The privacy and security of your personal data is of the utmost importance to Spirax-Sarco Engineering plc (Spirax Sarco) and we invest heavily in measures that help protect your personal data and operate in a way that meets your data protection rights.
This policy describes how and why we collect, store, process and manage the personal data we hold from our data subjects. The term “Personal Data” refers to any data relating to an identifiable individual or his or her personal identity, including (for example) name, email address, home address, telephone number, debit/credit card data or date of birth.
This policy outlines how your data will be processed lawfully, fairly and in a transparent manner.
Spirax Sarco will never sell or rent your Personal Data to third parties for marketing purposes.
We will ensure that the Personal Data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process Personal Data obtained for one purpose for any unconnected purpose unless the person has agreed to this or would otherwise reasonably expect this.
Spirax Sarco collects your Personal Data in order to manage your relationship with us and to communicate with our shareholders. We also collect your data so that we can send you news announcements, for which you have provided your consent. Spirax Sarco has appointed a Data Protection Office (DPO) that is responsible for ensuring that Personal Data is managed responsibly throughout the Company. You can contact the DPO using the details listed at the end of this policy.
You have the right to see the data we hold on you, rectify that data and also request us to delete that data at any time.
1. Introduction
1.1 Spirax Sarco is defined as the data controller with regard to all of the information contained within this document.
1.2 This Privacy Policy sets out the way in which Spirax Sarco collects and processes Personal Data of its data subjects. Spirax Sarco is registered for the purposes of data protection with the Information Commissioner's Office in the UK (registration reference: Z8234137).
1.3 By using our services and/or registering your consent, you acknowledge that you have read and agree to the terms of this Privacy policy in relation to processing under legitimate interests.
2. The data we collect
2.1 We collect your Personal Data when you register your interest through the use of online forms and when you email your details to us.
2.2 In addition, we may collect Personal Data through surveys which we undertake. Such surveys are voluntary and are anonymous where possible.
3. Your rights as a "data subject"
3.1 Under data protection law you retain the following rights over your personal data:
- the right to access the data we hold about you;
- the right to rectification of any data that is inaccurate or incomplete;
- the right to erasure of your data (also known as "the right to be forgotten");
- the right to restrict processing of your data;
- the right to data portability;
- the right to object to the processing of your data; and
- rights in relation to automated decision making and profiling.
3.2 If you exercise your right to be forgotten, this would result in a termination of your relationship with Spirax Sarco.
4. Our basis for processing Personal Data
4.1 For the purpose of managing our business, it is important for us to maintain your Personal Data.
4.2 It is a requirement of our Terms and Conditions that any person who wishes to attend or benefit from the services offered by us should provide the necessary Personal Data.
4.3 Data collected and processed for the purposes of your engagement with us is done so under the basis of a legitimate interest. The justification for this is outlined in paragraph 4.1 above.
5. How we use your Personal Data
Your Personal Data is processed by us to provide you with the products and services relating to our business. In particular, we collect your Personal Data in order to enable us to:
- set-up, administer and manage your relationship, associated accounts and records;
- receive and respond to your communications and requests;
- notify you about promotional offers and general marketing;
- ensure that we are able to fulfil our regulatory obligations regarding your account, including by verifying the accuracy of any information you give us;
- comply with our obligations under applicable laws;
- investigate, and assist with the investigation of, suspected unlawful, fraudulent or other improper activity connected with the services (including, where appropriate, dealing with requests from regulatory bodies for the sharing of information);
- carry out market research campaigns; or
- in the event that we sell or buy any business, assets or shares in part or whole we may disclose your personal details to such relevant third parties involved.
6. Disclosure of your Personal Data
We may disclose your Personal Data to any of the following recipients:
- any company within our Group (including to its employees and sub-contractors) that assists us in providing the services or that otherwise has a need to know such information;
- any contractors or other advisers auditing any of our business processes or who have the need to access such information for the purpose of advising us;
- any data processor that enables us to manage our systems or processes as part of any service or promotion offered to you. However, we will take reasonable steps to ensure that these data processors are compliant with requirements of the Data Protection Act 1998 and the General Data Protection Regulations;
- any law enforcement or regulatory body which may have any reasonable requirement to access your Personal Data; or
- in the event that we sell or buy any business, assets or shares in part or whole we may disclose your personal details to such relevant third parties involved. 7. Marketing preferences
7. Marketing preferences
7.1 We will not send you unsolicited information regarding any third party’s products or services.
7.2 You will have the opportunity to choose whether or not to receive information on our offers and promotions. This consent is subject to the data retention periods defined within this policy.
7.3 We will assume legitimate business purpose in sending marketing communication whilst including the option to opt out every time such communications are sent out to you. The product, service or ideals we are marketing to you are the same or similar to those that you originally consented to receive marketing for at time of enrolment, and therefore it is reasonable for you to receive marketing material from us.
7.4 Our local marketing policies contain further information relating to marketing preferences, copies of which are available on request.
8. Accessing and updating your Personal Data
8.1 You may update your Personal Data at any time by contacting the Data Protection Office using the details below.
8.2 You may obtain a copy of your Personal Data held by us by contacting:
The Data Protection Office
Spirax-Sarco Engineering plc
Charlton House
Cirencester Road
Cheltenham
Gloucestershire
GL53 8ER
United Kingdom
Tel: +44 (0)1242 521361
Email: gdpr.sars@uk.spiraxsarco.com.
We will process your request within the timeframes as prescribed by the relevant regulations but may need to contact you to obtain further information.
8.3 Requests for access to your personal data are free of charge.
9. How long do we keep your data for?
9.1 We retain your data for no longer than is necessary. This length of time is different for each type of personal data that we hold. These retention periods are subject to change only where deemed necessary by the Data Protection Office where there is a defined vital interest under data protection law.
9.2 Our Retention Policies relating to the data in question contain further information on retention periods, a copy of which are available on request.
10. Security
We use a number of methods to ensure that all customer information remains confidential. We have developed a comprehensive policy for data protection management that is reviewed and updated as necessary.
11. Complaints
11.1 Spirax takes the protection of the Personal Data we hold very seriously and is happy to receive any queries or concerns you may have. If you believe that we have not adhered to this policy or that your data has been handled in a way that you feel is not in accordance with your wishes then you may complain to the Data Protection Office using the contact details below.
The Data Protection Office
Spirax-Sarco Engineering plc
Charlton House
Cirencester Road
Cheltenham
Gloucestershire
GL53 8ER
United Kingdom
Tel: +44 (0) 1242 521361
Email: dpo@uk.spiraxsarco.com
11.2 Alternatively, you may contact the Information Commissioners Officer (ICO) directly who are the body responsible for managing data protection compliance in the UK. You can contact the ICO at the following address:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: +44 (0)303 123 1113
Email: casework@ico.org.uk
12. Contact information
Please contact us via the contact form on our website or in writing at:
The Data Protection Office
Spirax-Sarco Engineering plc
Charlton House
Cirencester Road
Cheltenham
Gloucestershire
GL53 8ER
United Kingdom
Tel: +44 (0) 1242 521361
Email: dpo@uk.spiraxsarco.com