Privacy Policy

Introduction

Humberside Offshore Training Association Limited (“HOTA”, “we”, “us”, or “our”) is strongly committed to protecting personal data. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.

Personal data is any information relating to an identified or identifiable living person. HOTA processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.

When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities, please go to the relevant sections of this statement.

Our processing activities

To find out more please go to the sections that are relevant to you at the bottom of this statement, the available sections are:

Business contacts
Individuals who use our applications
Individuals whose personal data we obtain in connection with providing services to our customers and stakeholders
Others who get in touch with us
Recruitment applicants
Staff, Consultants, Apprentices and Trustees
Suppliers (including subcontractors and individuals associated with our suppliers and subcontractors)
Visitors to our offices
Visitors to our website

Security

We take the security of all the personal data we hold very seriously. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

When and how we share personal data and locations of processing

We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

From time to time, we may use third parties located in other countries to help us run our business. As a result, personal data may be transferred outside the countries where we and our customers and stakeholders are located. This includes to countries outside the European Union ("EU") and to countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses.

Personal data held by us may be transferred to:

Third party organisations that provide applications/functionality, data processing or IT services to us

We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services.

Third party organisations that otherwise assist us in providing goods, services or information

Auditors and other professional advisers

We are regularly audited by awarding and accreditation bodies and others who will have limited access to personal data for the duration of the audit process.

Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

Changes to this privacy statement

We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.

This privacy statement was last updated on 24th May 2018.

Data controller and contact information

The data controller is Humberside Offshore Training Association Limited (a limited company registered in England under registration no. 02190605 and a registered charity in England under registration no. 519889 and with its registration address at Malmo Road, Sutton Fields Industrial Estate, Hull, HU7 0YF).

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Data Protection

HOTA

Malmo Road

Sutton Fields Industrial Estate

Hull

HU7 0YF

Email: dataprotection@hota.org

Telephone: 01482 820567

Individuals’ rights and how to exercise them

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights. Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below.

Right of access to personal data

You have a right of access to personal data held by us as a data controller. This right may be exercised by emailing us at dataprotection@hota.org. We will aim to respond to any requests for information promptly, and in any event within the legally required time limit of 30 days.

Right to rectification of personal data

To update personal data held by us, you may email us at dataprotection@hota.org. When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information within 30 days.

Right to erasure

In certain situations, you have the right to request us to erase your personal data. To request the erasure of your data please email us at dataprotection@hota.org, we will respond to your request within 30 days and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data.

Right to restrict processing

In certain situations, you have the right to request the restriction of processing to your personal data. To request that processing of your data is restricted please email us at dataprotection@hota.org, we will respond to your request within 30 days and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will continue to store the personal data, but not use it.

Right of data portability

You have the right to transfer your data from us to another data controller; however HOTA does not currently hold personal data that is suitable for transferring to another data controller. If you have any questions regarding this please email us at dataprotection@hota.org.

Right to object

This right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes. To object to the processing of your data please email us at dataprotection@hota.org.

Right to avoid automated decision-making

This right enables you to contest a decision made about you based on automated processing; currently HOTA does not employ any automated decision-making processes. If you have any questions regarding this please email us at dataprotection@hota.org.

Right to withdrawal of consent

Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We process a limited amount of personal data based on consent as we can usually rely on another legal basis. To withdraw consent for receiving an email from an HOTA marketing list, please click on the unsubscribe link in the relevant email received from us, or for any other matters please email us at dataprotection@hota.org.

Complaints

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to dataprotection@hota.org. We will look into and respond to any complaints we receive.

You also have the right to lodge a complaint with the Information Commissioner's Office (“ICO”) (the UK data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO website (www.ico.org.uk) or you can contact them in the following ways:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Email: casework@ico.org.uk

Telephone: 0303 123 1113

Further Information on Processing Activities:

Business contacts

Collection of personal data

HOTA processes personal data about contacts (existing and potential HOTA customers and stakeholders and/or individuals associated with them).

The collection of personal data about contacts will include name, employer name, contact title, phone, email and other business contact details.

Use of personal data

Personal data relating to business contacts may be visible to and used by HOTA for:

Administering, managing and developing our businesses and services
Providing information about us and our range of services
Making contact information available to HOTA personnel
Describing the nature of a contact’s relationship with HOTA

HOTA does not sell or otherwise release the personal data that it holds to third parties for the purpose of allowing them to market their products and services under any circumstances.

Data retention

Personal data will be retained by HOTA for as long as it is necessary for the purposes set out above (e.g. for as long as we have, or need to keep a record of, a relationship with a business contact).

Individuals who use our applications

We provide external users access to the applications which are managed by us. Such applications will contain their own privacy statements explaining why and how personal data is collected and processed by those applications. We encourage individuals using our applications to refer to the privacy statements available on those applications.

Individuals whose personal data we obtain in connection with providing services to our customers and stakeholders

Collection of personal data

Our policy is to collect only the personal data necessary for agreed purposes and we ask the applicable organisations only to share personal data where it is strictly needed for those purposes.

Where we need to process personal data to provide our services, we ask our customers and stakeholders to provide the necessary information to the data subjects concerned regarding its use.

We collect and use contact details in order to manage and maintain our relationship with those individuals. Please see the Business contacts section of this privacy statement for more information about our processing of this type of data.

Given the diversity of the training and consultancy services we provide to customers and stakeholders, we process many categories of personal data, including:

Information about management and employees, including the experience and qualifications of instructors, consultants, apprentices and truestees at HOTA;

Training records of delegates who have completed HOTA facilitated training, and assessment programmes;
Contact details;
Business activities.

Use of personal data

We use personal data for the following purposes:

Providing services to customers and stakeholders

We provide a diverse range of services. Some of our services require us to process personal data in order to provide training and subsequent certification and verificiation, advice and deliverables.

Administering, managing and developing our businesses and services

We process personal data in order to run our business, including:

- Managing our relationship with customers and stakeholders;

- Developing our businesses and services (such as identifying stakeholder needs and improvements in service delivery);

- Maintaining and using IT systems;

- Hosting or facilitating the hosting of events; and

- Administering and managing our website and systems and applications.

Security, quality and risk management activities

We have security measures in place to protect both our own and our customers and stakeholders’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We monitor the services provided to customers and stakeholders for quality purposes, which may involve processing personal data stored on the relevant stakeholder file. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to stakeholder engagements. We collect and hold personal data as part of our stakeholder engagement and acceptance procedures. As part of our stakeholder review and engagement acceptance, we carry out searches using publicly available sources (such as internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations and check that there are no issues that would prevent us from working with a particular stakeholder (such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues).

Complying with any requirement of law, regulation or a professional body of which we are a member

As with any provider of services, we are subject to legal, regulatory and professional obligations. We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.

We are continually looking for ways to help our customers and stakeholders and improve our business and services. Where agreed with our customers and stakeholders, we may use information that we receive in the course of providing services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, provide insights back to our customers and stakeholders, to improve our business, service delivery and offerings and to develop new services and offerings. To the extent that the information that we receive in the course of providing services contains personal data, we will remove the personal data prior to using the information for these purposes.

Data retention

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).

Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.

For further information on data retention periods please contact dataprotection@hota.org

Others who get in touch with us

We collect personal data when an individual gets in touch with us with a question, complaint, comment or feedback (such as name, contact details and contents of the communication). In these cases, the individual is in control of the personal data shared with us and we will only use the data for the purpose of responding to the communication.

Recruitment applicants

When applying online for a role at HOTA via the vacancies page on the website, applicants are able to provide their personal details, a CV and any further information that they choose to submit. The personal data supplied is only used as part of the relevant recruitment process and the information of unsuccessful applicants is retained for 6 months after the end of the process.

Staff and apprentices

We collect personal data concerning our own personnel (both contract staff and external consultants) as part of the administration, management and promotion of our business activities.

Staff and apprentices should refer to the Data Protection section of the Employee Handbook and appendices for information on why and how personal data is collected and processed.

Suppliers (including subcontractors and individuals associated with our suppliers and subcontractors)

Collection of personal data

We collect and process personal data about our suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) in order to manage the relationship, contract, to receive services from our suppliers and, where relevant, to provide services to our customers and stakeholders.

Use of personal data

We use personal data for the following purposes:

Receiving services

We process personal data in relation to our suppliers and their staff as necessary to receive the services. For example, where a supplier is providing us with facilities management or other outsourced services, we will process personal data about those individuals that are providing services to us.

Providing services to customers and stakeholders

Where a supplier is helping us to deliver services to our customers and stakeholders, we process personal data about the individuals involved in providing the services in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our customers and stakeholders (for example, where our supplier is providing people to work with us as part of an HOTA approvals team providing services to our customers and stakeholders).

Administering, managing and developing our businesses and services

We process personal data in order to run our business, including:
Managing our relationship with suppliers;
Developing our businesses and services (such as identifying stakeholder needs and improvements in service delivery);
Maintaining and using IT systems;
Hosting or facilitating the hosting of events; and
Administering and managing our website and systems and applications.

Security, quality and risk management activities

We have security measures in place to protect our own and our customers and stakeholders’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers. We collect and hold personal data as part of our supplier contracting procedures. We monitor the services provided for quality purposes, which may involve processing personal data.

Providing information about us and our range of services

Unless we are asked not to, we use business contact details to provide information that we think will be of interest about us and our services. For example, industry updates and insights, other services that may be relevant and invites to events.

Complying with any requirement of law, regulation or a professional body of which we are a member

Data retention

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).

Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.

Visitors to our offices

We require visitors to our office to sign in and record any vehicles in the car park at reception and keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need to know basis (e.g. to look into an incident).

We have external and internal CCTV at our training sites and there are signs showing that CCTV is in operation. The images captured are securely stored and only accessed on a need to know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation.

Visitors to our website

Collection of personal data

Visitors to our website are generally in control of the personal data shared with us. We may capture limited personal data automatically via the use of cookies on our website. Please see the section on Cookies below for more information.

We receive personal data, such as name, title, company address, email address, and telephone numbers, from website visitors; for example when an individual subscribes to updates from us.

We ask that you do not provide sensitive information (such as race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records) to us when using our website; if you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent for us to collect and use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information.

We use small text files called ‘cookies’ which are placed on your hard drives to assist in personalising and enriching your browsing experience by displaying content that is more likely to be relevant and of interest to you. The use of cookies is standard operating procedure for most websites. However if you are uncomfortable with the use of cookies, most browsers now permit users to opt-out of receiving them. You need to accept cookies in order register on our website. You may find other functionality in the website impaired if you disable cookies. After termination of the visit to our site, you can always delete the cookie from your system if you wish.

You can find out more details regarding our use of cookies on our Cookies page.

Use of personal data

When a visitor provides personal data to us, we will use it for the purposes for which it was provided to us as stated at point of collection (or as obvious from the context of the collection). Typically, personal data is collected to:

Register for certain areas of the site;
Subscribe to updates;
Enquire for further information;
Distribute requested reference materials;
Submit curriculum vitae;
Monitor and enforce compliance with our terms and conditions for use of our website;

Administer and manage our website, including confirming and authenticating identity and preventing unauthorised access to restricted areas, premium content or other services limited to registered users; and aggregate data for website analytics and improvements.

Unless we are asked not to, we may also use your data to contact you with information about HOTA’s business, services and events, and other information which may be of interest to you. Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate webpage, in our communication to the individual, or the individual may contact us by email to dataprotection@hota.org.

Our website does not collect or compile personal data for the dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties. If there is an instance where such information may be shared with a party that is not an HOTA group member, the visitor will be asked for their consent beforehand.

Data retention

Personal data collected via our website will be retained by us for as long as it is necessary (e.g. for as long as we have a relationship with the relevant individual).