Data Privacy Policy

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Introduction – Purpose

NEO Energy is committed to being transparent about how it collects and uses the personal data of its workforce, and to meeting its data protection obligations. This policy sets out NEO Energy’s commitment to data protection, and individuals’ rights and obligations in relation to personal data.

It is important that you read and act in accordance with this policy. This policy should also be read alongside any other notices and policies on data protection. Any breach of this policy may result in the termination of any contract and/or disciplinary action.

The Data Protection Officer is ultimately responsible for ensuring compliance with this policy and all supervisors and managers are required to ensure that its standards are maintained. Equally, everyone working for NEO Energy must comply with its terms. If individuals have any questions about this policy or how NEO Energy handles personal data, they should contact the Data Protection Officer. Individuals also have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues.

This policy applies to current and former employees, workers and contractors. This policy does not form part of any contract of employment.

Definitions

“Data Protection Officer” means the General Counsel & Commercial Director, who can be contacted via email (DPO@neweuropeanoffshore.com).

“GDPR” means the General Data Protection Regulation.

“ICO” means the Information Commissioner’s Office.

“Personal data” is any information that relates to a living individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.

“Special Categories of Personal Data” (sometimes known as sensitive personal data) is data about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership(s), physical or mental health, sex life or sexual orientation, and their biometric data or genetic data.

Data protection principles

NEO Energy processes HR-related personal data in accordance with the following data protection principles:

• NEO Energy processes personal data lawfully, fairly and in a transparent manner.
• NEO Energy collects personal data only for specified, explicit and legitimate purposes and will not process it in a manner that is incompatible with those purposes.
• NEO Energy processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
• NEO Energy keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
• NEO Energy keeps personal data only for the period necessary for processing.
• NEO Energy adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.

NEO Energy tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons. HR-related data will not be shared with third parties, except as set out in privacy notices. Where the organisation relies on its legitimate interests as the basis for processing data, it will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals.

NEO Energy will update HR-related personal data promptly if an individual advises that their information has changed or is inaccurate.
Personal data gathered during the employment, worker, contractor or volunteer relationship, or apprenticeships or internships is held in the individual’s personnel file (in hard copy or electronic format, or both), and on HR systems. The periods for which the organisation holds HR-related personal data are contained in its privacy notices to individuals.

From time to time NEO Energy may need to process Special Categories of Personal Data. Further details of such processing are provided in NEO Energy’s privacy notices.

NEO Energy keeps a record of its processing activities in respect of HR-related personal data in accordance with the requirements of the GDPR.

Individual rights

As a data subject, individuals have a number of rights in relation to their personal data.

Subject access requests

Individuals have the right to make a subject access request. If an individual makes a subject access request, the organisation will tell them:

• whether or not their data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
• to whom their data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
• for how long their personal data is stored (or how that period is decided);
• their rights to rectification or erasure of data, or to restrict or object to processing;
• their right to complain to the Information Commissioner if they think the organisation has failed to comply with their data protection rights; and
• whether or not the organisation carries out automated decision-making and the logic involved in any such decision-making.

NEO Energy will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless they agree otherwise. To make a subject access request, the individual should send the request in writing to the Data Protection Officer.

NEO Energy will normally respond to a request within a period of one month from the date it is received. In some cases, such as where the request is complex, it may respond within three months of the date the request is received. The organisation will write to the individual within one month of receiving the original request to tell them if this is the case.

Other rights

Individuals have a number of other rights in relation to their personal data. They can require NEO Energy to:

• rectify inaccurate data;
• stop processing or erase data that is no longer necessary for the purposes of processing;
• stop processing or erase data if the individual’s interests override the organisation’s legitimate grounds for processing data (where the organisation relies on its
• legitimate interests as a reason for processing data);
• stop processing or erase data if processing is unlawful; and
• stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual’s interests override the organisation’s legitimate grounds for processing data.

Further details are provided in the NEO’s Privacy Notice. To ask NEO Energy to take any of these steps, the individual should send the request to the Data Protection Officer.

Data security

NEO Energy takes the security of HR-related personal data seriously. NEO Energy has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties.

Where NEO Energy engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

NEO Energy have put in place procedures to deal with any suspected data security breach and will notify individuals and any applicable regulator of a suspected breach where legally required to do so.

NEO Energy will refrain from keeping personal data in a form which permits identification of the individual to whom it relates for any longer than is necessary for the purposes for which it is processed

Data breaches

As a Data Controller, NEO Energy have certain legal obligations under the GDPR to notify the ICO in the event of the loss or unauthorised access, disclosure or acquisition of the personal data we hold (“Data Breach”).

If individuals know or suspect that a Data Breach has occurred, they should not attempt to investigate the matter. Individuals must contact the Data Protection Officer immediately and follow their instructions. Individuals should preserve all evidence relating to the potential Data Breach.

Individual responsibilities

Individuals are responsible for helping NEO Energy keep their personal data up to date. Individuals should let NEO Energy know if data provided to NEO Energy changes, for example if an individual moves to a new house or changes bank details.

Individuals may have access to the personal data of other individuals and of our customers and clients in the course of their employment, contract, internship or apprenticeship. Where this is the case, NEO Energy relies on individuals to help meet its data protection obligations to staff and to customers and clients.

Individuals who have access to personal data are required:

• to access only data that they have authority to access and only for authorised purposes;
• not to disclose data except to individuals (whether inside or outside the organisation) who have appropriate authorisation;
• to keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);
• not to remove personal data, or devices containing or that can be used to access personal data, from the organisation’s premises without adopting appropriate
• security measures (such as encryption or password protection) to secure the data and the device;
• not to store personal data on local drives or on personal devices that are used for work purposes; and
• to report data breaches of which they become aware to the Data Protection Officer immediately.

In addition, individuals must:

• ask the Data Protection Officer or their line manager if they are unsure about this policy or any aspects of data management;
• advise the Data Protection Officer if they become aware of any act or omission that has or risks compromising the security, confidentiality or integrity of personal data;
• consult the Data Protection Officer if they are involved or may be involved in any major change of process or system that involves the processing of personal data as this may require that a data protection impact assessment is carried out;
• immediately forward on any data subject access requests which they may receive to the Data Protection Officer who will coordinate a response;
• complete all mandatory data protection training; and
• make sure they do not hold personal data otherwise than in accordance with this policy and all applicable rules and regulations NEO Energy may lay down from time to time and comply with all instructions to delete data given to individuals.

Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under NEO Energy’s disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.

Changes to this policy

NEO Energy reserves the right to update this policy at any time, and individuals will be provided with a new policy when any substantial updates are made. NEO Energy may also notify individuals in other ways from time to time about the processing of personal information.

If individuals have any questions about this policy, they should contact the Data Protection Officer.

Cookies policy

A “cookie” is a bite-sized piece of data that is stored on your computer’s hard drive. They are used by nearly all websites and do not harm your system.

We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website but the information does not usually identify you directly. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes.

These also include social media plug-ins which enable you to share our website content via your social media account(s) or easily share information with others.  We have a presence on YouTube, LinkedIn and Twitter, and if you click on any of these icons on our website, you will be taken to our pages or profiles on those platforms. The platforms may then start tracking your behaviour using cookies for their own purposes; for example, to better understand your interests so that they can present relevant content or advertising to you.  Data about you may also be transmitted to the social media channel even if you do not click on the plug-in.  The social media platforms will provide us with statistical information, which we use to help understand how you and our other users interact with our social medial presence.  All these platforms provide you with some control over their use of non-essential tracking technology and you can find details of how to exercise this control by reviewing their privacy and cookie notices.  We have contractual arrangements in place with the social media channels we use.  Please contact us for more information.

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 generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

Below we describe the cookies which are installed upon this website.

You can change your cookie preferences at any time by clicking on the icon at the bottom left of this webpage.  You can then adjust the available sliders to “On” or “Off” and then click “Save and close”. You may need to refresh your page for your settings to take effect.

Alternatively, most web browsers allow some control of most cookies through the browser settings. Find out how to manage cookies on popular browsers:

• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera
• Apple Safari

If you use a smart phone, you can usually prevent cross-site tracking and block cookies in the settings section on your device. You may also be able to visit websites without leaving a history by turning private browsing on.   You should visit the support section of the website of your device for more information on how to do this.

Strictly necessary cookies

These cookies are always active and are necessary for this website to function. They cannot be switched off. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences.

You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

FUNCTION PROVIDER	COOKIE NAME	DATA STORED	PURPOSE	DURATION
Youtube.com	LOGIN_INFO, 1p_JAR, ANID, APSID, CONSENT, DSID, GPS, HSID, SID, SSID, IDE, NID, OGP, OGPC, PREF, SAPISID, SID, SIDCC, SSID, VISITOR_INFO1_LIVE, YSC, permutive-id, permutive-session, watched_video_id_list, demographics	Various unique identifiers, as well as login information that may relate to a Google account.	Video functionality	Some of the cookies expire up to 20 years after your last visit to a page containing a Youtube video, although some expire sooner.
neweuropeanoffshore.com	PHPSESSID	Works by creating a unique id (UID) for each visitor and stores variables based on this UID.	Session cookie	When browsing session ends.
	moove_gdpr_popup		Cookie set by the UK cookie consent plugin to record that you accept the fact that the site uses cookies.
	pum-*		These control the repeated display of popups in the browser. Cookies are assigned an identification (ID) number formatted as ‘pum-{integer}’.	14 days
BrighterIR	AWSALB, AWSALBCORS		Cookie set by Amazon Web Services Load Balancer to preserve server session stickiness.	1 week
	XSRF-TOKEN		Cookie set by Laravel framework to protect against cross-site exploits.	2 hours
	Laravel_session		Cookie set by Laravel framework to preserve session data on investor relations tools.	2 hours

Performance cookies

These cookies allow us to count visits and traffic so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular, and see how visitors move around the site.

All information that is collected by these cookies is aggregated, and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

These cookies are set by the Google Analytics service, but hosted by Neo.

HOST	COOKIE NAME	DURATION
neweuropeanoffshore.com	_ga	1 year
neweuropeanoffshore.com	_gat	1 minute
neweuropeanoffshore.com	_gid	24 hours

Targeting cookies

We do not currently use targeting cookies.

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 require further information please contact us by emailing DPO@neweuropeanoffshore.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.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table above and with business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, and credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

• External Third Parties as set out below.
• Specific third parties such as HMRC.
• 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 notice.

External third parties

• Service providers acting as processors based in the UK who provide Investor Registrar services, Nominated Adviser and Broker services, and marketing services.
• Professional advisers based in the UK who provide banking, legal, insurance, accounting and auditing services and company secretarial services.
• HMRC, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
• Fraud prevention agencies, credit reference agencies, HM Courts & Tribunals Service.

We require all third parties 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. If you require further information please contact us by emailing dpo@neweuropeanoffshore.com.com.

6. International transfers

We do not transfer your personal data outside the European Economic Area (“EEA”) to be used by any other party. We do however use US-based cloud email and storage system providers. This will therefore involve transferring your data outside the EEA.

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

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

If you require further information please contact us by emailing DPO@neweuropeanoffshore.com.

7. 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. We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We will store all the personal information you provide on our secure servers. All electronic transactions you make to or receive from us will be encrypted using SSL technology. Of course, data transmission over the Internet is inherently insecure, and we cannot guarantee the security of data sent over the Internet. You are responsible for keeping your password and user details confidential. We will not ask you for your password.

In addition, we limit access to your personal data to those employees, agents 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 also 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.

8. Data retention and storage

How long will you use my personal data for?

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, or reporting requirements. We review the personal data that we hold every 12 months.

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for accounting, tax and legal purposes. This also helps us, for example, in the event that there is a complaint about our Services, to respond to you in full.

Details of retention periods for different aspects of your personal data are available from us by emailing us at DPO@neweuropeanoffshore.com

In some circumstances, you can ask us to delete your data: see “Request erasure” below for further information.

In other 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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

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.

If you wish to exercise any of the rights set out above, please email us at DPO@neweuropeanoffshore.com with specific details of who to contact for subject access rights.

No fee usually required

Data Subjects have the right to access their personal data and supplementary information. The right of access allows individuals to be aware of and verify the lawfulness of the processing.

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, or requires copies of previously provided information. Alternatively, we may refuse to comply with your request in these circumstances.

In the event of manife

stly unfair or excessive requests, we may refuse to respond to the request and any such refusal will be notified to the requester with a reason for the refusal and, in addition, information as to your rights to complain to the ICO or judicial authority within one month of such a request being received.

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.