WHAT IS THE PURPOSE OF THIS DOCUMENT?
Cortez Subsea Limited is committed to protecting the privacy and security of personal information. The term personal information means any personal information which relates to a living individual.
This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with data protection legislation, including the General Data Protection Regulation (GDPR) and Data Protection Act 2018, as may be amended from time to time.
It applies to parties with whom we may deal with or interact with.
Cortez Subsea Limited is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This notice applies to all parties with whom we may deal with or interact with. We may update this notice at any time.
It is important that you read this notice, together with any other privacy policies or privacy notices we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
We will collect, store, and use the following categories of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers, and work and/or personal email addresses.
- Date of birth.
- Next of kin and emergency contact information.
- tax status information.
- Location of employment or workplace.
- Copy of driving licence.
- Copy of Passport
- Copy of CV
- Copies of qualifications and certifications
- Performance information.
- Disciplinary and grievance information.
- Information about your use of our information and communications systems.
- Hours worked for HSEQ reporting purposes.
We may also collect, store and use the following “special categories” of more sensitive personal information:
- Information about your health, including any medical condition, health and sickness records.
- Information about criminal convictions and offences.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information during the course of (i) performing contracts we enter into with our customers (ii) performing contracts we enter into with suppliers of goods and services to us (iii) the course of our commercial operations including administration, compliance, finance, and business development (including sales and marketing) .
We may, where necessary, collect additional personal information in the course of activities throughout our interaction with you.
HOW WE WILL USE INFORMATION ABOUT YOU
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform the contract we have entered into with you.
- Where we need to comply with a legal obligation.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest or for official purposes.
Situations in which we will use your personal information
We need all the categories of information in the list above primarily to allow us to perform our contract with our customers and/ or with our suppliers and/or our general commercial activities and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.
Change of purpose
We will only use your personal information 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. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
- In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations and in line with our Data Protection Policy.
- Where it is needed in the public interest, and in line with our Data Protection Policy.
- Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
- Where you have already made the information public.
Do we need your consent?
We do not need your consent if we use special categories of your personal information in accordance with our Data Protection Policy to carry out our legal obligations. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data.
INFORMATION ABOUT CRIMINAL CONVICTIONS
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our Data Protection Policy
We do not envisage that we will hold information about criminal convictions.
We will only collect information about criminal convictions where we are legally able or obliged to do so.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We may have to share your data with third parties, including (but not limited to) third-party service providers and other entities in the group.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
When might you share my personal information with third parties and other entities in the group?
We may share your personal information with third parties and other entities in our group for the purpose of: business administration, IT services, arranging business travel, and the requirements and performance of a contract with our clients and/or our suppliers.
Transferring information outside the EU
As Cortez Subsea Limited is an internationally focused company we may in order to perform our contracts with our clients and/or our suppliers or for commercial sales tendering purposes transfer information to countries outside the EU. It is not possible to identify these countries at this time as the Company is a project based business and the countries where we perform contracts depends on business opportunities and on project awards. There may be certain countries where the Company works on client projects in respect of which the European Commission has made an adequacy decision whilst for other countries where the Company may perform contracts for its clients the European Commission has not made an adequacy decision. This means that for some countries to which we may transfer your personal data in order to perform a contract or tender for work those countries are deemed to provide an adequate level of protection for your personal information. For other countries to which we may transfer your personal data in order to perform a contract or tender for work those countries are not deemed to provide an adequate level of protection for your personal information.
However, to ensure that your personal information does receive an adequate level of protection we will have put in place the following appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection: these include Binding Corporate Rules and also Data Transfer Agreements with parties including clients of the Company to whom we may transfer your personal information which agreements will place contractual obligations on the recipient of your personal information regarding its handling. If you require further information about these protective measures, you can request it from the Cortez Subsea Data Protection Compliance Manager.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use/hold my information for?
We will only retain your personal information 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.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once we are no longer required to retain your personal information we will securely destroy your personal information in accordance with applicable laws and regulations.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you.
- Request correction This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing Where we are relying on a legitimate interest (or those of a third party) and there is something which makes you want to object to processing on this ground.
- Request the restriction of processing This allows you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party when the information is stored and processed automatically.
If you want to exercise any of the above rights, please contact the Cortez Subsea Data Protection Compliance Manager in writing.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Cortez Subsea Data Protection Compliance Manager.
DATA PROTECTION OFFICER/COMPLIANCE MANAGER
We have appointed a data protection compliance manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Cortez Subsea Data Protection Compliance Manager. Contact details for the Cortez Subsea Data Protection Compliance Manager can be obtained by telephoning us at 44 (0) 1224 392888.
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.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact the Cortez Subsea Data Protection Compliance Manager.