INTRODUCTION

Peritus International provides subsea system and offshore pipeline engineering services to the offshore energy industry.

TERMINOLOGY

Below is some quick guidance on terminology to help you clearly understand this Policy: –

Personal information is any information relating to an identified or identifiable living person.

The Data Controller is a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.  In the context of this Policy, Peritus International is the Data Controller.

SECURITY

Peritus International is committed to protecting your personal information and privacy.

We have security measures in place designed to prevent the loss of data, preserve data integrity, and to control access to the data and know that ensuring the accuracy and security of your personal information is essential to retaining your confidence and trust.

PURPOSE OF THIS PRIVACY POLICY

The purpose of this privacy policy is to describe, in cases where Peritus International is the Data Controller, why and how we collect and use your personal information and provides information about your rights.  It applies to personal information provided to us, both by individuals themselves or by others.  We may use personal information provided to us for any of the purposes described in this privacy policy or as otherwise stated at the point of collection.

When collecting and using personal information, our policy is to be fair, lawful and transparent about why and how we process personal information.

To find out more about our specific processing activities, please go to the relevant sections of this policy.

TOPICS

What we do with your Personal information

Our Contact Details

Your Rights

How to Complain

Changes to Our Privacy Policy

WHAT WE DO WITH YOUR PERSONAL INFORMATION – EXISTING OR POTENTIAL BUSINESS CUSTOMER, SUPPLIER OR PARTNER

What information we collect

We collect or use the following information

• Names and contact details
• Addresses
• Payment details
• Account information
• Website user information (including user journeys and cookie tracking)
• Records of meetings and decisions
• Information relating to compliments or complaints
• Financial transaction information
• Health and safety information
• Marketing preferences

Why we use your personal information

We may use your data for the following purposes: –

• Unless we have identified you do not wish to receive marketing information to contact you directly in the future regarding our services and/or events (i.e. via postal and electronic marketing);
• To create publicity materials to promote the Company’s activities – for inclusion on/in our or other website(s), social media, press articles and/or case studies;
• To improve our website, services, business partner relationships and experiences
• For use in our internal publications;
• For financial reporting;
• For external use such as Annual Review.

Our legal basis for using your personal information

• The processing of your personal information is based upon the lawful basis of: –
• Performance of a contract with you
• Necessary to comply with a legal obligation
• Necessary for our legitimate interests (the running and development of our business)

WHAT WE DO WITH YOUR PERSONAL INFORMATION – EXISTING OR POTENTIAL EMPLOYEE

What information we collect

• Contact details (eg name, address, telephone number or personal email address)
• Date of birth
• National Insurance number
• Photographs (eg staff ID card)
• Copies of passports or other photo ID
• Next of kin or emergency contact details
• Employment history (eg job application, employment references or secondary employment)
• Education history (eg qualifications)
• Right to work information
• Performance records (eg reviews, disciplinary records, complaints or disciplinary action)
• Training history and development needs
• Monitoring employees’ IT use
• Job role and employment contract (eg start and leave dates, salary, changes to employment contract or working patterns)
• Time spent working (eg timesheets or clocking in and out)
• Expense, overtime or other payments claimed
• Leave (eg sick leave, holidays or special leave)
• Maternity, paternity, shared parental and adoption leave and pay
• Pension details
• Bank account details
• Payroll records
• Tax status
• Benefits
• General health and wellbeing information
• Occupational health referrals and reports
• Sick leave forms or fit notes
• Accident at work records
• Access needs or reasonable adjustments
• Protected Characteristics (as defined by the Equality Act and s.75 of the Northern Ireland Act for the purpose of equal opportunities monitoring)

Why we use your personal information

We may use your data for the following purposes: –

• For staff recruitment, administration and management
• To manage staff salaries and pensions
• To manage staff health and wellbeing
• To demonstrate our skills, experience and competence

Our legal basis for using your personal information

The processing of your personal information is based upon the lawful basis of:

• Consent
• Performance of a contract with you
• Necessary to comply with a legal obligation
• Necessary for our legitimate interests (the running and development of our business)

WHO WE MAY SHARE YOUR PERSONAL INFORMATION WITH

Internal Third Parties which are other companies in the Sapura Group acting as controllers or processors and who are based in and outside of the UK for delivery of projects and group wide services.

External Third Parties which are service providers acting as processors based in and outside the UK who provide services such as travel, insurance, and IT services.

Authorities and regulators, such as HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in and outside the UK who require reporting of processing activities in certain circumstances.

Professional advisers including lawyers, bankers, auditors, and insurers acting as processors or controllers based in and outside the UK who require reporting of processing activities in certain circumstances or who process your personal data for the purpose of delivering their services to us.

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.

THE TRANSFER OF YOUR PERSONAL INFORMATION TO A COUNTRY OR INTERNATIONAL ORGANISATION OUTSIDE OF THE UK OR EUROPEAN UNION

We may share your personal data within the Sapura Group or with other external third parties based outside of the UK. This will involve transferring your data outside of the UK or European Union.

Many of our external third parties are also based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

We may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

HOW LONG WE KEEP HOLD OF YOUR DATA

We retain the personal information processed by us, only for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).   In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for your personal information and other documentary created is stated in our document retention matrix, which you can request from us by contacting us.

AUTOMATED DECISION MAKING & PROFILING

We do not make any decisions in relation to your personal information, solely by automated means without any human involvement (e.g. we do not conduct automated decision making).

Neither do we conduct any automated processing of personal information to evaluate certain things about you (e.g. we do not conduct profiling).

PERITUS INTERNATIONAL CONTACT DETAILS

If you have any questions about this privacy policy or how and why we process personal information, please contact us via any of the routes below: –

Post: The Data Protection Officer/Representative, 4D Dukes Court, Duke Street, Woking. GU21 5BH. UK

Email: enquiry@peritusint.com

Phone: +44 1483 312 800

YOUR RIGHTS

Under certain circumstances, you have the rights under data protection laws in relation to your personal information.  These rights are summarised below:

Access to your personal information

You have a right of access to personal information held by us as a Data Controller.  We will aim to respond to any requests for information promptly, and in any event within the legally required time limits.

Correcting your personal information

You have a right to request amendment(s) to your personal information.  Wherever practically possible, once we are informed that any personal information processed by us is no longer accurate, we will make the necessary amendments based on the updated information.

Restriction of Processing of your personal information

In certain circumstances, you have the right to request the restriction or suppression of your personal information.  This effectively allows you to limit the way that we use your persona data.

Object to Processing

In certain circumstances, you have the right to object to the processing of your personal information.  This effectively allows you to ask us to stop processing your personal information.

Where we have told you that any use of information is based on ‘legitimate interest’, you can raise an objection to that use. When you make an objection, we’ll have up to one month to respond to you. We will stop using the information in this way unless we disagree that we should because of a compelling legal justification for continuing to use it. We’ll always tell you what the justification is.

You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other parts of the Group and/or our Marketing Partners. If you no longer wish to be contacted for marketing purposes, please email enquiry@peritusint.com

Erasure (also known as “the right to be forgotten”)

In certain circumstances, you have the right to request the erasure of your personal information.

Portability

In certain circumstances, you may have the right to obtain and reuse your own personal information, that you provided to us, for your own purposes across different services.  This data will be provided in a structured, commonly used and machine-readable format and we can transmit this data directly to other parties at your request.

Withdrawal of consent

Where we process your personal information based on consent, you have a right to withdraw consent at any time.

If you would like to request to withdraw your consent, please contact us by emailing enquiry@peritusint.com.  Alternatively, to stop receiving our Marketing emails, please click on the unsubscribe link in the any of the emails we have sent to you.

HOW TO COMPLAIN

In the event you wish to complain about our use of your personal information, please send an email with the details of your complaint to enquiry@peritusint.com.  We will look into and respond to any complaints we receive.

In the UK, you also have a right to lodge a complaint with the Information Commissioner’s Office (ICO) (the UK’s data protection regulator).  For further information on your rights and how to complain to the ICO, please refer to the ICO website: www.ico.org.uk.

CHANGES TO OUR PRIVACY POLICY

We keep our privacy policy under regular review and we will place any updates on this web page.

This policy replaces all previous versions and is correct as at August 2024.