Here at L1 Renewables Limited, we are committed to protecting your privacy. We are a Controller of personal data as defined under the General Data Protection Regulation (GDPR). This privacy notice is issued on behalf of L1 Renewables Limited and when we mention “L1 Renewables”, “we”, “us” or “our” in this privacy notice, we are referring to the L1 Renewables Limited who are responsible for processing your data.
L1 Renewables Limited is a wholly owned subsidiary of Universities Superannuation Scheme Limited, the sole corporate trustee of the Universities Superannuation Scheme (USS). USS is one of the largest pension schemes in the UK. Established in 1974, USS provides pensions for universities and other higher education institutions in the UK. L1 Renewables has appointed USS Investment Management Limited as its Investment Manager.
We take our obligations very seriously and have appropriate procedures in place to ensure your information and rights are protected. This privacy notice tells you what to expect when we collect your personal data.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Where we think it will assist you in understanding the meaning of some of the terms used in this privacy notice, we have provided an explanation of the terms we use.
• Who this notice applies to.
• How we use your information.
• International Transfers.
• Data Retention.
• Your Rights.
• Contact us.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Who this notice applies to
This notice applies to information we collect about the following persons:
• Certain individuals, in connection with loan arrangements;
• Persons contacting us using the contact details provided on our website or specific business contact details provided directly to them.
How we use your information
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). Depending on which category of person you fall in to will determine what types of personal data we may collect, use, store or transfer.
We may monitor, record, store and use any telephone, email or other communication with you in order to maintain a record of any instructions given to us, for training purposes, for crime prevention, for regulatory purposes, and to improve the quality of our customer service.
In the course of administering a loan arrangement, we may collect personal information from certain individuals. The identifiable personal information we may collect and process is as follows:
• Personal Identifiers e.g. Name, Date of Birth, Passport Number.
• Personal Contact Data e.g. Address (current or previous).
We may collect and process this information for the following purposes:
• For the prevention and detection of fraud and crime.
• To assess the financial stability of a corporate entity to which an individual is connected with.
For these purposes we may disclose your personal data to our third party suppliers who we have engaged with to assist us including professional advisers, external administrators, and legal counsel. In administering your loan we may also disclose your personal information to Universities Superannuation Scheme Limited and USS Investment Management Limited. We take great care to ensure that the information we collect and process about you is held securely and safeguarded and therefore require this of any third party we transfer your information to.
Lawful basis of collection and processing
We will never collect or process your personal information unless it is lawful to do so. The different types of lawful basis used by us to collect and process your personal information for the purposes set out above, are explained in the following section.
• Legal obligation – means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. For example, to carry out checks for the prevention and detection of fraud and crime.
• Performance of Contract – means processing your personal data where it is necessary in relation to the performance of a contract between you and us. For example, to administer the loan agreement entered into by you.
• Legitimate Interest – means the interest of L1 Renewables in conducting and managing our business to enable us to give you the best service, to meet our obligations and to give you the best and most secure experience. Where we hold a strong legitimate interest and it is necessary to process and collect your personal data. We will make certain that this processing does not prejudice your rights and freedoms as an individual. For example, we collect certain information from you to assess the financial stability of the corporate entity to which you as individual are connected to.
Wherever possible we will ensure your data is processed within the European Economic Area (EEA). However should it be necessary to transfer your personal data outside the European Economic Area (EEA), we will ensure appropriate safeguards and levels of protection including contractual provisions are in place and your consent sought where necessary in accordance with the law.
We will store your personal data for no longer than is necessary and in accordance with our records retention policy which takes into account timeframes set out by law and good practice industry guidelines. For example, we will retain your information throughout the relationship with you to administer your loan arrangement. Upon end of relationship, we will retain this data for a minimum of six years, in line with the statute of limitations.
We fully support the enhanced rights for individuals as set out in the General Data Protection Regulation (GDPR). You have the right to be informed about what we do with your personal data, to access your personal data held by us, for it to be accurate and kept up to date, and for it to be deleted, transmitted or its processing by us restricted, if permissible. We do not use your personal data to carry out any automated profiling or make any automated decisions about you.
The following sections provide you with more detail on how you can access a copy of your personal data, how you can ask for that to be transmitted to another service provider or deleted by us, if permissible. It also gives you information on your right to make a complaint to the supervisory authority.
Subject Access Request
You have the right to know what personal data we hold about you, the purpose for which we hold it and who we share it with. You are entitled to receive a copy of your personal data and you can exercise these rights verbally or in writing. We will not charge you a fee to make a subject access request but you must provide us with suitable identification so we can verify that it is you making the request. However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
You have the right to obtain and reuse the personal data we hold about you for your own purposes across different services. You are entitled to receive a copy in a readable format and you can exercise these rights verbally or in writing. We will provide you or the third party to which you consent for us to transmit your personal data to, in a structured, commonly used and machine readable format. We will use secure methods as determined by us to transmit this personal data to you.
Right to Erasure (commonly known as the right to be forgotten)
You have the right to request personal data we hold about you to be deleted. You can exercise these rights verbally or in writing. The right is not absolute and only applies in certain circumstances. However we are committed to giving full consideration to each request and acting on it in accordance with the law. We have procedures in place to inform any onward recipients such as our third party data processors, if we erase any of your data we have shared with them as part of the course of our business.
Right to Rectification
If the information we hold about you is inaccurate you have the right to ask us to rectify it, including completing incomplete information. You can exercise these rights verbally or in writing.
Right to Restrict Processing
You have the right to ask us to restrict how we process your personal data. This means we are permitted to store your data but not to continue to process it. The right is not absolute and only applies in certain circumstances. However we are committed to giving full consideration to each request and acting on it in accordance with the law.
Right to Object
You have the right to object to the processing of your personal data, even if this is based on our legitimate interests. The right applies in certain circumstances however we are committed to giving full consideration to each request and acting on it in accordance with the law.
Time Limit to respond to your requests
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. The ways in which you can contact us directly about the rights listed above can be found on the contact us page on our website here.
Complaints to the supervisory authority
You also have the right to complain to the supervisory authority if you believe we are not processing your information in accordance with the law. The supervisory authority for the United Kingdom is the Information Commissioner’s Office (ICO) and their contact details are available on their website www.ico.org.uk. Please be assured that we take all complaints seriously and if you would like to discuss these in the first instance with us, then you can call (0151) 227 4711.
We take the security of your personal data very seriously. We have put in place appropriate technical, organisational and contractual measures to prevent the unauthorised disclosure or use of your personal data.
To discuss any part of this privacy notice or if you have a query, you can contact us by telephone on (0151) 227 4711 or 0845 068 1110 (local rate call charge number), lines are open Monday – Friday 9am – 5pm. Alternatively you can contact us directly using the details on the contact us page on our website here.
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We may update this privacy notice from time to time without notice to you and any revised privacy notice will appear on this page. You should check back frequently for any updates or changes to this notice.