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1. Purpose.

WG Tanker Services Ltd are committed to protecting and respecting your privacy.

This policy together with any other documents referred to on it sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation (GDPR). More information is available from the Information Commissioner’s Office (ICO).

2. Definitions.

Data controller – A controller determines the purpose and means of processing personal data. Data processor – A processor is responsible for processing personal data on behalf of a controller. Data subject – Natural person

Categories of data: Personal data and special categories of personal data.

Personal data – The GDPR applies to “personal data” meaning any information relating to an identifiable person who can be directly or indirectly identified, in particular by reference to an identifier (as explained in Article 6 of GDPR). For example, name, passport number, home address, or private email address. Online identifiers include IP addresses and cookies.

Specialist categories personal data – The GDPR refers to sensitive personal data as “special categories of personal data” (as explained in Article 9 of GDPR). The special categories specifically include, genetic data, and biometric data where processed to uniquely identify and individual. Other examples include, racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions religious or philosophical beliefs.

Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure through transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor are authorised to process personal data.

3. Who are we?

WG Tanker Services Ltd is the data controller. This means that we decide how your personal data is processed and for what purposes. Our contact details are 01283 585985 or silo.uk@wgtanker.com. For all data matters, contact our data representative Paul Moore on 01283 585985 or paul.moore@wgtanker.com.

4. The purpose(s) of processing your personal data.

We use your personal data for the following purposes;

Customer/ supplier

• To facilitate trading with you

• To enable us to make informed decisions on risks regarding the credit worthiness of your company.

Employees

• To fulfil employment requirements

• To enable payment of salary

• To enable contacting of next of kin or emergency contact in event of an emergency. • To enable us to make informed decisions on risks regarding to right to work status, and the driving of company vehicles, or driving for the business for insurance purposes.

5. The categories of personal data concerned.

With reference to the categories of personal data described in the definitions section, we process the following categories of your data;

Customer / supplier.

• Personal data.

• Company name.

• Company address (including site locations).

• Company contacts (purchasers / sales / accounts / Manager etc).

• Various telephone numbers and email addresses as supplied by you.

• VAT number.

• Company registration number.

We have obtained your personal data from your completed account application form and from the use of Creditsafe.

Employees

• Individual names.

• Personal address.

• Contact numbers.

• National Insurance Number.

• Previous employment details.

• Immigration / Right to work status.

• Driving licence details including any endorsements.

• Bank details

We have obtained your personal data from your completed job application form and from details provided at your company induction.

6. What is our legal basis for processing your personal data?

a) Customer / supplier Personal data (article 6 of GDPR).

Our lawful basis for processing your general personal data:

Consent of the data subject:

Processing necessary for the performance of a contract with the data subject or to take steps to enter into an account – the buying or selling of goods or services.

Processing necessary for compliance with a legal obligation.

Processing necessary to protect the vital interests of a data subject or another person.

Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Processing necessary for the purpose of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interest or fundamental rights or freedoms of the data subject – making an informed judgement on your credit worthiness.

b) Employees personal data (Article 6 of GDPR)

Our lawful basis for processing your general personal data:

Consent of the data subject:

Processing necessary for the performance of a contract with the data subject or to take steps to enter into an account – employment contract, company induction. Banking information for payment of salary.

Processing necessary for compliance with a legal obligation – check right to work in UK status. Check driving licence for endorsements.

Processing necessary to protect the vital interests of a data subject or another person – for the purpose of health monitoring surveillance. Emergency contact information in event of emergency.

Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller – checking of driving licence for any endorsements – HGV drivers and working time directives.

Processing necessary for the purpose of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interest or fundamental rights or freedoms of the data subject – checking the suitability of potential employees.

7. Sharing your personal data.

Your personal data will be treated as strictly confidential and never shared or sold without your consent.

8. How long do we keep your data?

We keep your personal data for no longer than is reasonably necessary for a period of trading in order to maintain our records, in case of any legal claims/complaints or for safeguarding purposes etc.

9. Providing us with your personal data.

We require your personal data as it is a requirement necessary to enter into a contract.

10. Your rights and your personal data.

Unless subject to an exception under the GDPR, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you.

• The right to request that we correct any personal data if it is found to be inaccurate or out of date.

• The right to request your personal data is erased where it is no longer necessary to retain such data.

• The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data.

• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller,(known as right to data portability), (where applicable i.e. where the processing based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means).

• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.

• The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest / exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).

11. Transfer of data abroad

We do not transfer your data outside of the UK

12. Automated decision making.

We do not use any form of automated decision making in our business.

13. Further processing.

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

14. Changes to our privacy policy

Any changes we make to our privacy policy will be posted where appropriate, and/or notify you by email.

15. How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact our data representative on 01283 585985, paul.moore@wgtanker.com.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) on 03031 231113 or via email www.ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.

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