Moray West Privacy Policy

INTRODUCTION

Moray Offshore Windfarm (West) Limited (Registered Number 10515140) (“we, us, our”) is committed to protecting your personal data.

This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

By using our website, you are agreeing to be bound by this policy.

In this policy, references to “you” and “your” are to users of our website or otherwise persons who interact with us.

1. Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data through your use of this website or otherwise when you interact with us, including any data you may provide through this website when you register your interest in our offshore windfarm project on our website, contact us via our website or through any other form of communication channel. It also sets out if you have any queries or concerns about this information.

It is important that you read this privacy policy together with any other:

legal notices or terms and conditions provided or made available to you on other pages of our website;
other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

This privacy policy supplements other notices and privacy policies and is not intended to override them.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

Moray Offshore Windfarm (West) Limited (Registered Number 10515140) is the controller and responsible for your personal data.

We are registered with the ICO as a data controller.

We have appointed our Head of Legal as our data privacy officer. She is responsible for overseeing questions in relation to this policy. If you have any questions about this privacy policy, please contact our Head of Legal using the details set out below.

Contact Details

If you have any questions about this privacy policy or our privacy practices, please contact our Head of Legal in the following ways:

Full name of legal entity: Moray Offshore Windfarm (West) Limited

Email address: Claire.Stewart@edpr.com

Postal address: 5th Floor, Atria One, 144 Morrison Street, Edinburgh, EH3 8EX.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in March 2020.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together in certain categories below. The types of information that we may collect from you depends on your use of our website and how you interact with us whether by post, phone, e-mail, face-to-face, social media or otherwise. We may collect personal information about yourself which is not business related, for example personal phone number, address and e-mail address if you approach us (whether directly or indirectly) to express your interest in a vacancy or other opportunity in our project via our website.

Please take care when submitting information to us, particularly when completing free text fields or uploading content, documents and other materials. Some of our services may be automated and we may not recognise that you have accidentally provided us with incorrect or sensitive information.

Whenever you interact with us (or third parties acting on our behalf), you may be asked to provide us with information relating to you. The following types of data may be collected from you:

Identity Data includes your name, last name, title and date of birth;
Contact Data includes your address, e-mail address and telephone numbers (business and personal);
Technical Data includes your IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website and other technical information which tells us about how you use our website);
Geographic Data includes your geographic location (country/territory where you are living and/or working);
Business Data includes your job title, role, name of your employer/company and the industry sector of where you work;
Enquiry Data includes information that you provide us when: using the ‘contact us’ section of our website or when completing a form on our website; contacting us via telephone, e-mail or our social media channels; you visit us at a public event, industry event, exhibition or other forum.
Recruitment Data includes the content of your CV and covering letter where you contact us (whether directly or indirectly) regarding a vacancy with us; and
Other Data: any other information relating to you which you may provide to us.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Interactions with us

you may give us your Identity, Contact, Business Data and other types of data (including personal data) when filling in forms or by corresponding with us by post, phone, e-mail, face-to-face, social media or otherwise.

Automated technologies or interactions.

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, digital analytics (Google), server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy [https://www.moraywest.com/cookie-policy] for further details.

Third parties or publicly available sources.

We may receive personal data about you from various third parties which include:

Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.
Identity, Contact and Technical Data from your social media account if you interact with us on our LinkedIn, Twitter or YouTube social media page.
Identity and Contact Data and other personal data from third parties acting on our behalf.

4. How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason for doing so.
This will be for one of the following reasons:

For the performance (or pre-performance) of any contract with you or the business you represent;
To comply with our legal, regulatory and contractual obligations;
For our legitimate interests or those of a third party and your interests and fundamental rights do not override those interests; and
Where you have given consent.

Most commonly, we will use your personal data that you have provided to us (whether directly or indirectly) in the following circumstances:

Communications

To respond to your queries, feedback or concerns and/or to provide the information and/or assistance that you have requested;

Contract or supply chain opportunities

To explore potential contracting or other project opportunities with you (whether through negotiations or otherwise) and to promote any such opportunity on our website.

Recruitment

Where you apply for, or otherwise contact us regarding, a vacancy in our project, which may lead to potential exploration by us of alternative roles within the project which we believe are likely to interest you;

Project Updates

To keep you updated on our project’s progress;

Events

If you wish to attend one of our events, we will use your personal data to organise and/or manage the event you have registered to attend;

Our Business Purposes

To administer and protect our business and this website including:

to manage our business;
for record keeping, troubleshooting, data analysis, internal reporting and research purposes;
to ensure network and information security;
to notify you about changes to our services and Terms of Use;
to investigate any complaint you make;
to analyse how our website is being used;
to customise various aspects of our website to improve your experience;
to host, maintain and otherwise support the operation of our website;
for risk management purposes;
for business and disaster recovery (e.g. to create back-ups);
for document retention/storage purposes;
to protect our rights, property, and/or safety, our personnel and others;
to establish, exercise or defend our legal rights, including where we reasonably consider it is in our (or others) legitimate interests;
to comply with any procedures, law and regulations which apply to us including where we reasonably consider it is in our (or others) legitimate interests to comply.

In addition, we may use your personal data for further specific purposes made clear at the point of collection on our website.

If you choose not to provide personal data requested by us, we may not be able to provide you with the information and/or services you have requested or otherwise fulfil the purpose(s) for which we have asked for your personal data. Aside from this, your visit to our website will remain unaffected.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before adding you to any mailing list of ours via email. You have the right to withdraw consent to such communications by contacting us.

5. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy [https://www.moraywest.com/cookie-policy].

6. Who we may share your personal information with

We may have to share your personal data with the third parties set out below for the purposes set out in this privacy policy:

Internal third parties

other companies within our group based within the EEA and the UK and the project company of our sister project Moray East offshore windfarm project (Moray Offshore Windfarm (East) Limited);

External third parties, which include:

Google Analytics: Our website uses Google Analytics, a web analysis service provided by Google Inc. ("Google"). Google Analytics works using cookies. Please refer to our cookie policy [https://www.moraywest.com/cookie-policy] for more information.
IT and system administration service providers based within the EEA and UK;
service providers such as solicitors, consultants and accountants;
our suppliers of technical, support, analysis and installation services;
our insurers;
our security providers and cloud services providers;
courts, parties to litigation and their professional advisers where we reasonably deem it necessary in connection with the establishment, exercise or defence of legal claims;
third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
third party providers of social media platforms;
Governmental, local or regulatory bodies such as Marine Scotland (a directorate within the Scottish Government); and
members of the project’s supply chain.

Other than as set out above, we will only disclose your personal data when you direct us or give us permission, when we are required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International Transfers

Our external third parties may be based outside the UK or the EEA. Whenever we transfer your personal data out of the UK or the EEA, we ensure that adequate safeguards have been put in place to protect your personal information.
This means that we will:

(a) ensure that the country in which your personal information will be handled has been deemed “adequate” by the European Commission under Article 45 of the General Data Protection Regulation (GDPR);

(b) include standard data protection clauses approved by the European Commission for transferring personal information outside the EEA into our contracts with those third parties (these are the clauses approved under Article 46.2 of the GDPR); or

(c) (in the case of transfers from the EEA to the USA), ensure that the recipient of the personal information has certified with the US-EU Privacy Shield Framework, as permitted by Article 46.2 of the GPDR.

8. How secure is my data?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Unfortunately, no transmission of information over the internet can be completely secure, and you should also note that the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect account information and passwords, so please take care to protect this information.

9. How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. However, we may be obliged to store some of your information for a longer time, taking into account factors including:

legal obligation(s) under applicable law to retain data for a certain period of time;
statute of limitations under applicable law(s);
(potential) disputes and
guidelines issued by relevant data protection authorities.

Whilst we continue to process your information, we will ensure that it is treated in accordance with this privacy policy. Otherwise, we securely erase your information once this is no longer needed.

[We store the information collected by Google Analytics for 24 months from website visit.]

Details of retention periods are available in our retention policy which you can request from us by contacting us.
You can ask us to delete your data: see “Your Legal Rights” section below for further information. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. Your Legal Rights

Under certain circumstances, you have various rights in relation to your personal data under data protection laws. If you wish to exercise any of these rights, please contact us using the details at the start of this policy.

Procedural matters

(A) No fee is usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

(B) What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Legal Rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
As stated above, you also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the details at the start of this notice.

Confidentiality

We acknowledge that the information you provide may be confidential. We do not sell, rent, distribute or otherwise make your personal data commercially available to any third party, except that we may share information with our service providers for the purposes set out in this privacy policy. We will maintain the confidentiality of and protect your information in accordance with our privacy policy and all applicable laws.