GDPR 2022 Privacy Notice
Scope
This Privacy Notice refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The UK General Data Protection Regulation (UK GDPR) and the 2018 Data Protection Act along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of all data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the movement of personal data within the UK and overseas. It should be noted that UK GDPR does not apply to information already in the public domain such as Companies House data.’
The Hire Association Europe Ltd (HAE) and Event Hire Association Ltd (EHA), are pleased to provide the following information:
Who We Are
HAE is a trade membership body representing plant, tool and equipment hire businesses located in the UK, Europe and elsewhere in the World. HAE assists businesses, from sole traders to larger independent and privately owned organisations, by providing operational resources to support the hire industry. EHA is a leading trade association for the event hire industry. Both organisations serve over 900 members across the world, by providing operational resources to support the events hire industry.
For the purposes of this Privacy Notice both organisations will be referred to as HAE EHA.
Personal Data
HAE EHA uses the information collected from you to provide quotations, make telephone contact and to email you information which the company believes may be of interest to you and your business. In you making initial contact you consent to HAE EHA maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services. HAE EHA may occasionally also act on behalf of its members in the capacity of data processor. When working exclusively as a data processor, HAE EHA will be acting on the instruction of its members, and will work hard to ensure that the work is fully UK GDPR compliant.
Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses. HAE EHA may, from time to time, use such information to identify its visitors. HAE EHA may also collect statistics about the behaviour of visitors to its website.
The HAE EHA websites use cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. WordPress.org uses cookies to help HAE EHA identify and track visitors and their website access preferences. HAE EHA website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the HAE EHA websites.
Any information HAE EHA holds about you and your business encompasses all the details we hold about you and any sales transactions including any third-party information we have obtained about you from public sources and our own suppliers such as credit referencing agencies.
HAE EHA will only collect the information needed so that it can provide you with the services it provides, the Associations do not sell or broker your data, although coincidentally there may be times when your information could be contained in data that HAE EHA have coincidently purchased from a third-party list broker.
For the purposes of payroll, marketing and certain other services HAE EHA uses third party suppliers, who for the purposes of UK GDPR are processors. Where these suppliers are not based within the UK, such as MailChimp, data is processed on the basis of signed Standard Contract Clauses and/or other safeguards.
Legal basis for processing any personal data
To meet HAE EHA contractual obligations to its employees, the membership and to respond to business enquiries.
Legitimate interests pursued by HAE EHA
To promote membership of HAE and/or EHA and the benefits of joining. This may include direct mail, email, newsletters, telephone calls, social media and any other channels to reach those involved in the different hire sectors. We will also share your contact details with a select list of HAE EHA approved suppliers, so that your organisation can benefit from bulk purchase arrangements, events, webinars, legal support and other third party services provided for the membership.
To also support the legitimate interests of Members and Affiliates in the prevention and/or detection of unlawful acts through the sharing of criminal intelligence gained from the membership with the police, fellow Members and approved Affiliates. HAE which acts as the Facilitator of the sharing service will be relying on UK GDPR Article 6 (f) for the purposes of data processing. Criminal intelligence personal data will only be shared with Members and Affiliates where they have signed the HAE Criminal Intelligence Data Sharing Agreement, which strictly regulates the dissemination of the details. HAE will be relying on Paragraph 2 of Schedule 2 of the DPA 2018 for the purposes of sharing with the Police.
Consent
Through agreeing to this privacy notice you are consenting to HAE EHA processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing dpo@hae.org.uk or by phoning +44 (0) 121 380 4600 or writing to us, see last section for full contact details.
Disclosure
HAE EHA may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. HAE EHA requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and UK GDPR. HAE EHA do not broker or pass on information gained from your engagement with the company without your consent. However, HAE EHA may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. The business may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of HAE EHA, its clients and/or the wider community.
Retention Policy
HAE EHA will process personal data during the duration of membership or contract and will continue to store only the personal data needed for seven years after the contract has expired to meet any legal obligations. After seven years any personal data not needed will be deleted. Data storage concerning employees is covered in an addendum to their employment contracts.
Data storage
Data is held in the United Kingdom and also held outside the UK on Google Drive and MailChimp who have signed Standard Contract Clauses for the processing of personal data. DropBox is regulated by the Cloud Security Alliance (CSA) Code of Conduct for GDPR Compliance.
Your rights as a data subject
At any point whilst HAE EHA is in possession of or processing your personal data, all data subjects have the following rights:
In the event that HAE EHA refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
At your request HAE EHA can confirm what information it holds about you and how it is processed.
You can request the following information:
To access what personal data is held, identification will be required
HAE EHA will accept the following forms of ID when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If HAE EHA is dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to dpo@hae.org.uk or by phoning +44 (0) 121 380 4600 or writing to us at the address further below.
Complaints
In the event that you wish to make a complaint about how your personal data is being processed by HAE EHA or its processors, you have the right to complain to HAE EHA’s managing director. If you do not get a response within 30 days you can complain to the ICO.
The details for each of these contacts are:
HAE EHA, attention of the Managing Director
Unit 2450, Regent Court, Birmingham Business Park, Solihull, West Midlands, B37 7YE.
Telephone +44 (0) 121 380 4600 or email dpo@hae.org.uk
ICO
Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/