Britain's Energy Coast Business Cluster is committed to ensuring that
your privacy is protected. Should we ask you to provide certain
information by which you can be identified when using this website, then
you can be assured that it will only be used in accordance with this
Britain's Energy Coast Business Cluster may change this policy from
time to time by updating this page. You should check this page from time
to time to ensure that you are happy with any changes.
The policy below is effective from May 2018.
West Cumbria Business Cluster Limited, trading as Britain’s Energy
Coast Business Cluster is a member organisation a data controller for
data protection in respect of the personal data we process.
The Cluster respects the privacy of the people whose personal data we
process and we are committed to protecting it. This privacy notice sets
out what personal data we use, how we use it, how we look after it and
what rights you have. It applies to information we collect in relation
- Members and their employees who interact with us;
- Users of our website;
- People who attend our meetings and events;
- People who contact or interact with us via any medium (e.g. by post, email, telephone or social media).
It is important that you read this notice, which is provided pursuant
to the General Data Protection Regulation and the Data Protection Act
2018) together with any other privacy notice we may provide on specific
occasions when we are collecting or processing personal information
about you, so that you are aware of how and why we are using such
information. This privacy notice supplements the other notices and is
not intended to override them.
Please note that the Cluster is not responsible for how members or
their employees use personal data as part of their business or
charitable activities and you should refer to the relevant member
organisation for further details.
1. Important information
If you have any questions about this privacy notice, including any
requests to exercise your legal rights, please contact Hazel Duhy using
the details set out below:
Postal address: c/o Woodrow Hall, Woodrow, Wigton, Cumbria CA7 0AT
Telephone number: 016973 44905
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 (www.ico.org.uk). We would, however, appreciate the
chance to deal with your concerns before you approach the ICO so please
contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
We reserve the right to update this privacy notice at any time.
It is important that the personal data we hold about you is accurate
and current. Please keep us informed if your personal data changes
during your relationship with us.
Our website includes links to third-party websites, plug-ins and
applications. Clicking on those links or enabling those connections may
allow third parties to collect or share data about you. We do not
control these third-party websites and are not responsible for their
privacy statements. When you leave our website, we encourage you to read
the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about
an individual from which that person can be identified. It does not
include data where the identity has been removed (anonymous data).
We may collect and use the following types of data about you:
- Name, username or similar identifier, title, job title and gender.
- Billing address, delivery address, email address and telephone numbers.
- Photos or videos of you.
- Details of your business interests.
- Internet protocol (IP) address, browser type and version, time zone
setting and location, browser plug-in types and versions, operating
system and platform and other technology on the devices you use to
access our website.
- Information about how you use our website.
- Details about your preferences for your preferences in receiving information from us and your communication preferences.
We do not collect or process any Special Categories of Personal
Dataabout you (this includes details about your race or ethnicity,
religious or philosophical beliefs, sex life, sexual orientation,
political opinions, trade union membership, information about your
health and genetic and biometric data) but will update this privacy
notice and notify you if this changes.
If you fail to provide personal data
There is no requirement on you to provide us with any personal data;
however, if you fail to do so other members and potential business
contacts will not be able to find your contact details on our website,
promotional material created by us or by asking us for it.
3. How is your personal data collected?
We use different methods to collect personal data from and about you including:
- Direct interactions. You may give us your personal data by filling
in forms or by corresponding with us by post, phone, email or otherwise.
This includes personal data you provide when you:
- Join the Cluster as a member;
- Provide details to us at member meetings or events;
- Request information to be sent to you; or
- Interact with us about business activities or member events.
- Automated technologies or interactions. As you interact with our
website, we may automatically collect technical data about your
equipment, browsing actions and patterns. We collect this personal data
by using cookies, server logs and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- From your employer, who may be a member, seeking to become a member
or otherwise interacting with our members via the Cluster;
- From members or businesses;
-Technical data from search engines and analytics providers;
- Details from publicly availably sources.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most
commonly, we will use your personal data in the following circumstances:
- Where we need to comply with a legal obligation.
- Where it is necessary for our legitimate interests (or those of a
third party), by which we mean in the interest of the Cluster’s business
or our members in conducting and managing our/their business. We have
assessed the potential impact on individuals (both positive and
negative) and do not consider that the legitimate interests of the
Cluster or our members are overridden by any potential impact on you.
Our legitimate interests are as follows;
- Providing a network for our member organisations to share knowledge and opportunities, including via events and member meetings;
- Educating the local and wider business community about member capabilities;
- Lobbying external stakeholders on behalf of our members;
- Advising, assisting and supporting member organisations;
- Identifying and providing training and skills transfer and employment opportunities amongst members and the local area.
Generally we do not rely on consent as a legal basis for processing
your personal data. We send relevant information about member meetings
and events to members and businesses that have requested
information. Whilst we don’t consider this to be unsolicited direct
marketing we will nevertheless stop emailing such information at any
time if you ask us to stop.
Purposes for which we will use your personal data
We have set out below the ways we plan to use your personal data:
- Internal record keeping and administration, including in relation
to your attendance at member meetings, events or training
- Contacting you via any medium in relation to member meetings, events or business opportunities.
- Using your images for marketing purposes.
- Sharing your details with other members and external businesses for
the purposes of providing you with potential business opportunities.
Change of purpose
We will only use your personal data for the purposes for which we
collected it, 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
Please note that we may process your personal data without your
knowledge or consent, in compliance with the above rules, where this is
required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below:
- Consultants and subcontractors acting on our behalf.
- Professional advisers including lawyers, accountants, bankers, auditors and insurers.
- Suppliers of goods and services to us.
- Other members.
- Businesses who are not members but who might represent a business opportunity for you or the member you represent.
We do not allow our third-party processors to use your personal data
for their own purposes and only permit them to process your personal
data for specified purposes and in accordance with our instructions.
6. International transfers
We will only transfer your personal data out of the EEA (for example
where there is a potential business opportunity for you or the member
you represent involving a non-EEA organisation or nation) with your
explicit consent. Ordinarily, we will provide you with details of the
opportunity so that you can decide whether to supply any personal data
7. Data security
We have put in place appropriate security measures to prevent your
personal data from being accidentally lost, used or accessed in an
unauthorised way, altered or disclosed. In addition, we limit access to
your personal data to those employees, agents, contractors and other
third parties who have a business need to know. They will only process
your personal data on our instructions and they are subject to a duty of
We have put in place procedures to deal with any suspected personal
data breach and will notify you and any applicable regulator of a breach
where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to
fulfil the purposes we collected it for, including for the purposes of
satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we
consider the amount, nature, and sensitivity of the personal data, the
potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data and
whether we can achieve those purposes through other means, and the
applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it
can no longer be associated with you) for research or statistical
purposes in which case we may use this information indefinitely without
further notice to you.
9. Your legal rights
You have the right to:
- Request access to your personal data (commonly known as a "data
subject access request"). This enables you to receive a copy of the
personal data we hold about you and to check that we are lawfully
- Request correction of the personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about
you corrected, though we may need to verify the accuracy of the new
data you provide to us.
- Request erasure of your personal data. This enables you to ask us
to delete or remove personal data 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 data where you have successfully exercised your
right to object to processing (see below), where we may have processed
your information unlawfully or where we are required to erase your
personal data to comply with the law. Note, however, that we may not
always be able to comply with your request of erasure for specific legal
reasons which will be notified to you, if applicable, at the time of
- Object to processing of your personal data where we are relying on a
legitimate interest (or those of a third party) and there is something
about your particular situation which makes you want to object to
processing on this ground as you feel it impacts on your fundamental
rights and freedoms. You also have the right to object where we are
processing your personal data for direct marketing purposes. In some
cases, we may demonstrate that we have compelling legitimate grounds to
process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This
enables you to ask us to suspend the processing of your personal data in
the following scenarios: (a) if you want us to establish the data's
accuracy; (b) where our use of the data is unlawful but you do not want
us to erase it; (c) where you need us to hold the data even if we no
longer require it as you need it to establish, exercise or defend legal
claims; or (d) you have objected to our use of your data but we need to
verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third
party. We will provide to you, or a third party you have chosen, your
personal data in a structured, commonly used, machine-readable format.
Note that this right only applies to automated information which you
initially provided consent for us to use or where we used the
information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to
process your personal data. However, this will not affect the lawfulness
of any processing carried out before you withdraw your consent. If you
withdraw your consent, we may not be able to provide certain products or
services to you. We will advise you if this is the case at the time you
withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to
exercise any of the other rights). However, we may charge a reasonable
fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these
What we may need from you
We may need to request specific information from you to help us
confirm your identity and ensure your right to access your personal data
(or to exercise any of your other rights). This is a security measure
to ensure that personal data is not disclosed to any person who has no
right to receive it. We may also contact you to ask you for further
information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month.
Occasionally it may take us longer than a month if your request is
particularly complex or you have made a number of requests. In this
case, we will notify you and keep you updated but comply in any event
within 3 months of receiving your request (or any further information
requested from you).