Privacy Policy
Last Updated: 20th March 2019
This privacy policy sets out how New Anglia Local Enterprise Partnership (LEP) uses
and protects any information that you provide to New Anglia LEP and its delivery
partners.
A separate privacy policy is available for director’s, employees and prospective
employees. Please contact the HR department for further information.
Data Controller and Data Processor
As Data Controller and Data Processor, New Anglia LEP is responsible for ensuring
that all data, including any Personal Data, that it holds is accurate and, where
necessary, kept up to date.
New Anglia LEP will ensure that individuals have access rights to their data as
required by the General Data Protection Regulation (2016/679) and Data Protection
Act 2018.
As the Data Controller, New Anglia LEP’s Data Protection Officer oversees the use of
data within the LEP and has the right to enforce any legal requirements contained
within the General Data Protection Regulation (2016/679) and Data Protection Act
2018.
Use and Storage of Data
In accordance with Article 5(2) of the General Data Protection Regulations, New
Anglia LEP adheres to the following principles when storing and processing data:
• Data is collected for specified, explicit and legitimate purposes and will not be
processed in a manner that is incompatible with the original purpose(s) for
which the data was collected.
• Data is stored and processed lawfully, fairly, and in a transparent manner, in
relation to individuals.
• We use appropriate technical or organisational measures to ensure that there
is appropriate security in place for any personal data; this includes protection
against unauthorised or unlawful processing and against accidental loss,
destruction or damage.
• The data we collect is as accurate as possible and, where necessary, kept up
to date.
• Data is kept in a form which permits identification of data subjects for no
longer than is necessary for the purposes for which the personal data is
processed.
• All reasonable steps are taken to ensure that inaccurate personal data is
erased or rectified without delay.
• Data may be used for further processing and archiving purposes in the public
interest, or for scientific, historical research or statistical purposes.
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• Personal data may be stored for longer periods insofar as the personal data
will be processed solely for archiving purposes in the public interest, scientific
or historical research and/or statistical purposes, subject to implementation of
the appropriate technical and organisational measures, required by the
GDPR, in order to safeguard the rights and freedoms of individuals.
Personal Data Collected
New Anglia LEP has contracts with Government Departments to deliver a range of
business support programmes and grant schemes, several of which are delivered in
partnership with other organisations and Local Authorities.
As part of the operation of these programmes/schemes, New Anglia LEP processes
personal data according to the following lawful basis:
Article 6(1)(e) of the General Data Protection Regulation “Processing is necessary for
the performance of a task carried out in the public interest or in the exercise of official
authority vested in the controller”.
The lawful basis for controlling or processing ‘special category’ data is:
Article 9(2)(g) of the General Data Protection Regulation “Processing is necessary for
reasons of substantial public interest, on the basis of Union or Member State law
which shall be proportionate to the aim pursued, respect the essence of the right to
data protection and provide suitable and specific measures to safeguard the
fundamental rights and the interests of the data subject”.
Depending on the nature of activities or support provided by New Anglia LEP and its
delivery partners, the following information may be collected and may be shared with
delivery partners and Government Departments for the purposes of reporting and
monitoring:
1. name of contact
2. job role
3. company name (legal and trading)
4. business sector/activity/SIC code
5. location/address/relevant local authority
6. email address
7. public IP address
8. phone number (including mobile)
9. date and time of enquiry
10. business status
11. business ownership
12. business size
13. business turnover
14. staffing numbers (including apprentices)
15. business Companies House registration number, VAT, PAYE
16. date of incorporation
17. start date of trading
18. financial information (historic, current and forecasts) required for assessment
of business support
19. enquiry source
20. reason for contacting the partner
21. outcome of any advice given
22. details relating to the support given and/or provided
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23. correspondence with businesses/individuals related to business support
services
24. ethnicity
25. disability
26. gender
27. age
28. labour market status
29. pay details
Information Being Shared
As part of the operation of New Anglia LEP’s business support programmes and
grant schemes, a shared CRM System has been developed by New Anglia LEP to
enable business support and delivery partners across Norfolk and Suffolk to:
• facilitate the delivery, coordination and management of business support
services to customers (Individuals, Small and Medium-sized Enterprises
(SMEs) as well as Large Companies) across the counties of Norfolk and
Suffolk;
• provide support to inward investment opportunities in line with the objectives
outlined in the Norfolk and Suffolk Economic Strategy;
• contact customers about business support services that can be accessed
through the New Anglia Growth Hub (delivered by Suffolk Chamber of
Commerce on behalf of New Anglia LEP).
Your details will be used to support research and evaluation activities, with New
Anglia LEP sharing all, or some of, your personal data with organisations to
undertake independent external audits and evaluations of activities, to assess the
effectiveness of the support provided, as well as ensuring that U.K. and E.U. law,
rules and regulations have been fully complied with. Such organisations may be
appointed by New Anglia LEP and/or the Ministry of Housing and Local Government;
the Department for Businesses, Energy and Industrial Strategy; other Government
Departments and/or the European Commission.
New Anglia LEP will not give any personal data to any other organisation(s) unless
required for the purpose of audit and/or evaluation. In such circumstances, where
possible, New Anglia LEP will remove the details that might identify individuals
personally and will instruct the organisations undertaking the audit and/or evaluation
not to use the data to contact individuals for any reasons unconnected with the audit
and/or evaluation process.
Freedom of Information Act 2000
As a Company Limited by Guarantee we are not formally subject to the Freedom of
Information Act 2000. However, we recognise the importance of accountability and
transparency and voluntarily adhere to this legislation. We respond to Freedom of
Information requests in the same way as organisations which are formally bound by
the legislation and always seek to make information available wherever possible.
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Withdrawal of Individual’s rights
Under Article 6(1)(e) and Article 9(2)(g) of the General Data Protection Regulation,
participants in New Anglia LEP’s business support programmes and grant schemes
are unable to claim the following rights in terms of personal data:
• the right to erasure (“right to be forgotten”)
• the right to portability of their data.
However, the data collected is your personal data, and you have the right, subject to
lawful data requirements:
• to see what data we have about you
• to ask us to stop using your data
• to ask us to delete your data, or to correct your data if there is no longer a
justification to process it
• to lodge a complaint with the independent Information Commissioner (ICO) if
you think we are not handling your data fairly or in accordance with the law.
Data Retention
Contracts with several Government Departments, including contracts with the
Ministry of Housing and Local Government, and the Department for Businesses,
Energy and Industrial Strategy, stipulate that data and evidence must be kept for a
specified period after support has been provided by New Anglia LEP and its partners.
In the case of one of these contracts, data and evidence must be kept until the end of
the year 2036.
Destruction of Information
In accordance with the General Data Protection Regulation (2016/679) and Data
Protection Act 2018, any data no longer required for the purposes that it was held for
will be destroyed. This means that New Anglia LEP will destroy all hard copy and
electronically stored information using secure methods that comply with all data
protection regulations in force at the time of destruction.
Data Breaches
In the case of a data security breach, New Anglia LEP will immediately take steps to
contain the breach. Where a serious breach is encountered, New Anglia LEP, as
Data Controller, will notify the Information Commissioner’s Office and launch an
investigation to establish the reasons behind the breach. New Anglia LEP is
permitted to take all reasonable corrective steps as resulting from a security breach,
including suspending use of any systems and/or withholding joint working with
delivery partners.
Automated decision making
New Anglia LEP does not use personal data to undertake automated decision
making.
New Anglia LEP Contact Details
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If you would like further information, please contact:
Data Protection Officer
New Anglia Local Enterprise Partnership
Centrum
Norwich Research Park
Colney Lane
Norwich
Norfolk
NR4 7UG
Tel: 01603 510070
Information Commissioner’s Office Contact Details
The Information Commissioner’s Office is the UK’s independent authority set up to
uphold information rights in the public interest, promoting openness by public bodies
and data privacy for individuals:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113
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