Low Carbon Contracts Company and Electricity Settlements Company privacy notice
INTRODUCTION
We, Low Carbon Contracts Company, and Electricity Settlements Company, respect your privacy and are committed to protecting your personal data. This privacy notice informs you about how we look after your personal data when you visit our website or communicate with us in any way and tells you about your rights and how the law protects you. You can click through each area set out below.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW YOUR PERSONAL DATA IS COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
1.IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide by signing up to our stakeholder updates, participating at an event, contacting us (through the website, through email or otherwise) or any other such interaction.
This website is not intended for children and we do not knowingly collect data relating to children.
Please read this privacy notice together with any other privacy notice or fair processing notice 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 use your data. This notice supplements other notices and is not intended to override them.
CONTROLLER
Low Carbon Contracts Company and Electricity Settlements Company are the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
CONTACT DETAILS
Our full details are:
Full name of legal entity: Low Carbon Contracts Company LTD and Electricity Settlements Company LTD
Name and title of DPO: Allison Sandle, General Counsel & Company Secretary
Email address: DPO@lowcarboncontracts.uk
Postal address: 10 South Colonnade, Canary Wharf, London, E14 4PU
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 NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 09 August 2020. The data protection law in the UK changed on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) as we are still working towards getting our systems ready for some of these changes.
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 notice 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 as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes postal address, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, 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.
- Profile Data includes your username and password, your interests, feedback, and survey responses.
- Usage Data includes information about how you use our website and tools.
Communications Data includes your preferences in receiving communications from us.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.
We do not collect any Special Categories of Personal Data about you (e.g. details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, data about your health, genetic and biometric data). Nor do we collect any data on criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
If we need to collect personal data, and you fail to provide that data when requested, we may not be able to deliver on an arrangement we have with you. For example, we may have to cancel your place at an event or your subscription to a stakeholder update but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity Data or Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when applying to attend an event], accessing the transparency tool on our website; subscribing to our newsletters, stakeholder updates, publications or similar; requesting communications to be sent to you; entering a survey; or giving us feedback.
- Third parties or publicly available sources. We may receive personal data about you from third parties and public sources as follows.
- Technical data from analytics providers and search information providers.
- Identity and Contact Data from publicly available sources such as Companies House.
- Any other such interactions.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use it as follows:
- Where we need to perform a contract we are about to enter into or have entered into with you.
- Where we need to comply with a legal or regulatory obligation.
If you have signed up for any of our information services, such as stakeholder bulletins, or attended any of our events, you may receive an annual stakeholder survey from a trusted third party acting on our behalf. When sending this out we may rely on legitimate interest, as the survey is used to improve the company’s performance and our services to you. We would rely on consent to send third party direct communications to you via email for any other purpose. You have the right to withdraw consent to communications at any time by Contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out in a table below, a description of all the ways we plan to use your personal data, and the legal bases we rely on to do so. We may process your personal data for more than one lawful ground depending on the specific purpose for which we use your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave feedback or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for the public interest (to keep our records updated and to study how customers use our tools/communications)
To administer and protect us and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for the public interest (to prevent fraud, ensure network security and enable us to continue functioning)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and communications to you and measure or understand the effectiveness of the communications we provide to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Communications
(f) Technical
Necessary for the public interest (to study how users use the tools, communications and information we provide, to improve them and keep you informed)
To use data analytics to improve our website, tools, communications, stakeholder relationships and experiences
(a) Technical
(b) Usage
Necessary for the public interest (to define types of users for our tools, to keep our website updated and relevant, to improve what we offer you and to inform our communications strategy)
To make suggestions and recommendations to you about tools, communications and/or events that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for the public interest (to develop our tools and communications)
COMMUNICATIONS
We strive to provide you with choices regarding certain personal data uses, particularly around communications. We have established the following personal data control mechanisms:
EVENT INVITATIONS AND COMMUNICATIONS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what is of interest to you. This is how we decide which events and communications may be relevant for you.
You will receive communications from us if you have requested information from us or subscribed to stakeholder updates or other communications from us, or if you provided us with your details when you registered for an event, and in each case, you have not opted out of receiving communications.
THIRD-PARTY COMMUNICATIONS
We will get your express opt-in consent before we share your personal data with any entity. If you have signed up for any of our information services, such as stakeholder bulletins, or attended any of our events, you may receive an annual stakeholder survey from a trusted third party acting on our behalf. When sending this out we may rely on legitimate interest, as the survey is used to improve the company’s performance and our services to you.
OPTING OUT
You can ask us or third parties to stop sending you communications at any time by Contacting us at any time.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. For an explanation of how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with service providers acting as processors based in the EU who provide IT and system administration services and/or professional advisers who provide professional services for the purposes set out in the table in paragraph 4 above. 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.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside of the UK or the European Economic Area (EEA); however, some of our external third parties work with sub-processors outside of the UK or the EEA and their processing of your personal data will involves a transfer of data outside of the UK or the EEA. We contractually require that whenever they transfer your personal data out of the UK or the EEA, they ensure a similar degree of protection is afforded to it by ensuring that personal data is given the same or similar protection as it has in the UK in accordance with relevant legislation and guidance from the ICO.
7. DATA SECURITY
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.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
9.YOUR LEGAL RIGHTS
You have rights under data protection laws in relation to your personal data:
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, but 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 tools or communications to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us via sar@lowcarboncontracts.uk.
NO FEE 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 may refuse to comply with your request in these circumstances.
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.
TIME LIMIT TO RESPOND
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.
Cookies
Low Carbon Contracts Company and Electricity Settlements Company cookie policy
INTRODUCTION
1.WHAT ARE COOKIE
2.ESSENTIAL COOKIE
3.NON-ESSENTIAL COOKIES
1. WHAT ARE COOKIES
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Our site uses both essential and non-essential cookies. By selecting the "No, thanks" button in the cookies consent box it will deactivate non-essential cookies.
Alternatively, most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.
To opt-out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout. You can also use the NAI service to opt-out of other organisations that use interest-based advertising, visit https://optout.networkadvertising.org/?c=1. If you have additional questions about our use of Cookies, please Contact us.
2. ESSENTIAL COOKIES
We use essential cookies to manage performance, and security of our site, and are strictly necessary for the website to function. While you can turn off these cookies in your browser's settings, this may result in the parts of the site not working as intended. All essential cookies, bar the one that identifies whether or not you have accepted non-essential cookies, expire either after the end of your browsing session or within 48 hours.
3. NON-ESSENTIAL COOKIES
Non-essential cookies are cookies that are useful, and in many cases, vital to the website owner in managing their site, but are not strictly necessary for users to interact with the site in any given browsing session. These cookies are disabled when you select the "No, thanks " button.
Google Analytics
Google Analytics uses cookies to measure user-interactions in a manner that helps website owners understand how users view their site content. As a user navigates between web pages, Google Analytics provides website owners JavaScript tags (libraries) to record information about the page a user has seen, for example, the URL of the page. The Google Analytics JavaScript libraries use HTTP Cookies to "remember" what a user has done on previous pages/interactions with the website.
HotJar
We also use HotJar Cookies to track the user's journey through our site, including their interactions with specific site features. We use this information to improve our site design and to ensure we provide content relevant to our users.
Third-party Cookies
Our site utilises embedded videos to better convey messages to our users. We embed videos from both YouTube and Vimeo. When you access these sites, they may drop their own cookies, including non-essential cookies, which LCCC does not have control over. But if you do not view these videos, third-party cookies from YouTube or Vimeo would not be installed on your device.