Privacy Policy 

Who we are

Our website address is: https://solarus.co.uk.

1. INTERPRETATION

1.1 DEFINITIONS:
Automated Decision-Making (ADM): when a decision is made which is based solely on Automated Processing (including profiling) which produces legal effects or significantly affects an individual. The UK GDPR prohibits Automated Decision-Making (unless certain conditions are met) but not Automated Processing.

Automated Processing: any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of Automated Processing.

Solarus Energy Ltd
Limited company registered in England under company number 10560692.

Company Personnel: all employees, workers, contractors, agency workers, consultants, directors, members and others.

Consent: agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject’s wishes by which they, by a statement or by a clear positive action, signifies agreement to the Processing of Personal Data relating to them.

Data Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the UK GDPR. We are the Data Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes.

Data Subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.

Data Privacy Impact Assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing activity. DPIA can be carried out as part of Privacy by Design and should be conducted for all major system or business change programs involving the Processing of Personal Data.

Data Protection Officer: the person required to be appointed in specific circumstances under the UK GDPR. Where a mandatory Data Protection Officer has not been appointed, this term means a data protection Representative or other voluntary appointment of a nominated representative or refers to the Company data privacy team with responsibility for data protection compliance.

EEA: the 28 countries in the EU, Iceland, Liechtenstein and Norway.

Explicit Consent: consent which requires a very clear and specific statement (that is, not just action).

UK General Data Protection Regulation (UK GDPR): the UK General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the UK GDPR.

Personal Data: any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Sensitive Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour.

Personal Data Breach: any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach.

Privacy by Design: implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the UK GDPR.

Privacy Guidelines: the Company Data Management and Retention Policy provided to assist in interpreting and implementing this Privacy Policy and Related Policies.

Privacy Notices: separate notices setting out information that may be provided to Data Subjects when the Company collects information about them.

Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.

Pseudonymisation or Pseudonymised: replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure.

Related Policies: the Company’s policies, operating procedures or processes related to this Privacy Policy are designed to protect Personal Data, available in the Company Handbook.

Sensitive Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and Personal Data relating to criminal offences and convictions.

2. INTRODUCTION

This Privacy Policy sets out how Solarus Energy Ltd (”we”, “our”, “us”, “the Company”) handle the Personal Data of our customers, suppliers, employees, workers and other third parties.

This Privacy Policy applies to all Personal Data we Process regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other Data Subject.

This Privacy Policy applies to all Company Personnel (”you”, “your”). You must read, understand and comply with this Privacy Policy when Processing Personal Data on our behalf and attend training on its requirements. This Privacy Policy sets out what we expect from you in order for the Company to comply with applicable law. Your compliance with this Privacy Policy is mandatory. Related Policies and Privacy Guidelines are available to help you interpret and act in accordance with this Privacy Policy. You must also comply with all such Related Policies and Privacy Guidelines. Any breach of this Privacy Policy may result in disciplinary action.

The Data Protection Representative is Emma Coleman.

3. SCOPE

We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times. The Company is exposed to potential fines of up to EUR20 million (approximately £17.5 million) or 4% of total worldwide annual turnover, whichever is higher and depending on the breach, for failure to comply with the provisions of the UK GDPR.

All directors and managers are responsible for ensuring all Company Personnel comply with this Privacy Policy and need to implement appropriate practices, processes, controls and training to ensure such compliance.

The Data Protection Representative is responsible for overseeing this Privacy Policy.

Please contact the Data Protection Representative with any questions about the operation of this Privacy Policy or the UK GDPR or if you have any concerns that there may have been a data breach. Please refer to the Data Management and Retention Policy for details on how to handle individual rights requests.

4. PERSONAL DATA PROTECTION PRINCIPLES

We adhere to the principles relating to Processing of Personal Data set out in the UK GDPR which require Personal Data to be:

(a) Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).

(b) Collected only for specified, explicit and legitimate purposes (Purpose Limitation).

(c) Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation).

(d) Accurate and where necessary kept up to date (Accuracy).

(e) Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation).

(f) Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality).

(g) Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).

(h) Made available to Data Subjects and Data Subjects allowed to exercise certain rights in relation to their Personal Data (Data Subject’s Rights and Requests).

We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).