Privacy and Cookie Policy

Renewco Power Limited (“Renewco“, “we“, “our“) is committed to protecting the privacy of individuals whose data it processes (“you” or “your“).

1. Important information and who we are
This privacy policy aims to give you information on how Renewco collects and processes your personal data as a controller, through your use this website and/or by applying for employment with us. In addition, it outlines your data protection rights under the UK General Data Protection Regulation.
This website is not intended for children and we do not knowingly collect data relating to children.
Renewco is the controller of the personal data that you provide or which is provided to or collected by us. Please contact us at 10c Wester Coates Gardens, Edinburgh, Scotland, EH12 5LT or at info@renewcopower.com if you have any queries in relation to the processing of your personal data under this policy.

We may update this policy from time to time. Please refer back to this page regularly to see any changes or updates to this policy.

2. Categories of data subject
(A) Job applicants
The following section of this policy sets out how Renewco may process personal data (as a controller) about job applicants and candidates.

The types of data we may hold
In connection with your application for work with us, we may hold various categories of personal data about you, which you provide to us from time to time, and which we have grouped together as follows:

• Identity data may include your name, title, and date of birth;
• Contact data may include addresses, work email addresses, personal email addresses, and telephone numbers;
• Right to work data may include copies of your passport, driving licence and utility bills, and unspent criminal convictions;
• Financial data may include bank account details;
• Equal opportunities data may include your gender, gender identity, ethnicity, age, sexual orientation, religion and beliefs, physical or mental impairments, and native language;
• Career data may include places of work, job titles, employment history, qualifications and CV, and information provided to us during telephone calls, interviews and/or meetings with you; and
• Technical data may include internet protocol (IP) address, 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 our website, and usage data (including information about how you use our website).

We may also collect, store and use the following “special categories” of sensitive personal data: Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions, information about your health, including any medical condition, health and sickness records and/or information about criminal convictions and offences.

How we collect data
We use different methods to collect data from and about you including from the following sources:

• you, the candidate directly;
• recruitment agencies;
• background check providers;
• credit reference agencies;
• your named referees; and
• data from third parties is from a publicly accessible source including Companies House records and social media (such as LinkedIn).

The reasons and legal bases on which we collect data
Your personal data may be processed by Renewco or its processors (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes and on the following legal bases:

Purpose / Activity	Type of data	Legal basis for processing
To assess your skills and qualifications, to consider your suitability for the position and to decide whether to enter into a contract with you and to take steps prior to entering into a contract with you.	Identity data Right to work data Financial data Equal opportunities data Career data	(a) Performance of (or taking steps prior to entering into) a contract; (b) Our legitimate interests of pursuing and developing our business.
To carry out background and reference checks	Right to work data	Compliance with our legal and regulatory obligations
To communicate with you about the recruitment process	Contact data	Performance of (or taking steps prior to entering into) a contract
To keep records related to our hiring processes	Identity data Contact data Right to work data Equal opportunities data Career data	(a) Compliance with our legal and regulatory obligations;  (b) Our legitimate interests of pursuing and developing our business, maintaining a diverse and equal working environment and ensuring that no discrimination occurs in the workplace
To comply with our legal and regulatory requirements	Contact data Right to work data Equal opportunities data	Compliance with our legal and regulatory obligations
To consider whether we need to provide appropriate adjustments during our recruitment process	Equal opportunities data	(a) Compliance with our legal and regulatory obligations; (b) Necessary for the purposes of carrying out obligations in the field of employment law (in particular, our obligation to make reasonable adjustments under the Equality Act 2010).
To be able to undertake equal opportunity monitoring and reporting	Equal opportunities data	(a) Our (and our employees’ / prospective employees’) legitimate interests to maintain a diverse and equal working environment and ensure that no discrimination occurs in the workplace; (b) Necessary for the purposes of identifying and keeping under review the existence or absence of equality of opportunity and treatment.
To monitor emails sent to us (including attachments) for viruses or malicious software	Technical data Contact data	Our legitimate interests to protect and maintain the security of our systems
To protect and manage email traffic	Technical data Contact data	Our legitimate interests to protect and maintain the security of our systems
Generally to manage the activities of the company, including by monitoring and recording electronic communications (including telephone calls and emails)	Technical data Contact data	Our legitimate interests of pursuing and developing our business

 

We will use your sensitive personal data in the following ways:

• we will use information about disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during the interview; and
• we will use information about race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure equal opportunity monitoring and reporting.

We do not envisage that we will process information about criminal convictions.

Once we receive your CV and covering letter or your application form, we may process that information to decide whether we have any suitable vacancies and if you meet the basic requirements to be shortlisted for that role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the work. If we decide to offer you the work, we will then take up references and we may carry out other checks before confirming your appointment.

If you fail to provide information when requested
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

Automated decision-making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Data retention
If your application is successful, the information you provide during the application process will be retained as part of your employee file and held in accordance with our employee privacy policy and our data retention policy and applicable laws.

If your application is unsuccessful, the information you have provided will be retained by us for six (6) months after we have communicated to you our decision to you. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy or applicable laws and regulations. If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

(B) Visitors to our website
The following section of this policy sets out how Renewco may process personal data (as a controller) about visitors to its website.

The types of data we may hold
We may collect, use, store and transfer different kinds of personal data about you which you provide to us though our website and which we have grouped together as follows:

• Identity data may include your name, title, and date of birth;
• Contact data may include addresses, personal email addresses, and telephone numbers; and
• Technical data may include internet protocol (IP) address, 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 our website, and usage data (including information about how you use our website).

We do not collect any sensitive personal data or special categories of personal data about you through our website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we collect data
We use different methods to collect data from and about you including through:

• direct interactions with you, including by filling in forms. This includes personal data you provide when you subscribe to our publications and/or request marketing to be sent to you.
• Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
• Technical data (on an anonymised basis) from analytics providers, such as Google based outside the UK.

The reasons and legal bases on which we collect data
Your personal data may be processed by Renewco or its processors (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes and on the following legal bases:

Purpose / Activity	Type of data	Legal basis for processing
To respond to queries from you	Identity data Contact data	Performance of (or taking steps prior to entering into) a contract
To improve our website, marketing, customer experiences	Technical data Contact data	Our legitimate interests of pursuing and developing our business
To monitor emails sent to us (including attachments) for viruses or malicious software	Technical data Contact data	Our legitimate interests to protect and maintain the security of our systems
To protect and manage email traffic	Technical data Contact data	Our legitimate interests to protect and maintain the security of our systems
To send you marketing communications which you have signed up for	Contact data	Consent
Generally to manage the activities of the company, including by monitoring and recording electronic communications (including telephone calls and emails)	Technical data Contact data	Our legitimate interests of pursuing and developing our business

If we consider it necessary to obtain your consent in relation to the use your personal data, we will contact you to request this consent. In such circumstances, we will provide you with full details of the personal data that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. If you decide to provide your consent, you have the right to withdraw your consent at any time, although that will not affect the lawfulness of processes based on consent before its withdrawal. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Automated decision-making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Data retention
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.

Where our website provides links to other websites, we are not responsible for the data protection/privacy/cookie usage policies of those other websites, and you should check these policies on such other websites if you have any concerns about them. If you use one of these links to leave our website, you should note that we do not have any control over that other website.

3. Disclosures of your personal data
We will not disclose personal information we hold about you to any third party except as set out below.
We may disclose your personal data to other members of our group, to third parties who are providing services to us (including payroll, pension and IT service providers), and backup and disaster recovery service providers.

We may also disclose personal data we hold to third parties:

(a) in the event that we sell any business or assets, in which case we may disclose personal data we hold about you to the prospective and actual buyer of such business or assets; and/or

(b) if we are permitted by law to disclose your personal data to that third party or are under a legal obligation to disclose your personal data to that third party.

4. International transfers
We do not transfer your personal data outside the United Kingdom.

5. Data security
Renewco has put in place measures to ensure the security of the personal data it collects and stores about you. It will use its reasonable endeavours to protect your personal data from unauthorised disclosure and/or access, including through the use of network and database security measures, but it cannot guarantee the security of any data it collects and stores.

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.

6. Your legal rights
In certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. 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 of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables 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.
• Withdraw your consent. If we are processing your personal data on the basis of your consent, you have the right to withdraw such consent at any time. Withdrawing your consent will not affect the lawfulness of processes based on consent before its withdrawal. To withdraw your consent or to opt out of receiving marketing communication, please contact us at info@renewcopower.com or by following the unsubscribe instructions included in each electronic marketing communication. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

If you wish to exercise any of the rights set out above, please contact us at info@renewcopower.com.
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.

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.

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.

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.

7. Cookies
Our websites use cookies. A cookie is a small text file, which is stored on your computer in order to recognise your computer at recurring visits. The cookie may transmit information via your browser with a purpose of authenticating or identifying the computer (eg, via the IP address) or the user. Cookies may contain information such as registration data and user preferences. When a server receives a request from a computer which stores a cookie from the website, the server is able to use the information stored in the cookie in combination with the information stored on the server. A cookie cannot collect information from your computer and cannot carry any virus or other damaging files.
We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested.

The table below provides more information about the cookies we use and why:

The cookies we use	Name	Purpose	Duration	Whether cookie is essential for us to provide you with a service that you have requested and whether we will seek your consent before we place the cookie
Google Analytics	_ga	Analytics Cookie Registers a unique ID that is used to generate statistical data on how the visitor uses the website.	2 years	No, will therefore request your consent before placing this cookie.
Google Analytics	_ga_#	Analytics Cookie Used by Google Analytics to collect data on the number of times a user has visited the website as well as dates for the first and most recent visit.	2 years	No, will therefore request your consent before placing this cookie.

The cookies we use will only be accessed by us and those third parties named in the table above for the purposes referred to in this cookie policy. Those cookies will not be accessed by any other third party. To deactivate the use of third party advertising cookies, you may visit the consumer page to manage the use of these types of cookies by following the links above.

You may delete cookies if you no longer wish to store them on your computer. However, please note that the quality of our website may be reduced as a consequence thereof. Please refer to the help guide for your browser for further guidance. Further information about cookies (including how to turn them off) can be found at www.allaboutcookies.org and www.ico.org.uk/for-the-public/online/cookies.

8. Changes
We reserve the right in our sole discretion to amend and/or delete this privacy and cookie policy at any time without providing prior notice to you. We will post the current version of this privacy and cookie policy on the website.

9. Contact details
If you have any queries about this policy or your personal data, or you wish to submit an access request or raise a complaint about the way your personal data has been handled, please contact us at info@renewcopower.com.