Purpose

Welcome to TWMA’s privacy policy for information relating to individuals who are not employed or contracted to any of the TWMA group of companies.

TWMA respects your privacy and is committed to protecting your personal data.

Scope 

This privacy policy  will inform you as to how we look after your personal data when you are considering becoming a customer of ours or a supplier to us, or you visit our website, visit us on one of our trade stands or at one of our facilities (regardless of where you visit it from) or when you email or communicate with us; and tell you about your privacy rights and how the law protects you.

This privacy policy is NOT intended to apply to you if you are:

• a child (as we do not knowingly collect data relating to children); or
• applying for a vacancy we are currently advertising on our website; or
• an employee of TWMA;
• an existing contractor or consultant to TWMA regulated under a contract for services; or
• an existing customer of ours or a supplier to us regulated under a contract.

If you are applying for a vacancy we are currently advertising, please access our Candidate Recruitment Privacy Policy by clicking on the ‘Privacy’ section at the bottom of the home page of our website. 

For TWMA employees we have a Privacy Policy for employees which informs you about our privacy policy, which is made available internally.

If you have a contractual relationship with us as a supplier (including consultants or contractors) or are a customer of ours, please look to this Privacy Policy as indicative of our general data protection policies and also look to the contractual documentation which supports our relationship with each other in order to identify and understand the privacy obligations we have towards each other.

1.3       Responsibilities    

It is important that you read this privacy policy together with any other privacy policy 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 policy supplements those other privacy policies and is not intended to override them.

If you want to know more about our company and our services it is important that you read this privacy policy. 

Alternatively, you can get in touch with us using the contact details outlined in this policy for a pdf version of this or any other of our privacy policies.

Definitions and References

Please use the Glossary to understand the meaning of some of the terms used in this privacy policy.

This policy is divided up into the following specific areas:

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW WE COLLECT AND USE YOUR PERSONAL DATA
4. THE PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
5. IF AND HOW WE SHARE YOUR PERSONAL DATA
6. YOUR CONSENT AND YOUR LEGAL RIGHTS
7. INTERNATIONAL TRANSFERS
8. DATA SECURITY AND DATA RETENTION
9. MORE INFORMATION AND GLOSSARY

PURPOSE OF THIS PRIVACY POLICY 

This privacy policy aims to give you information on how TWMA collects and processes your personal data through (i) your use of this website; (ii) if you visit us at one of our stands at a trade show or at one of our facilities; or (iii) if you communicate with us by email or other form of correspondence.

WHO WE ARE

TWMA is made up of different legal entities, details of which can be found on our website and at the end of this policy. When we mention “TWMA”, we are referring to the relevant company in the TWMA Group responsible for processing your data which will be clear to you when interact with us or  use our website. TWMA Group Limited is the controller responsible for this website.

COMPLIANCE TEAM

We have appointed a Compliance Team. If you have any questions about this privacy policy, or our data protection practices please contact the Compliance Team in one of the following ways:

CONTACT DETAILS

By post:

Compliance Team

TWMA Ltd

Level 1, Building 3,

AIBP,

Dyce Drive,

Aberdeen,

AB23 0BR

Or by email: compliance@twma.com

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 POLICY AND YOUR DUTY TO INFORM US OF CHANGES 

We keep our privacy policy under regular review.  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 interaction or relationship with us.

THIRD-PARTY LINKS 

This website may include 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 policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.

When you use our website, we may collect, use, store and transfer different kinds of data about you as follows:

• your Identity Data (your name).
• your Contact Data (your email address or other contact details).
• For the purposes of Usage Data analysis(frequency of and website information people are most interested in), we use Google Analytics but the analysis is anonymised in order that your personal data as defined above (i) & (ii) will not be processed for this purpose during your interaction with our website.
• With your express, prior opt-in consent, we may seek permission to collect and store your personal information as defined above (i) & (ii) for the purposes of Marketing and Communications Data (the aspects of TWMA that are or may be of interest to you). 

We do NOT collect any Special Categories of Personal Data about 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). Nor do we collect any information about criminal convictions and offences.

As you interact with our website, we will automatically collect Usage Data and Technical Data about your equipment, browsing actions and patterns.  We collect this using Google Analytics and Cookies. 

Cookies Notice

Cookies are small data files created on your computer when you visit a website.  Cookies store information to personalise a user experience.  You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

We do NOT subject your data to automated decision making during your website interaction.

We will use your name and contact details to respond legitimately and lawfully to any queries you have placed in our contact form.

If you have communicated with us by email or contacted us with an enquiry on our services or regions in which we work around the world, or have visited one of our TWMA facilities or marketing stands at any trade show, we may have taken your business card or recorded some personal details about you in another format.,  We will treat your personal data in the same way as we would treat any personal data as if it were collected on our website.  If you have visited us in facilities where we share space with third parties, then those third parties may also collect your personal data (Name, contact and car registration) for legitimate security purposes.

The rest of this Policy tells you about what we do if we have collected any personal data about you.

The personal date we collect about you will be processed in compliance with the obligations we have a legal duty to comply with, which are explained below.  We will only use your personal data for the purpose for which we collected it.

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

MARKETING  

We will NOT collect any personal data for direct marketing to you unless we obtain your prior express opt-in consent to do so.  In the event that we request your consent, the consent form will advise you of what decisions you can make about our use of your personal data for this purpose and allow you the relevant personal data control mechanisms.

THIRD-PARTY MARKETING  

We do NOT share any personal data with any third-party marketing companies.  If we would like to do this, we will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT  

If you do ever give us your consent to send you marketing information or have third parties send you marketing information, you can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us requesting a Subject Access Request at: compliance@twma.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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.

We will NOT share your information with any External Third parties unless we obtain your prior express opt-in consent.  Please see the Glossary for the explanation of what these may be.

We may share your personal data internally within the TWMA group of entities depending on the jurisdiction of operations you show an interest in, on a strictly need to know basis, in order that we can respond to your needs.  This is known as Internal Third Parties as set out in the Glossary.

We may share your personal data with related Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties whether they are external or internal, to respect the security of your personal data and to treat it in accordance with the law.

We do NOT allow our third-party service providers 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.

The only time we may transfer your personal data to an international location is if you are interested in the services we offer in any of our group of companies located internationally to the UK or if you are applying for a vacancy we are advertising on our website which is for work located in one of our companies which are based internationally to the UK. 

Our Privacy Policy – For Employees (Internal) and this Policy which includes the processes and procedures are implemented throughout all of our international group locations which means that our internationally located companies will treat your personal data with the same levels and standards of privacy as we do in the UK.

As detailed above, 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 perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Under certain circumstances, you have rights under data protection laws in relation to your personal data including the right to receive a copy of the personal data we hold about you and the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk). 

Your legal rights allow you 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 processing it.
• 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 local 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 your request.
• 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:
• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• 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.
• 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 at compliance@twma.com

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 could refuse to comply with your request in these circumstances.

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 could 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.

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 internal 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 confidentiality.

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.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

For more detailed information on our data security and data retention policies, please refer to our Group Policies listed at the end of this policy and either contact us to request the relevant policy or  clicking on the ‘Privacy’ section at the bottom of the home page of our website.

GLOSSARY      

LAWFUL BASIS:

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES:

INTERNAL THIRD PARTIES  

Other companies in the TWMA Group acting as joint controllers or processors and who are based in the UK; EEA; USA and Middle East and provide system administration services and undertake leadership reporting.

EXTERNAL THIRD PARTIES  

• Service providers acting as processors based in the UK; EEA; USA and Middle East who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, pension providers, occupational health providers and insurers based in the UK; EEA; USA and Middle East who provide consultancy, banking, legal, insurance and accounting services.
• Tax Authorities, regulators and other authorities based in the UK; EEA; USA and Middle East who require reporting of processing activities in certain circumstances.

TWMA GROUP OF COMPANIES

TWMA Group Ltd

Registered Office: Blackwood House, Union Grove Lane, Aberdeen, United Kingdom, AB10 6XU

Business Address: Level 1, Building 3, AIBP, Dyce Drive, Aberdeen, United Kingdom, AB23 0BR

Company Registration Number SC205718

Total Waste Management Alliance Ltd

Registered Office: Blackwood House, Union Grove Lane, Aberdeen, United Kingdom, AB10 6XU

Business Address: Level 1, Building 3, AIBP, Dyce Drive, Aberdeen, United Kingdom, AB23 0BR

Company Registration Number SC203064

Total Waste Management International Ltd

Registered Office: Blackwood House, Union Grove Lane, Aberdeen, United Kingdom, AB10 6XU Business Address: Level 1, Building 3, AIBP, Dyce Drive, Aberdeen, United Kingdom, AB23 0BR

Company Registration Number SC212585

TWMA Norge AS

Registered & Business Address: Jåttåvågveien 7B, 2nd Floor, 4020 Stavanger, Norway

Company Registration  Number 991616969

TWMA Egypt for Oil Services SAE

Business Address: 64 Street 13, Port Saeid Square Maadi, Cairo, Egypt, or

Street 12 Alex Public Free Zone, Alexandria, Postal code 23512, Egypt

Commercial Registration Number 902

TWMA Middle East Ltd

Registered Office: Blackwood House, Union Grove Lane, Aberdeen, United Kingdom, AB10 6XU

Company Registration Number SC067091

Total Waste Management Alliance Inc

Business Address: c/o Dynamic Oilfield Services LLC (DBA/TA: TWMA USA), 10235 West Little York Road, Suite 425, York Centre, Houston, Texas, 77040

Registered Office; CT Corporation, 350 N. St. Paul Street Dallas, TX 75201

Charter Number; 01635330

Dynamic Oilfield Services LLC (DBA/TA: TWMA USA)

Business Address: 10235 West Little York Road, Suite 425, York Centre, Houston, Texas, 77040

Registered Office; CT Corporation, 350 N. St. Paul Street Dallas, TX 75201

Charter Number; 01635330

TWMA Group IT Policy

TWMA Group Data Retention Policy

TWMA Group Privacy Policy – For Employees

TWMA Group CCTV Policy

TWMA Group Subject Access Request Procedure

TWMA Group Data Breach Procedure

TWMA Group Candidate Recruitment Statement