CLYDE TRAINING SOLUTIONS PRIVACY POLICY

BACKGROUND

1.1 We hope you will enjoy using the Clyde Training Solutions website (our “website”) and we want to make sure your experience is as safe and useful as possible. Here you can find out how our website works, what data we collect from you, how we use it, conditions where we may disclose this data to others and how we keep it secure.

1.2 Clyde Training Solutions is part of is part of Northern Marine Group Ltd (SC474118). (“Northern Marine”“we”“our” and “us”) takes the  issue of security and data protection very seriously and strictly adheres to guidelines published in the United Kingdom Data Protection Act of 1998 and the General Data Protection Regulation (EU) 2016/679 which is applicable from the 25th May 2018. We are data controller of any personal data that you provide us in accordance with this policy.

1.3 Any questions relating to this policy and our privacy practices should be sent to datasecurity@stena.com.

HOW WE COLLECT INFORMATION FROM YOU AND WHAT INFORMATION WE COLLECT

2.1 We collect your personal information in the following ways:

2.1.1 you may give us information about you via our website, or by corresponding with us by e-mail or telephone. This includes information you provide when you contact us via our website, including when you report a problem with our website, or when you correspond with us for any purpose;

2.1.2 by visiting our website we may automatically collect technical information which may form personal information;

2.2 We may collect the following personal information about you where relevant:

2.2.1 name, e-mail address, address, employer and telephone number;

2.2.2 technical information including your IP address, login information, browser type and clicks on our website from your use of our website (for further information see our section on cookies below);

WHY WE NEED THIS INFORMATION ABOUT YOU

3.1 We collect and process personal information held about you: (i) when we are required to comply with a legal obligation; and/or (ii) if the processing is for our legitimate interests or those of a third party, as noted below.

3.2 We need your information and use the information we collect about you:

3.2.1 to enable us to supply you with products and services that you have requested;

3.2.2 to help us with understanding more about how our website is used and to improve the website to ensure that content is presented in the most effective manner;

3.2.3 to be able to respond to your query;

3.2.4 [to be able to send you communications that may be of interest to you, either electronically or otherwise;] and

3.2.5 for all other purposes consistent with the proper performance of our operations.

3.3 We will only use your personal information for the purposes for which we collected it as detailed above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so, or we will seek your consent if required.

MARKETING

4.1 It is your choice whether you receive information such as marketing from us. If you indicated that you are interested in receiving regular information about Northern Marine’s activities, we will send you communications either electronically or by post. In addition, we may send you direct mail that we feel may be of interest to you. We will not contact you for marketing purposes unless you have given your prior consent. If, at any time, you no longer wish to receive this information, please send a written request to datasecurity@stena.com.

4.2 Also, all of our email marketing correspondence gives you the option to opt-out of receiving further marketing emails. Please note that you will still receive emails directly related to an enquiry you have submitted via our contact form.

HOW WE USE COOKIES

5.1 We use cookies, pixels and tags (collectively “Cookies”) on our website in order to help improve our website and provide you with a more personalised web service.

5.2 Cookies are small text files, placed on your hard disk by a web page server. They are uniquely assigned to you, and can only be read by a web server in the domain that issued the Cookie to you.

5.3 We use encrypted information gathered from Cookies to improve your online experience with Northern Marine.

5.4 We use per session Cookies which are deleted when you leave our website. They help keep track of your progress so you don’t have to enter the same information more than once. More specifically we use the following Cookies which carry out the functions described:

5.4.1 __utma – This is a Google Analytics cookie and tracks the number of times you have visited our website.

5.4.2 __utmb and __utmc – This is another Google Analytics cookie and acts to calculate how long you have spent on our website in each session.

5.4.3 __utmz – This Google Analytics cookie tracks what search engine you have visited the website from and which search terms you used to find our website.

5.4.4 Facebook Pixel – this is an analytical tool that helps us measure the effectiveness of our advertising. For more information on our use of pixels please go to: https://www.facebook.com/business/help/651294705016616

5.5 If you wish to restrict or block the cookies which are set by our website, or indeed any other website, you can do this through your browser settings. If you chose to restrict or block any cookies, this may result in certain features of the website not being provided and accordingly you may not be able to take full advantage of the website’s features.

DATA SECURITY

6. Please be aware that the transmission of information via the internet is not always completely secure. Although we will do our best to protect your personal data, we cannot guarantee the complete security of your data transmitted to us electronically; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to restrict unauthorised access.

SHARING OF YOUR INFORMATION

7. The information you provide to us will be treated by us as confidential and will be processed only by our employees. We may disclose your information to other third parties who act for us for the purposes set out in this notice or for purposes approved by you, including group companies, payment providers and marketing suppliers.

TRANSFERS OUTSIDE THE UK AND EUROPE

8. We may transfer your personal information outside the European Economic Area. If we do, you can expect a similar degree of protection in respect of your personal information.

HOW LONG WE WILL KEEP YOUR INFORMATION

9.1 We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you.

9.2 We will generally keep your information as long as is necessary to fulfil our obligations to you after which this will be destroyed if it is no longer required for the reasons it was obtained.

YOUR RIGHTS

10.1 Under certain circumstances, by law you have the right to:

10.1.1 Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;

10.1.2 Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;

10.1.3 Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);

10.1.4 Object to the processing of your personal information where we are relying on a legitimate interest (or a legitimate interest of a third party) and there is something about your particular situation which makes you want to object to processing on this ground;

10.1.5 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it; and

10.1.6 Request the transfer of your personal information to another party.

10.2 If you want to access, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact datasecurity@stena.com.

10.3 You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information.

CHANGES TO OUR PRIVACY POLICY

11.1 Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

PRIVACY NOTICE (APPLICANTS)

1 INTERPRETATION

1.1 In this policy “Northern Marine” is a reference to Northern Marine Group Limited.  “Stena Group” is a reference to the group of companies of which Northern Marine forms part and, where appropriate, any individual company within the Stena Group.  A reference to “we” or “us” is a reference to Northern Marine.  References to “you” are references to the employee or worker covered by this policy.

1.2 “Third party” or “third parties” includes third party service providers (including contractors and designated agents) and other entities within the Stena Group.

1.3 “DCM” means Northern Marine’s Data Compliance Manager, who can be contacted at datasecurity@stena.com or on +(44)1418763000.

2 SCOPE

2.1 This privacy notice is issued under and in terms of the General Data Protection Regulation (“GDPR”) and applies to all individuals applying for roles with us, whether as an employee, via any contractor relationship or otherwise.

2.2 Please note that the relevant Data Protection Policy (or any similar policy or notice which may apply to our contractors from time to time) will apply, as appropriate, should your application be successful and you take up employment with, or are engaged by us.

2.3 You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues.

3 CORE RESPONSIBILITIES OF NORTHERN MARINE AS “DATA CONTROLLER”

3.1 As a “Data Controller” we are responsible for deciding how we hold and use personal data (sometimes referenced as personal information) about you. We are committed to protecting the privacy and security of personal data. This notice is being provided to you so that you are aware of our approach to the management of personal data.

3.2 This notice describes how we collect and use personal data in accordance with the GDPR and it also contains obligations on you.

3.3 We have, in advance of issuing this notice, reviewed the technical and other measures adopted by us to ensure compliance with data privacy principles.

4 ACKNOWLEDGEMENT OF NOTICE

4.1 We require all individuals applying for roles with us to read and act in accordance with this notice.

5 RESPONSIBILITY

5.1 The DCM is ultimately responsible for the matters covered in this notice.

6 ACCOUNTABILITY

6.1 We will make sure we have in place appropriate measures to ensure compliance with the GDPR and this privacy notice, and where appropriate we will carry out and document risk assessments.

7 DATA SECURITY

7.1 We have put in place measures to protect the security of your personal information. These prevent your personal information from being accidentally lost, used or accessed in an unauthor