Privacy Policy.
Introduction
UK Steel Enterprise Limited (UKSE, we, us) is a data controller and we take privacy very seriously. It is important to us that we only use the personal data that we receive from our customers, suppliers, workers and other third parties (you, your) in accordance with applicable data protection legislation. We are committed to being transparent with you about how we use your data and this document explains how we collect and process any personal data received as a result of our business activity, why it is collected, how it is used and your rights with regards to the collection of your personal data.
What Type of Personal Data Might We Collect?
The table below sets out the type of information and data that we may collect when providing our services:
| Ref | Information Type | Detail |
|---|---|---|
| D1 | Contact and Identity Information | This is data concerning you and how we will contact you. It includes personal biographical details (which may be obtained from your curriculum vitae, business plan and application forms) and will be information such as full name (and any previous names), previous employment history, job references, length of residency, date of birth, passport and driving licence details. It includes data concerning how we will contact you such as postal address (and any previous addresses), email address and telephone numbers. |
| D2 | Business Information | This is data relating to the nature of your business and your personal business dealings. It includes details of any directorships or association with companies (including failed companies) and businesses you may have had, details of any past relationship with UKSE, details of your suppliers and customers, details of your employees and consultants. It will include any information that we may obtain or collect about you and your business as a result of our due diligence investigations. |
| D3 | Financial and Banking Information | This is data relating to your financial circumstances. It includes bank account information, details of investments, financial statements, assets and liabilities statements, details of any personal guarantees and value of assets. |
| D4 | Communication Information | This is data that is exchanged between you and us as part of us providing (or intending to provide) services to you. It includes information provided by way of correspondence such as communication by email, letter, telephone, face to face interviews and on-going reviews. It may include information from social media platforms such as LinkedIn, Facebook and Twitter. |
| D5 | Digital Information | This is data collected when you visit our website, applications or other digital platforms. It includes details of IP-addresses, browser data and traffic data. For more information please see our Cookie Policy. It includes digital data stored in the “fobs” that we allocate to individuals to allow entry to and from our buildings as well as recording the date and time of entry to a building by a specific “fob” holder. |
| D6 | Video and Photographic Information | This is data collected as part of our marketing activities and includes information in press releases (including any photographs taken to support such literature). |
| D7 | Criminal Convictions | In our application forms we ask you to confirm that you do not have any criminal convictions and, if you do, to tell us about any that you may have. |
| D8 | Biometric Information for Identification Purposes | This is data collected for security devices for example fingerprint recognition to unlock doors and devices. |
| D9 | CCTV | We have CCTV cameras located on our premises as part of crime prevention and our security for those buildings. Your image may be collected if you use or visit our premises. |
Where Do We Collect the Personal Data From?
We collect the data from you or from third parties as part of providing (or intending to provide) our services to you.
What Do We Use Your Personal Data For?
We may collect and process your personal data for the following reasons:
| 1. Appraising and carrying out due diligence in connection with your application for one of our investment products and completing the investment | |
| Type of Data | We ask you to provide D1, D2, D3, D4, D5 and D7 data as part of our assessment of your application for our investment products and the type of investment we are going to provide to you. This may include data relevant to your business such as details of your directors, shareholders, customers and suppliers. |
| Lawful Basis for Processing | In order to be able to fulfil our agreement with you (assessing the investment), pursuing our legitimate business interests and to comply with our legal obligation to prevent crimes such as fraud or money laundering. We will only collect D7 data on the basis of your consent. Please note that, subject to our legal obligations, we will delete (or redact) any D7 data you may have provided to us whether or not your application proceeds. |
| Disclosure | We may undertake searches about you, your business or anyone else named on the application form at credit reference agencies. These agencies will provide us with credit information as well as information from the electoral register and will record details of any searches whether or not your application is successful. We will carry out due diligence in relation to you and your business with third parties and may share data with other advisors or funders in connection with the investment. We may be under a legal obligation to disclose your data (the data of your business or anyone else named on the application form) to any relevant authority to prevent crimes such as fraud or money laundering. Other than as set out above, we will not disclose your data to anyone else outside of our group of companies. |
| 2. Monitoring any investment we make | |
| Type of Data | We ask you to provide D1, D2, D3, D4 and D5 data as part of our monitoring and review of any investment we make. This may include data relevant to your business such as details of your directors, shareholders, customers and suppliers. |
| Lawful Basis for Processing | In order to be able to fulfil our agreement with you (providing the investment), pursuing our legitimate business interests and to comply with our legal obligation to prevent crimes such as fraud or money laundering. |
| Disclosure | We may undertake monitoring searches about you and your business at credit reference agencies. These agencies will provide us with credit information as well as information from the electoral register and will record details of any searches. We may be under a legal obligation to disclose your data (and any data of your business) to any relevant authority to prevent crimes such as fraud or money laundering. Depending on the type of investment provided, we may provide information to Government agencies (central or local). We may carry out on-going due diligence in relation to you and your business with third parties. Other than as set out above, we will not disclose your data to anyone else outside of our group of companies. |
| 3. Your enquiry for one of our office / workshop spaces and assessing your application for one of our office / workshop spaces | |
| Type of Data | We ask you to provide D1, D2, D3, D4, D5 and D7 data as part of the application to consider whether or not you are a suitable candidate for one of our office / workshop spaces. |
| Lawful Basis for Processing | In order to be able to fulfil our agreement with you (assessing the provision of the office / workshop space to you), pursuing our legitimate business interests and to comply with our legal obligation to prevent crimes such as fraud or money laundering. We will only collect D7 data on the basis of your consent. Please note that if you do not provide us with D7 data we will not be able to proceed with your application. Subject to our legal obligations, we will delete (or redact) any D7 data you may have provided to us whether or not your application proceeds. |
| Disclosure | We may undertake searches about you, your business or anyone else named on the application form at credit reference agencies. These agencies will provide us with credit information as well as information from the electoral register and will record details of any searches whether or not your application is successful. We may be under a legal obligation to disclose your data (the data of your business or anyone else named on the application form) to any relevant authority to prevent crimes such as fraud or money laundering. Other than as set out above, we will not disclose your data to anyone else outside of our group of companies. |
| 4. Our obligations as landlord for any office / workshop space that we provide | |
| Type of Data | We ask you to provide D1, D2, D3, D4 and D5 data as part of our obligations as a landlord. Where relevant we may also ask for D8 data so that you can access areas of the building and / or devices that are subject to such security mechanisms. A number of our buildings are fitted with CCTV for security and we may collect D9 information. |
| Lawful Basis for Processing | In order to be able to fulfil our agreement with you (providing the office / workshop space), pursuing our legitimate business interests and to comply with our legal obligation to prevent crimes such as fraud or money laundering. We will only collect D8 data on the basis of your consent. Please note that if you do not provide us with D8 data you will not be able to access the area / device that is the subject of the security mechanism. D9 information is processed in accordance with our legal obligation to keep persons and buildings safe and secure. |
| Disclosure | We may undertake monitoring searches about you or your business at credit reference agencies. These agencies will provide us with credit information as well as information from the electoral register and will record details of any searches whether or not your application is successful. Information will be provided to certain suppliers to enable them to carry out essential services. We may be under a legal obligation to disclose your data (and any data of your business) to any relevant authority to prevent crimes such as fraud or money laundering. We will not disclose D9 data to third parties unless required to do so by law or on request from the authorities. Other than as set out above, we will not disclose your data to anyone else outside of our group of companies. |
| 5. Providing any community support products | |
| Type of Data | We ask you to provide D1, D2, D3, D4 and D5 data as part of our community support programme and any assistance or grants that we may subsequently provide. |
| Lawful Basis for Processing | In order to be able to fulfil our agreement with you (providing the funding), pursuing our legitimate business interests and to comply with our legal obligation to prevent crimes such as fraud or money laundering. |
| Disclosure | We may undertake monitoring searches about you and your business at credit reference agencies. These agencies will provide us with credit information as well as information from the electoral register and will record details of any searches. We may be under a legal obligation to disclose your data (and any data of your business) to any relevant authority to prevent crimes such as fraud or money laundering. Other than as set out above, we will not disclose your data to anyone else outside of our group of companies. |
| 6. Our marketing activities |
|
| Type of Data | We may collect D1, D2, D4 and D5 data as part of the marketing activities that we carry out. This will include our public relations activity and keeping you informed about our business, products or offerings. We may collect D6 data by way of photographs and / or videos. |
| Lawful Basis for Processing | The use of your data is based on our legitimate business interest of keeping you informed and up to date about our activities, products or offerings. If you do not wish to receive such marketing literature, you have the right to opt out of receiving such information. We will only collect and use D6 data in the form of photographs and / or videos on the basis of your consent. |
| Disclosure | We may use D6 data in the form of photographs and / or videos and include them in any press releases or marketing materials that we may issue. Other than as set out above, we will not disclose your data to anyone else outside of our group of companies. |
| 7. Your provision of goods and services to us as a supplier | |
| Type of Data | We may collect D1, D2, D3, D4 and D5 data as part of allowing you to provide us with goods and services. |
| Lawful Basis for Processing | In order to be able to fulfil our agreement with you (the provision of the goods and services), pursuing our legitimate business interests and to comply with our legal obligation to prevent crimes such as fraud or money laundering. |
| Disclosure | We will not disclose your data to anyone else outside of our group of companies. |
| 8. Your provision of services to us in the capacity of a consultant or non-executive director | |
| Type of Data | We may collect D1, D2, D3, D4 and D5 data as part of allowing you to provide us or customers in whom we have made an investment with business advice and support either as a consultant or a non-executive director. |
| Lawful Basis for Processing | In order to be able to fulfil our agreement with you (the provision of the services), pursuing our legitimate business interests and to comply with our legal obligation to prevent crimes such as fraud or money laundering. |
| Disclosure | We may disclose data to our customers who are thinking of using your services but other than this, we will not disclose your data to anyone else outside of our group of companies. |
How Long Do We Store Your Personal Data For?
We will keep your data for as long as you are one of our customers or suppliers or for the purposes of our marketing activities. After you cease to be a customer or supplier, we may keep your data:
- to respond to any questions or complaints you may have
- to show that we treated you fairly
- to maintain records according to rules that apply to us or our internal policies
- if we cannot delete it for legal regulatory or technical reasons
- for research or statistical reasons
If we do keep your data we will make sure that your privacy is protected. We may use D6 data in the form of photographs and / or videos and include them in any press releases or marketing materials that we may issue. Such materials may also appear on our website and may be viewed for as long as the story remains on our website.
We store D9 data for a period of thirty days after which time the recordings are deleted. If we deem it necessary to deliver D9 data to the lawful authorities due to a criminal or similar incident, we may store the D9 data for up to three months or longer if required.
Is My Personal Data secure?
We have implemented safeguards and security appropriate to the size and scope of our business (and our available resources) to ensure that the data that we hold is secured against unauthorised or unlawful processing and against accidental loss, destruction or damage
How Do I Access, Rectify or Erase My Personal Data?
You have various rights under the data protection legislation and further information about these rights can be found on the Information Commissioner’s Office website. In general terms you may contact us if you want to:
- receive access to your data
- rectify your data
- request a copy of the data we have collected from you
You may ask us to erase data that we have collected from you however we must keep data as may be necessary to fulfil our agreement with you and as necessary to comply with law or on request from authorities. Our contact details appear below.
If you consider our use of your data is inappropriate we would ask that you contact us as we may be able to resolve your query or correct any misunderstandings. You may also file a complaint with the Information Commissioner.
Cookies
We use cookies on our website and please see our Cookie Policy for more information.
International Transfer of Personal Data
We do not transfer data outside of the European Economic Area.
Changes to This Policy
We may update this policy from time to time and the updated policy will be published on our website.
Contact Us
If you wish to contact us in connection with our privacy policy and the use of your data you should contact the Company Secretary at UK Steel Enterprise Limited, The Innovation Centre, 217 Portobello, Sheffield S1 4DP.