This Privacy Notice applies to individuals we engage with, including those who submit general enquiries about our work, attend meetings and public events organised by us and sign up to receive our news and communications. We only process personal information for the purpose of delivering our corporate objectives and responding to enquiries, sending out news and communications and managing our meetings and public events.
This Privacy Notice explains what data we process, why we do so, how it is legal and your rights.
About Us and this Privacy Notice
This Privacy Notice is provided by Radioactive Waste Management Limited ("RWM", "we" or "us"). We are a 'controller' for the purposes of the General Data Protection Regulation (EU) 2016/679 and the UK Data Protection Act 2018 ("Data Protection Laws").
We take your privacy very seriously. We ask that you read this Privacy Notice carefully as it contains important information about our processing and your rights.
How to contact us
If you need to contact us about this Privacy Notice or would like this Privacy Notice in another format (for example, audio, large print) please use the details below:
Data Protection Officer
Radioactive Waste Management Limited Building 587
Curie Avenue Harwell Oxford Didcot
Changes to the Privacy Notice
We may change this Privacy Notice from time to time. Changes to the purposes for which we process your data will be highlighted to you.
Information we collect and what we use it for
Website visitors only
If you are just browsing our website, we will not collect personal data.
We process your name, contact details (including social media handles) and details of the enquiry when you send us enquiries about our campaigns (for example, the siting process or the geological disposal facility programme) or other general enquiries. We will use this information to respond to your queries.
News and Communications
We regularly provide news and communications by email and social media platforms and occasionally by telephone with updates on our work, to raise awareness of what we do and generally to invite individuals to get involved and support our work. We process your name, email address and social media handle (where applicable) as a minimum.
We need your name, email address when you fill in our online registration form in order to send you our regular news and communications. There is an option for you to provide us with more information, including additional contact details (address and phone number) in case you would like us to contact you using these methods and you can also provide information about your role and the sector you work in to help us to better understand our audience.
In addition, we obtain names and contact details from publicly available sources (e.g. organisations' websites and social media) and from databases collated by third parties.
Dialogue, Meetings and Public Events
We initiate dialogue, arrange meetings with stakeholders, update our posts on social media platforms and regularly hold public events for stakeholders and members of the public to explain our work and what we do and discuss the latest key issues. We process your name, job description, place of work, industry sector, address, email address, telephone number and details of any enquiries you have previously sent us to arrange your attendance at these meetings and public events.
We proactively try to identify individuals in a position of authority or who have an interest in radioactive waste management such as politicians, key figures within local authorities, community group and business group leaders so that we can engage with them about our work and discuss key issues. In order to identify these stakeholders, we collect information from publicly available sources (e.g. organisations' websites and social media for professional networking) and from third parties. We will only collect the name, contact details and any opinion on the subject of radioactive waste management which is offered. If any stakeholder does not want to receive further communications from us, they can opt out of our communications at any time.
During any public events we will ask you for your feedback, which is entirely optional, on the issues that were discussed, how the events were run and any improvements that we can make and any general comments you have for us. If, during any public event, you ask us to send you any information by email or post, we will collect your name and postal address/email address to respond to your request.
GDF Siting Process
If you apply to RWM or anyone working on behalf of RWM for any expenses incurred in connection with your participation in the Geological Disposal Facility ("GDF") siting process we will need to record and process your personal details, including your name, address and bank details, for us to manage such applications.
In order to develop a GDF we will need to apply for a Development Consent Order ("DCO"). As part of that process we may be required to include within our submission personal data processed during the course of responding to general enquiries and engaging in dialogue, meetings and public events (as explained above) in order to evidence our engagement with stakeholders and members of the public.
Freedom of Information
We will process your name and contact details if you submit a request under the Freedom of Information Act in order to respond to it in line with our respective procedures. We have a dedicated section on our website about making these requests.
How We Keep Your Personal Data Secure
We implement appropriate technical and organisational measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing. We aim to ensure that the level of security and the measures adopted to protect your personal data are appropriate for the risks presented by the nature and use of your personal data.
Legal Basis for Processing Your Information
In relation to responding to general enquiries about our work, identifying individuals to arrange meetings with and processing notes and feedback from our meetings and public events and processing applications for expenses or funding as part of the GDF siting process, we are allowed to process your personal data on the basis that it is necessary for the performance of a task carried out in the public interest which is laid down by law.
In relation to sending you our regular news and communications, invitations to our public events and meetings and processing your data which we have obtained from third party controllers, we are allowed to process your personal data on the basis of your consent. If you no longer wish to receive them, please click the "unsubscribe" link in the emails or contact us using the details in the "How to contact us" section.
Organisations that we may share your data with
For general management and oversight purposes, we share personal information with the Nuclear Decommissioning Authority ("NDA"), as we are a wholly-owned subsidiary of the NDA, and, the relevant government department that sponsors us (please contact us if you would like information on which department sponsors us).
As part of the DCO application process (as explained in the section "Information we collect and what we use it for"), we may provide the Planning Inspectorate with personal data processed during the course of responding to general enquiries and engaging in dialogue, meetings and public events.
Like any business or organisation, we use third party suppliers to assist with our operations such as web page hosting, customer relationship management system hosting, contact centre services and other IT services. These third parties will process your personal data in order to carry out their services for us. For example, the Government Digital Services, which is part of the Cabinet Office, provide our campaign web page hosting services. We take steps to ensure that our service providers process your data in accordance with the Data Protection Laws, only use it in accordance with our contract with them and keep it secure. As part of providing their services, the service providers may from time to time, transfer personal data outside the UK and the European Economic Area. Any such international transfer of your data will be carried out in accordance with the Data Protection Laws to safeguard your privacy rights and give you remedies in the unlikely event of a security breach or to any other similar approved mechanisms. If you would like more information about our processors and any international transfers of your data, please contact us using the details at the "How to contact us" section.
Other than stated above, we do not pass your personal data to third parties, unless required to do so by law or unless we have your consent to do so.
We do not sell or exchange our mailing list with other companies or organisations for marketing purposes.
Retention and Deletion of your Personal Data
We only retain your personal information for as long as we need it in order to provide you with the service you have requested from us.
If you have subscribed to receive information from us via our news and communications or about our public events, we will keep your information until you tell us that you no longer want to receive these emails. You can unsubscribe or manage your preferences via the links in the emails. Alternatively, you can contact us via the details below or via the details on our campaign web page and request us to unsubscribe you.
If you have contacted us with a general enquiry or question about a campaign or we have processed your data as part of our routine dialogue, meetings and public events, we will keep the data for a period of up to 20 years as we need to keep this information in order to evidence our engagement with stakeholders and members of the public as part of the planning applications which will be required to develop a GDF.
If you have provided your personal details to enable us to pay any expenses, we will keep your personal data for the duration of your participation in the GDF siting process and for 3 years after your involvement ends.
Separately, you can ask us to remove your personal information from our systems by contacting us via the details above in the section "How to contact us".
In relation to Freedom of Information requests, we will keep the data if the information request and any appeal period remain active. After this, details of the request will remain on the log but your personal data will be deleted.
You have the following rights under Data Protection Laws:
- Right to object to processing of your personal data
- Right of access to personal data relating to you (data subject access request)
- Right to correct any mistakes in your personal data
- Right to ask us to stop contacting you with direct marketing
- Right to prevent your personal data being processed
- Right to withdraw your consent
- Right to erasure
If you would like to exercise your rights, please contact us at the details set out above in the section "How to contact us" section.
We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex, in which case we will respond within three months.
Please note that exceptions apply to some of these rights which we will apply in accordance with the law.
When you provide us with information, we will process it in accordance with the Data Protection Laws. If you believe your information has not been handled in accordance with this Privacy Notice by RWM, please contact us using the details in the "How to contact us" section.
Alternatively, you may complain to the Information Commissioner's Office. Information about how to do this is available on its website at www.ico.org.uk.