This Privacy Notice sets out how CWA International Ltd ("the Company") handles the personal information we obtain from our clients, suppliers, contacts and other third parties.
We invite you to read this Privacy Notice which describes the types of information we collect from you, how it is used by us, how you can manage the information we have about you, and how you can contact us.
The information to which this Privacy Notice applies is “personal data”, which is defined in current data privacy law as information which can identify living people. Where we refer to personal data below, we use the term “personal information”.
Our Privacy Notice was last updated on 25 May 2018. The contents of our Privacy Notice may change from time to time. Please check it now and again so that you are sure you are happy to share your personal information with the Company.
Who We Are
CWA International Ltd is a company registered in England and Wales under company number 06446306. Our registered office is at Balmoral House, 9 John Street, London, WC1N 2ES.
Data Protection Principles
We adhere to the data protection principles set out in the General Data Protection Regulation which requires personal information to be:
(a) Used lawfully, fairly and in a transparent way;
(b) Collected only for valid purposes that we have clearly explained to you and not use in any way that is incompatible with those purposes;
(c) Relevant to the purposes we have told you about and limited only to those purposes;
(d) Accurate and kept up-to-date;
(e) Kept only as long as necessary for the purposes we have told you about; and
(f) Kept securely.
How Do We Collect Your Personal Information?
We collect your personal information in the following ways:
* If you are seeking general information about the Company when you contact us through our website or make an enquiry orally or telephone or email;
* If you, or an organisation for whom you work, has contracted with us to use our services, in corresponding and liaising with us;
* If you, or an organisation for whom you work, has supplied its services to us, in corresponding and liaising with us;
* If you have consented to receive our updates and marketing communications (for example, details of new services we offer);
* From information in the public domain;
* If you are applying for a job with us, your CV and cover letter, and any documents we ask you to complete during the recruitment process.
What Personal Information Do We Collect?
Depending on the method of collection and whether you are working with us personally or via a business, the personal information we collect might be all or some of the following:
* Your name and title;
* Your home address;
* Your work address;
* Your email address (personal and/or business);
* Your contact telephone number(s) (personal and/or business);
* Your place of work;
* Bank details;
* Invoice details and VAT number;
* Information about your use of our website, such as dates of your visit, pages viewed and the resources that you access (including traffic data, location data and other communication data);
* Images taken on our CCTV cameras;
* Other personal information provided by you in correspondence with us.
We currently use CCTV cameras to view and record individuals on our premises. We believe that such use is necessary for legitimate business purposes, including:
(a) to prevent crime and protect buildings and assets from damage, disruption, vandalism and other crime;
(b) for the personal safety of staff, visitors and other members of the public and to act as a deterrent against crime;
(c) to support law enforcement bodies in the prevention, detection and prosecution of crime;
This list is not exhaustive and other purposes may be or become relevant.
Images are monitored by authorised personnel normally during working hours only. Staff using surveillance systems will be given appropriate training to ensure they understand and observe the legal requirements related to the processing of relevant personal information.
In order to ensure that the rights of individuals recorded by the CCTV system are protected, we will ensure that personal information gathered from CCTV cameras is stored in a way that maintains its integrity and security. This may include encrypting the personal information, where it is possible to do so,
Personal information from CCTV cameras is retained for approximately nine months, when they are overridden by fresh images. Personal information may be retained for longer than nine months if such information is required for the purposes of an incident or dispute.
How We Use The Personal Information We Collect
Where we have entered into a contract with you or with the organisation with whom you work, we use your personal information to meet our obligations under that contract and, in some cases, to comply with our legal obligations.
We also use personal information relating to individuals employed or engaged by clients of third parties to whom we have provided our services.
We use personal information relating to individuals within Classification Societies for the purposes of contacting the Classification Society to check on a particular ship.
We use personal information relating to individuals within professional institutions, such as the Energy Institute and the Corrosion Institute for the purposes of contacting the professional institutions in order to obtain professional advice and pay them for it or because we are invited to participate in some of their committee work.
We use personal information relating to individuals employed or engaged by Government Departments for the purposes of contacting the Government Department to obtain information relevant to the conduct of our business.
We use personal information relating to individuals employed or engaged by consultancy firms for the purposes of conducting our business and/or engaging those individuals (or their consultancy firms) to co-ordinate inspections.
We use other personal information we collect for the purposes of providing information and answering general enquiries about the Company and our services. Using relevant personal information solely for these purposes is in our legitimate interests as a commercial business, provided that we use personal information in a proportionate way that respects your privacy rights as an individual.
How Long Do We Keep Your Personal Information?
Where we have a contractual relationship with you, or the business for whom you work, we keep your personal information during the contractual relationship and for seven years after the relationship ends. We have a legitimate purpose for retaining personal information for this length of time for legal and taxation reasons.
We will retain your name and contact details beyond that seven year period in order to keep you updated on our business and/or invite you to social events. If you no longer wish to receive our updates or invitations, you may opt-out of our communications. If you leave the employment (or engagement) of one of our customers, suppliers, contacts or other third parties, your personal information is removed from our records except for your name and the fact that you have left.
Where it is necessary to obtain your consent to receive our updates and marketing communications, we retain your personal information until such time as you withdraw that consent.
We retain personal information relating to unsuccessful candidates who have applied to work for us for two years for the purposes of responding to any legal claims. We also retain such information for the purposes of discussing future job opportunities with unsuccessful candidates and monitoring repeat applicants.
We do not keep personal information in any identifiable format longer than is necessary in the case of ordinary visitors to our website.
You have the right at any time to withdraw your consent to the processing of personal information save where it is necessary to perform a contract or where we need to keep the personal information for legal or taxation reasons.
The Company takes all appropriate technical and organisational measures to ensure the integrity and security of the personal information it holds. This includes restricting access to personal data via security barriers with username and password access only.
Sharing Your Personal Information
We do not share your personal information with third parties so you will not receive marketing or advertising material you do not want.
In the event that the Company becomes subject to a re-organisation, such as a merger, an acquisition of assets or a share sale, we may in accordance with our legitimate interests need to share some of your personal information with third parties who have a need to know about it specifically for reasons connected with the re-organisation.
We may share or reveal personal information if we are obliged or permitted to do so by law, or if it is required by law enforcement, fraud prevention, credit reference agencies, tax authorities or regulatory bodies.
Exporting Your Personal Information
We do not export personal data outside the EEA other than within the Company to the Singapore Office. Where data is transferred, it is infrequent and there are suitable safeguards in place to protect such data.
Managing Personal Information
You have the right as an individual to manage the personal information we hold about you and make amendments if this is necessary. You are also able to withdraw any consent you might have given us to receive marketing communications, such as newsletters or general information about our products and services, from the Company. You may also object to the Company using your personal information even if we rely on our legitimate interests to make use of it.
You have several rights in relation to your personal information under data protection law. In relation to most of these, if you exercise them we may ask for information from you to confirm your identity and, where applicable, to help us find your personal information. We will respond to you within 30 days after we have received a valid request, by which we mean a request that is backed up with any identification documents that we have requested.
You have the following rights:
* To request a copy or summary of the personal information we hold about you;
* To correct and update your personal information;
* To withdraw your consent (where we rely on it) from receiving any further communications from us which are not necessary (for example, we will not send you invitations to events, newsletters or details or our new services) or in respect of other matters for which your consent has already been given;
* To object to certain kinds of processing of your personal information such as automated processing and profiling;
* To erase your personal information or restrict its use.
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.
You can exercise your rights and manage your information by contacting us at:
CWA International Limited, Balmoral House, 9 John Street, London, WC1N 2ES
GDPR Telephone number: 0207 242 8444
Email address: firstname.lastname@example.org
Issues and Complaints
If you have an issue regarding how we handle personal information, please do not hesitate to contact the Company first. We will do everything we can to try to resolve your issue. If, however, you need to make a complaint, the contact details of the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection issues, are as follows:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone number: 0303 123 1113
You can also log your complaint or raise an issue on the ICO’s website at: https://ico.org.uk/global/contact-us/