Privacy Policy
Our Privacy Policy describes the categories of personal data we process and for what purposes. We are committed to collecting and using such data fairly and in accordance with the requirements of the General Data Protection Regulations (GDPR).

Introduction
We take your privacy seriously and you can find out more here about your privacy rights and how we gather, use and share your personal information – that includes the personal information we already hold about you now and the further personal information we might collect about you, either from you or from a third party. How we use your personal information will depend on the products and services we provide to you.

How we gather personal information
The information we hold is the information you provide to us directly, or through our website. We collect personal information in a number of ways:

  • directly from you, for example over the phone or when you fill out an application;
  • from other organisations such as housing associations and landlords;
  • We also may obtain some personal information from monitoring or recording calls and when we use CCTV.
    We will record or monitor phone calls with you for regulatory purposes, for training and to ensure and improve quality of service delivery, to ensure safety of our staff and customers, and to resolve queries or issues. We also use CCTV on our premises to ensure the safety and security of our staff, customers and suppliers;
  • Through our website:

Cookies
Cookies are small text files containing information sent by a web server to a web browser, and stored on your computer, tablet or mobile phone when you visit certain web pages. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.

Our website uses the following categories of cookies:

“Session cookies” – these keep track of you while you navigate our website, and will be deleted from your computer when you close your browser.

“Persistent cookies” – these enable our website to recognise you when you visit, and they remain stored on your computer until deleted, or until they reach a specified expiry date. They enable us to remember details such as your preferences and enable us to give you a better service.

We use Google Analytics to analyse the use of our website. Google Analytics generates statistical and other information about use of our website such as number of new visitors to our website, how long visitors spend browsing our website and which pages they viewed by means of cookies which are stored on user’s computers.

You can find out more about Google Analytics here: www.google.co.uk/intl/en/policies/privacy/.

Where our website contains links to other websites this privacy policy will not apply to those third-party website. When you link through to another website you should read the privacy policy which applies to that website.

Log files / IP addresses
When you visit our website, we automatically log your IP address (the unique address that identifies your computer on the internet) which is automatically recognised on our webs server. We may use IP addresses to help us administer our website and to collect brand demographic information for aggregate use. We do not link IP addresses to personally identifiable information.

How we use your personal information
We use your personal information to provide you with products and services, to comply with the law and enforce our legal rights (including debt recovery), and to improve and market our products and services.

To provide you with any products and services we need to know your name, address, contact telephone number and in some cases email address.

We sometimes need to gather, use and share additional personal information for specific purposes, which are set out in more detail below.

1.1 To operate and administer our products and services, including dealing with your complaints and fixing our mistakes, we will use:

  1. your contact details;

We might share all of the information we use for this purpose with third parties who help us to verify your contact details and deliver our products and services, such as our subcontractors. We use your information in this way because it is necessary to perform our contract with you and to meet our legal obligations.

1.2 To administer payments to and from you, we will use:
We may give this information to our third party payment providers to process the payment to you.

1.3 To comply with our legal obligations, to prevent financial crime including fraud and money laundering we will use:

  1. any information you have given us, that we have obtained from a third party, or that we have obtained by looking at how you use our services, where it is necessary for us to use that information to comply with a legal obligation; and
  2. this information will include name, address.
  3. We will give information to and receive information from third parties where that is necessary to meet our legal obligations, including credit reference agencies, fraud prevention agencies, the police and other law enforcement and government agencies, other banks and regulators. Fraud prevention agencies may use your information as set out in clause 1.3 above.

1.4 To comply with our legal obligations, to support our vulnerable customers:

  1. information you give to us which identifies a vulnerability (such as a health condition); and
  2. information we may receive from another Group company which identifies vulnerability.

We will give information to and receive information about a vulnerability from third parties where that is necessary to meet our legal obligations, for example from police, social services or someone acting on your behalf.

1.5 For financial management and debt recovery purposes, we will use:

  1. your contact details;
  2. information we obtain from looking at how you have used our services, including information about your location that we may find from reviewing your accounts; and

We will give information to and receive information from third parties where that is necessary to recover debts due by you to us, for example debt recovery agents’ sheriff officer or bailiff services. This might include passing personal information about you to a third party who we have transferred your debt to, and who will then contact you directly to collect that debt. If your debt is transferred to a third party you will be advised of the identity of that third party.

We use your information in this way because it is necessary to perform our contract with you, to exercise our legal rights, and because it is fair and reasonable for us to do so.

2. Our legal basis for using your personal information

2.1 We only use your personal information where that is permitted by the laws that protect your privacy rights. We only use personal information where:

  1. we have your consent (if consent is needed);
  2. we need to use the information to comply with our legal obligations;
  3. we need to use the information to perform a contract with you; and/or
  4. it is fair to use the personal information either in our interests or someone else’s interests, where there is no disadvantage to you – this can include where it is in our interests to contact you about products or services, market to you, or collaborate with others to improve our services.

Where we have your consent, you have the right to withdraw it. We will let you know how to do that at the time we gather your consent.

Our products and services
We need some personal information before we can provide our products and services to you, for example to allow us to check your identity. In some cases we won’t be able to provide products and services to you if we don’t have all the personal information we need.

Sharing and transferring personal Information
We share personal information with our suppliers and other third parties where needed to provide you with the best service.

Keeping personal information
We keep your personal information securely for as long as we need it for legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements.

Your consent
Sometimes we need your consent to use your personal information (for example for marketing). We won’t always need consent to use personal information – for example if we need it to meet regulatory requirements or to perform a contract with you. Where you have given us consent, you have the right to withdraw it at any time.

Your rights and requests
You have rights when it comes to how we handle your personal data. These include rights to:

(a)  withdraw consent to processing at any time;
(b)  receive certain information about our processing activities;
(c)  request access to their personal data that we hold;
(d)  prevent our use of their personal data for direct marketing purposes;
(e)  ask us to erase personal data if it is no longer necessary in relation to the purposes for which it was collected or processed or to rectify inaccurate data or to complete incomplete data;
(f)  restrict our processing in specific circumstances;
(g)  challenge our processing where we have sought to justify it on the basis of our legitimate interests or in the public interest;
(h)  request a copy of an agreement under which we transfer the personal data outside of the EEA;
(i)  prevent processing that is likely to cause damage or distress to the data subject or anyone else;
(j)  be notified of a personal data breach which is likely to result in high risk to their rights and freedoms;
(k)  make a complaint to the supervisory authority; and
(l)  in limited circumstances, receive or ask for their personal data to be transferred to a third party in a structured, commonly used and machine readable format.

You do not have to provide us with this data but without it we cannot provide you with our services.

From time to time, we add or change functions, features or products to our website or add or change services. This, and our commitment to protecting the privacy of your personal information, may result in periodic changes to this Privacy Policy. We will make every effort to inform you of any changes.

If you would like further information regarding the use or storage of your personal data please address your correspondence to the Data Protection Officer:

Martina Healy
T.B. Mackay Energy Services
Granton House
219 Granton Road
Edinburgh
EH5 1AB

Email: martina.healy@tbmes.co.uk
or call 0131 552 6103 between 9am and 5pm (GMT) Mon-Fri.

Complaints
We are committed to ensuring that your personal data is processed lawfully, fairly and securely. If you have any questions or concerns about the way in which we process your data please contact us at the address above and we will attempt to resolve any issues you have. If you remain unsatisfied you can contact the Information Commissioner’s Office.