BRE TRUST CONTACT NEWSLETTER BRE CHINA ABOUT US SERVICES EXPERTISE SECTORS PRODUCTS NETWORKS NEWS & INSIGHTS EVENTS BRE Group Privacy Policy BRE Group Privacy Policy Date: August 2021 v0.2 INTRODUCTION Welcome to the privacy policy for the BRE group of companies (“BRE Group”) websites. Version histories: Privacy Policy v0.0 dated 18 May 2018 This privacy policy replaces the BRE Group Limited privacy policy dated 1 February 2017. The previous privacy policy has been replaced by this one to: incorporate the new data protection requirements upon the BRE Group; and to further show to our customers and users that we have a consistent approach to data privacy across the BRE Group websites. Privacy Policy v0.1 dated March 2019 This privacy policy replaced v0.0 dated 18 May 2018 to: add new websites launched by the BRE Group since the date of the last privacy policy; correct errors where smartwaste.co.uk was not added to the list of “type C” websites and excesscold.com was listed as “type A” website instead of a “type D” website; other minor editorial changes; and include a link to a separate privacy statement relating to the hscd.bregroup.com website. Privacy Policy v0.2 dated August 2021 This privacy policy replaced v0.1 dated March 2019 to: Add additional information to the External Third Parties area. IMPORTANT INFORMATION AND WHO WE ARE Purpose of this privacy policy This privacy policy aims to give you information on how the BRE Group collects and processes your personal data through your use of a BRE Group website. The BRE Group websites – which may be amended from time to time – are listed below. The BRE Group is made up of the following commercial organisations: BRE Group Limited (“BREG”), company number 02704081; BRE Global (Assurance) Ireland Limited (“BRE Ireland”), company number 602123; Building Research Establishment Limited (“BRE”), company number 03319324; BRE Global Limited (“BRE Global”), company number 08961297; CEEQUAL Limited (“CEEQUAL”), company number 09568928; and Constructing Excellence (“Constructing Excellence”/“CE”), company number 04641522. BREG is the non-trading commercial holding company for the remainder of the BRE Group. The BRE Group is ultimately owned by the BRE Trust (company number 03282856), a registered charity in England and Wales under reg. no. 1092193 and Scotland under reg. no. SC039320. Except for BRE Ireland, all BRE Group entities, together with the BRE Trust, have their registered address at Bucknalls Lane, Garston, Watford WD25 9XX. BRE Ireland’s registered address is at 6th Floor, South Bank House, Barrow Street, Dublin 4, Ireland. BRE Group websites are not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with the BRE Group Acceptable Use Policy, the BRE Group Cookies Policy, and the relevant terms and conditions of use for the BRE Group website you are visiting. Data Controller This privacy policy is issued on behalf of the BRE Group so when we mention “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the BRE Group responsible for processing your data. The BRE Group websites and their respective data controllers are as follows: Controller: Website: BRE Trust qsand.org BRE bregroup.com smartwaste.co.uk bresmartsite.com yellowjacket.co.uk databooklive.com bretemplater.com brebuzz.net excesscold.com gdsap.org.uk isap.org.uk jsap.je ncm-pcdb.org.uk ncm-sbem.org.uk uk-ncm.org.uk hertslowcarbon.org housinghealthcosts.org hscd.bregroup.com homeof2030.com BRE Global greenbooklive.com redbooklive.com breeam.com forum.breeam.com bre.ac brebookshop.com elsonline.co.uk breeaminuse.breeam.org tools.breeam.com/projects homequalitymark.com msa4construction.com apres.bre.co.uk cemarkingtransfers.bregroup.com ceequal.com BRE Ireland cemarkingtransfers.bregroup.com CE nationalplatform.org.uk constructingexcellence.org.uk If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below. CONTACT DETAILS When contacting us about any BRE Group website, please do so as per the details below, and kindly state the name of the website you wish to mention: Postal address: Data Protection BRE Bucknalls Lane Watford, WD25 9XX Email: dataprotection@bregroup.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. THIRD-PARTY LINKS Our websites 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 statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. COOKIES 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. For more information about the cookies we use, please see the BRE Group Cookies Policy. DATA SECURITY 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 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. DATA USE The what, how and why we collect personal data is described more fully below. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, regulatory or reporting requirements. 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 requirements. Details of retention periods for different aspects of your personal data are available on request by contacting us. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. YOUR LEGAL RIGHTS Under certain circumstances, you have rights under data protection laws in relation to your personal data, including: requesting access to your personal data. requesting the correction of your personal data. requesting erasure of your personal data. objecting to processing of your personal data. requesting restriction of processing your personal data. requesting transfer of your personal data. the right to withdraw consent previously given. If you wish to exercise any of the rights set out above, please email dataprotection@bregroup.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 may 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 may 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. YOUR LEGAL RIGHTS You have the right 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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. 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 dataprotection@bregroup.com 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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. THIRD PARTIES Internal Third Parties means the other companies within the BRE Group (Including the BRE Trust) which are not listed as the Data Controller for a given BRE Group website. Please note that the BRE Group and BRE Trust shares internal IT and systems administration support. External Third Parties means companies, individual or other organisations that the given Data Controller who may need to process your personal data acting as either a data processor, or joint data controller. The categories are as follows: Service providers acting as data processors, and based within the European Economic Area (EEA) who host some BRE Group websites and provide IT and system administration services, and process online payments on behalf of the BRE Group. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based within the EEA who provide consultancy, banking, legal, insurance and accounting services. HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom and Republic of Ireland who require reporting of processing activities in certain circumstances. Market research and customer insight organisations, acting as joint data controllers, who are based within the EEA. We may also share data with separate data controllers including law enforcement bodies. What personal data we collect We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows: Identity Data (ID) includes your first name, last name, username and e-mail address. Commercial Role Data (CRD) includes job title, organisation name, organisation address, information relating to which sector your organisation is in. Financial Data (FD) includes bank account and payment card details should you chose to pay for any BRE Group products or services “on paper”. Transaction Data (TrD) means details about payments to and from you and other details of products and services you have purchased from us. Technical Data (TD) may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access BRE Group websites, how often and for how long you access BRE Group websites. Marketing and Communications Data (MCD) includes your preferences in receiving marketing from us and our third parties and your communication preferences. We have set out below, in a table format, a description of all the types of personal data we collect from you: Website: ID FD TD TrD CRD MCD qsand.org cemarkingtransfers.bregroup.com bregroup.com smartwaste.co.uk bresmartsite.com yellowjacket.co.uk databooklive.com bretemplater.com brebuzz.net redbooklive.com greenbooklive.com breeam.com forum.breeam.com breeaminuse.breeam.org tools.breeam.com/projects bre.ac brebookshop.com elsonline.co.uk ceequal.com homequalitymark.com msa4construction.com apres.bre.co.uk hertslowcarbon.org constructingexcllence.org.uk nationalplatform.org.uk excesscold.com gdsap.org.uk isap.org.uk jsap.je ncm-pcdb.org.uk ncm-sbem.org.uk uk-ncm.org.uk housinghealthcosts.org hscd.bregroup.com We also collect, use and share within the BRE Group aggregated data such as statistical or demographic data for the BRE Group’s legitimate business purposes. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. Purposes for which we will use your personal data We have set out below, in a table format, a description of all the ways we plan to 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. As the BRE Group operates a number of websites, we have grouped together all the websites into four types based on the purpose and functionality of the websites. 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. Type A websites: These websites require you to create an account to either access (either for free or following a purchase), and/or control how we communicate with you. bregroup.com elsonline.co.uk ceequal.com hertslowcarbon.org.uk apres.bre.co.uk msa4construction.com homequalitymark.com constructingexcellence.org.uk qsand.org.uk cemarkingtransfers.bregroup.com bre.ac brebookshop.com Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest Registering as a new user or customer · Identity Data · Commercial Role Data · Marketing and Communications Data Contract (where the user is an individual and is a contracting party through the website terms of use or a user end licence agreement): to fulfil obligations under the contract including providing access to the website/tool. Legitimate interest (where the user is a representative of a customer-organisation): to allow the customer’s designated users to access the website/tool; to market other BRE group company products and services to the representatives of the customer. To communicate new features and fixes to the website to the user · Identity Data Legitimate interest (where the user is a representative of a customer-organisation): explain to designated users of the customer what the new features and bug fixes are for the website/tool. Contract (where the user is an individual and is a contracting party through the website terms of use or a user end licence agreement): to explain to the customer what the new features and bug fixes are for the website/tool. To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) · Identity Data · Technical Data Legitimate Interest/Contract (where the user is referred to as “you” under the website terms of use): to deliver, optimise, maintain, and protect the website’s integrity for the benefit of each user. To allow customers to purchase products or services · Identity Data · Commercial Role Data · Financial Data · Transaction Data Contract (where the person making the purchase is the customer): to create a purchase history, facilitate transactions made “on paper” and fulfil contractual obligations more generally. Online payments are made through “Stripe”, the third party payment processing platform. Legitimate Interest (where the person making the purchase is doing so on behalf of an organisation): to create a purchase history, facilitate transactions made “on paper” and to create a record of customer users. Share information with the rest of the BRE Group for marketing purposes · Commercial Role Data · Marketing and Communications Data Legitimate interest: the BRE Group company operating the given website may wish to pass on the customer (where an individual) or designated user’s personal data to other BRE group companies to contact them about their experience of the website/tool and suggest other BRE Group products and services. Type B websites: These websites do not require creating an account to view content, users do not add content to the sites, and products and services are not purchased. brebuzz.net breeam.com bresmartsite.com nationalplatform.org.uk greenbooklive.com redbooklive.com Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) · Technical Data Legitimate Interest/Contract (where the user is referred to as “you” under the BREG terms of use): to deliver, optimise, maintain, and protect the website’s integrity for the benefit of each user. Type C websites: These websites require you to create an account to either access or create content, control how we communicate with you, collaborate with other users or purchase products and services from us. yellowjacket.co.uk breeaminuse.breeam.org tools.breeam.com/projects databooklive.com bretemplater.com smartwaste.co.uk cemarkingtransfers.bregroup.com bre.ac brebookshop.com forum.breeam.com Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest Registering as a new user or customer · Identity Data · Commercial Role Data · Marketing and Communications Data · Transaction Data Contract (where the third party is an individual and is a party to the conditions or use or a user end licence): to fulfil obligations under the contract including providing access to the website/tool. Legitimate interest (where the user is a representative of a customer organisation): to allow designated users to access the website/tool; to market other BRE group company products and services to the representatives of the customer. To communicate new features and fixes to the website to the user · Identity Data Legitimate interest (where the contract is between the BRE group company and a customer-organisation): explain to designated users of the customer what the new features and bug fixes are for the website/tool. Contract (where the third party is an individual and is a party to the conditions or use or a user end licence): to explain to the customer what the new features and bug fixes are for the website/tool. Share information with the rest of the BRE Group for marketing purposes · Commercial Role Data · Marketing and Communications Data Legitimate interest: the BRE Group company operating the given website may wish to pass on the customer (where an individual) or designated user’s personal data to other BRE group companies to contact them about their experience of the website/tool and suggest other BRE Group products and services. To anonymise and create internal case-studies and for statistical purposes · Identity Data · Commercial Role Data · Transaction Data · Technical Data Legitimate interest: any personal data is anonymised to be used for internal statistical purposes to create statistical reports and case studies. To facilitate communications between the various parties that use the tool; being a function of the website/tool · Identity Data · Commercial Role Data Contract (where the user is subject to website terms of use or an end user licence): the website/tool is collaborative and requires different parties upload content and communicate with each other and the BRE group company data controller. Legitimate interest (where the user is designated by the customer to use the website/tool): the website/tool is collaborative and requires different parties to upload content and communicate with each other and the BRE group company data controller. To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) · Identity Data · Technical Data Contract: (where the user is a third party and subject to terms of use or an end user licence for the website/tool) BRE will need to process this type of data to deliver the website/tool to the named contracting party. Legitimate interest: (where the user is designated by the customer to use the website/tool) BRE will need to process this type of data to deliver the website/tool to the contracting party’s designated users. Type D websites: These websites are hosted, developed and/or maintained by BRE on behalf of government customers, which are joint data controllers. If applicable, once individuals create an account to become users, they may access further content. gdsap.org.uk isap.org.uk jsap.je ncm-pcdb.org.uk ncm-sbem.org.uk uk-ncm.org.uk housinghealthcosts.org hscd.bregroup.com* excesscold.com Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest Registering as a new user · Identity Data · Commercial Role Data Contract (where the user is an individual and subject to the terms of conditions or user end licence): to fulfil obligations under the contract and provide access to the website/tool. To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) · Identity Data · Technical Data Legitimate Interest/Contract (where the user is referred to as “you” under the terms of use): we will need to process this type of data to deliver and maintain the website for the benefit of each user. To anonymise and create case-studies and for statistical purposes or research and development on behalf of the relevant government department · Identity Data · Commercial Role Data · Technical Data Legitimate interest: we may process your personal data, anonymise it and use the anonymised data for statistical or research and development purposes. * This website is hosted, developed and maintained by BRE on behalf of central and local government customers, which may be joint data controllers. Individuals working for customer organisations can create an account to become users and then access and create further content comprising profiling data at household level. Please refer to an additional, separate privacy statement relating to this website. 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