephone number, email address, postal address, and Curriculum Vitae. We will also record any other relevant professional or personal information which is relevant to your career situation and how we might help you e.g. salary details

  • Personal Data may also include links to professional sites such as LinkedIn, Twitter, or a corporate website

 

What Information do we obtain from other sources?

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  • We may obtain information about you from other sources such as our franchisees, our licensees and suppliers, your employer, your business card, personal recommendations

  • We will let you know we are holding your data by sending you this privacy policy within a maximum of 30 days of collection

 

What are the purposes and legal bases for our processing?

 

We use information held about you in the following ways:

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  • To carry out our obligations arising from any contracts we intend to enter or have entered between you and us and to provide you with the information, products, and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation

  • Our main legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation, and consent for specific uses of data

  • We will rely on contract if we are negotiating or have entered into an agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation

  • We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligation, for example, our statutory obligation as an employer

  • We will in some circumstances rely on consent for uses of your data and you will be asked for your express consent 

 

Our Legitimate Business Interests

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  • To manage employee and contractor relationships

  • To manage our corporate rights and obligations

 

Consent

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  • Should we want or need to rely on consent to lawfully process your data we will request your consent, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this processing at any time

 

Other uses we will make of your data:

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  • To notify you about changes to our services;

  • To ensure that content from our site is presented in the most effective manner for you and for your computer

  • To administer our site and for internal operations, including troubleshooting, security, data analysis, testing, research, statistical and survey purposes

  • To allow you to participate in interactive features of our service, when you choose to do so

  • To measure or understand the effectiveness of our advertising that we serve to you and others, and to deliver relevant advertising to you

  • We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process

 

Who will have access to your data inside and outside of European Economic Area (EEA)?

 

We will share your personal information with selected third parties including:

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  • Our data processors, licences, franchisees, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter with them or you

  • We will not disclose your personal information to third parties except if we sell or buy any business or assets, in which case we may disclose some of your personal data to the prospective seller or buyer of such business or assets for due diligence or substantially all our assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets

 

The lawful basis for the third-party processing will include:

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  • Their own legitimate business interests in processing your personal data, in most cases to fulfil their contractual obligations to us

  • To fulfil their legal obligations

 

Will your data be used for marketing?

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  • We will only send you information about our products and services that are relevant to you

  • We may send the communication in several ways including email, telephone, and post

 

What are cookies and how do they affect your personal data? 

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  • Our cookies track site visitor’s basic information to better tailor the site to our visitor’s needs and improve their customer experience

  • Most web browsers automatically accept cookies; however, you can disable cookies in your web browser if you wish. Please be aware disabling cookies will affect the functionality of our website and you may disable other features on the website. We recommend you do not disable cookies, in case they are used to provide a service that you use

  • For more information about the cookies we use, please see our cookie policy.

 

Where will we store and process your personal data?

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  • All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. 

  • The data that we collect from you may be digitally transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may be transferred to third parties outside of the EEA for the purposes of our services. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and UK and EU data protection law, including contractual clauses

 

How long will we retain your data?

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  • We understand our legal duty to retain accurate data that you are happy for us to retain and only retain personal data for as long as we need it for our legitimate business interests or to satisfy legal, accounting or reporting requirements. Accordingly, we have a data retention policy and run regular data routines to remove data that we no longer have a legitimate business interest in maintaining

 

We do the following to try to ensure our data is accurate:

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  • We may archive part or all your personal data or retain it on our financial systems. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so

  • For your information, pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms

  • Our current retention policy is available upon request

 

Changes to this Privacy Policy

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  • Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy

 

How safe is your data?

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  • Appropriate technical and organisational measures are taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data

  • We use electronic safeguards including firewalls, anti-virus and anti-malware software to protect your data

  • Only authorised staff have access to personal data and are appropriately trained and supported by policies and procedures for handling personal data

 

What are your rights to your personal data?

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  • You have the right to request copies of any personal data held by us.

  • To receive a copy of your personal data please send your written request to the Data Controller, SOA Energy, 1st Floor, 25 Berkeley Square, London, W1J 6HN

  • We will provide you with a hard copy of your personal data held

  • You will not be charged for your personal data request

  • Your data will be returned within 40 days of receiving the request

  • We will require proof of identity

  • You also have the right to the following:

    • The right to prevent data being processed for direct marketing

    • The right to have inaccurate personal data rectified, erased, or destroyed

    • You have the right to make a complaint to a supervisory body, which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/

 

When the GDPR comes into force you will have the following additional rights, subject to the GDPR:

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  • The right to object to processing that is likely to cause, or is causing damage or distress.

  • The right to object to decisions being taken by automatic means.

  • The right to have inaccurate personal data suppressed, rectified, blocked, erased, or destroyed.

  • You can enforce these rights by contacting the Data Controller.

 

Last Reviewed: 23/11/2022

Next Review: 22/11/2023

Reviewed by: Nicholas Moore-Searson 

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