Wiser Recycling – our privacy notice
Last updated 20th August 2018
This information is our privacy notice. It explains what we do with your personal information, why we want to use it, how we protect it, and what rights you have to control our use of your personal data.
The most important fact is that it’s your personal data. We have complete respect for your rights and we will only use it where necessary to deliver our services to you or your employer, to respond to your communications or to keep you up to date about developments in our business and industry.
Information about the data controller
The data controller is Wiser Recycling, Suite 11 Manor Mews, Bridge Street, St Ives PE27 5UW. Our company registration number is 04920416 and our registration number with the Information Commissioner’s Office is A8334745.
If you want to contact us about any of the points on this notice, or just generally about how we protect your privacy, please email us at firstname.lastname@example.org. We use this email address for all data protection and data access matters.
The purpose and lawful basis for processing your personal data
We use information for a few different purposes and each have a different lawful basis. This section describes these in detail and, although it’s technical, we’re required by law to explain this to you.
- Existing client
If you are an existing Wiser Recycling client, we hold your name and contact details because we have a contractual obligation to deliver services to you. We need your contact details to deliver our services (such as send you update emails when you need to take actions, send you invoices and so on). We will hold your information for a maximum of 10 years from when we last work for you.
- Previous client
If you are a previous Wiser Recycling client, in the 5 year period following the last work we did for you, we may continue to contact you with information about our services because we think you will find it useful. We believe we have a legitimate interest in this direct marketing activity (and this is also permitted under the Privacy and Electronic Communications Regulations or ‘PECR’) but you are always able to unsubscribe by clicking the link at the bottom of the emails we send, or by emailing us at email@example.com.
- Employee, temporary or contract worker of our clients
If you are an employee of (or temporary or contract worker at) an existing Wiser Recycling client, you should note that we have most likely been given your personal data by your employer. We may not have collected it from you directly. We hold your name and contact details so that we can deliver our waste electrical and electronic equipment services to your employer. We have a legitimate interest in being able to use your information in this way. We will hold your personal information for a maximum of 10 years from when we last worked for your employer.
If you are a supplier or other business associated with our field of work, we will hold your contact details because we have a legitimate interest in doing business with your company. We will aim to hold this information for no longer than 10 years since we were last in contact with you. It’s possible we picked this information up from public directories (such as LinkedIn and internet searches) or that you passed your details to us with a business card.
- Visitor to our website
If you visit our website, we use Google Analytics to track user activity on our site. We record your computer’s IP address so we can tell how each user and repeat visitor is using our site. We have a legitimate interest in tracking user journeys on the site so that we can improve our service. We will hold IP information for a maximum of three years from the time of your last visit to our site.
- Visitor to our facilities
If you visit us, we keep a visitor log book and use CCTV to monitor activity throughout both our Approved Authorised Treatment Facilities. We have a legitimate interest in recording your name and using CCTV to ensure the safety of visitors and security of our sites. We hold CCTV footage for a maximum of 3 months after which it is deleted unless required by the authorities (see below – who we share information with). Our visitor log books are kept for a maximum of 2 years after which they are destroyed.
- Accidents at our site
If you have an accident whilst at our site, we keep your name and contact details. We have a legal obligation to do so in order to meet health & safety legislation. We hold this information for up to 99 years for insurance and legal reasons. We may be required to share this information with the authorities, emergency services, insurance and legal service providers.
- Job applicant
If you apply for a job at Wiser Recycling we will hold your personal information to consider your application and correspond with you. We have a contractual obligation in holding this information to determine whether we wish to enter into an employment contract with you and to contact you with regards to your application. We hold your personal information for the duration of the recruitment process after which it is deleted (unless your application is successful or you consent to us holding your CV longer for future recruitment opportunities).
We have a separate privacy notice for employees.
Who receives your personal data?
- If you visit our website www.wiserrecycling.co.uk, we use Google Analytics to store your IP address and user journey on our website. Google is a data processor for us.
- If you are a client of Wiser Recycling, we hold your contact details in our email system (Outlook), scheduling system (Waste Logics) accounting system (Sage) and on our CRM support system (Mailchimp). These companies are data processors for us.
- All other business contacts we deal with (suppliers, authorities, associations etc), we may hold your contact details in Microsoft software (Excel, Word, Outlook) and store this on our shared drive. Microsoft is a data processor for us.
- If you are a client of Wiser Recycling or a supplier, we may have a legal obligation to share your contact details with the Environment Agency.
- If you apply for a job at Wiser Recycling we may hold your contact details and job application on Indeed or Linked In (if you applied through either of those routes). We may also hold this information in our email system (Outlook) and on a secure area of our shared drive.
- If you are on our marketing list, we hold your data in Mailchimp.
- If you visit our site, we hold your CCTV footage on xxx. We may need to share this with the authorities (Emergency services, Environment Agency, HSE) as well as insurance and legal service providers.
- If you have an accident at our site, we may need to share your personal information with the authorities (Emergency services, Environment Agency, HSE) as well as insurance and legal service providers.
- Wiser Recycling employs the services of external consultants and subcontractors to enable us to operate our business and deliver our services to our clients. We may share your personal information with those consultants with whom we hold agreements to ensure they safeguard the data they process on our behalf.
International transfers of personal data, and the measures in place to safeguard it
Google, Microsoft, Sage, MailChimp, etc. are all “cloud-based systems”, which means the information is held in huge information data centres in different locations.
The cloud-based systems we use reserve the right to hold copies of your personal information outside the European Economic Area (EEA.) Please note that the reason companies may choose to do this is to hold back-up copies, so they can guarantee recovery.
Microsoft, Mailchimp, Indeed, Linked In, Sage and Google may transfer your personal information to cloud data centres in the USA. The personal privacy laws and safeguards in the USA aren’t equivalent to those in the EU, so the European Commission has approved a system called “EU-US Privacy Shield” to make sure the personal information of European citizens is properly protected if held by companies in the USA.
Your personal data rights
The personal data we hold about you is your data, so you have certain rights over them. This section summarises your rights. You can exercise any or all these rights when you choose, and the easiest way is by dropping us an email at firstname.lastname@example.org.
Where we are processing your data based on your consent (e.g. for marketing purposes) you can withdraw that consent and we must immediately stop processing your data. Please note that up to that point, we’re acting lawfully with your consent, withdrawal of consent cannot be backdated.
You have the right to request a copy of all personal data we hold relating to you and we must provide this within 30 days. You also have the right to require us to correct any records that are wrong.
You have the right to require us to erase personal data and we must comply unless we need it for one of the purposes described above. We also retain the right to keep data that is needed to establish, exercise or defend a legal claim.
Where we process your data based on a ‘legitimate interest’ (underlined in the section on purpose and lawful basis, above) you still have the right to object to our processing of that data. From that point, we must stop processing your data until we have determined whether your rights override our interests.
Finally, you have the right to have your personal data transferred to another organisation, and we’re obliged to provide it to you in a clear and reasonable format.
Your rights to lodge a complaint with the Regulator
At all times, you have the right to report a concern or lodge a complaint with the Information Commissioner’s Office. Please refer to the ICO at https://ico.org.uk/concerns/ or by calling them on 0303 123 1113.
Of course, we hope that we can resolve your issue quickly and fairly – you can contact us at email@example.com.
Our contractual requirements to use your personal data
- If you’re a Wiser Recycling client, it’s a requirement that we collect personal information from you so that we can enter into a contract with your company.
- If you’re an employee (or temporary or contract worker) at a Wiser Recycling client, we may require your personal information to deliver services to your employer. Because of this, we have use legitimate interests as the lawful basis for processing your data (which is why we don’t ask for your consent to process it).
Automated processing of your personal data
We do not currently automatically process personal data.
Other purposes for processing personal data
We don’t process your personal data for any other purpose than we’ve described here. We won’t sell your personal data to other companies.
We may develop new processing purposes over time in which case we will let those concerned know what we intend to do, the lawful basis we will use, and your rights over our intended new processing. We will also publish information about it here.
Changes to this privacy notice
This privacy notice was last updated on 20th August 2018. Historic versions can be obtained by contacting us. We may change this privacy notice from time to time by amending this page.
How to contact us
If you have any questions, concerns or just want some more information about our privacy management, drop us a line at firstname.lastname@example.org.