Annex A
Balfour Beatty Group Limited, Balfour Beatty Plc and/or its group companies (“the Company”, “We”, “Our” or “Us”) regularly captures, photographs and/or film footage and/or audio or voice recordings or content of individuals (“Contribution”) for the purposes of using these in internal and external communications materials including but not limited to; case studies, newsletters, magazines, brochures, leaflets, display materials, office graphics, online content including social media, websites, podcasts and videos. (“Activities”). These Activities may be captured by Our employees, third parties or production companies that we employ or via applications/software that we have purchased or subscribe to.
This Privacy Notice regulates the use and protection by the Company of “personal data” you provide or make available to the Company as Contributions by participating in any of the above Activities following your agreement to a Contributor Photography, Filming and Voice Recording Release (18 years old and older) agreement (“Release Agreement”). Personal data is information which identifies (or which could, with other information that We hold or are able to access, identify) a living individual.
Balfour Beatty Group Limited is a “Controller” under the Data Protection Act 2018 and processes personal data in accordance with this legislation and if applicable, the General Data Protection Regulation (EU 2016/679) (“Data Protection Laws”). For queries on data protection, please contact the Company’s Group Data Protection Officer at Group Data Protection Officer, Balfour Beatty Plc, 5 Churchill Place, Canary Wharf, London, England, E14 5HU or dataprotection@balfourbeatty.com.
Personal data:
We only process personal data about you in relation to the Activities where you have agreed to a Release Agreement and where there is a valid legal basis for doing so.
Examples of personal data that you may provide to Us includes:
- Personal data in relation to your image or voice when captured and/or recorded in photographs or film footage or voice recordings or media content for the Activities
- Information such as your name, business email address, telephone number and contact details and occupation where required for the Activities
Where We store your personal data:
All personal data recorded or provided to Us in relation to the Activities is stored on systems with appropriate technical and organisational security measures and controls located in the United Kingdom and/or European Economic Area (“EEA”) sufficient to comply with the requirements under the Data Protection Laws. We will only store your personal data for as long as necessary for the Company to process such personal data for the purposes set out in this Privacy Notice and in accordance with our retention policies as updated and available here. The accuracy of the information that We hold about you is important to Us. If any of the personal information We hold about you becomes inaccurate or out of date (e.g. a contact/contact information changes), please inform Us as soon as possible using the contact details below.
Uses made of the personal data:
We use personal data held about you for the following purposes:
- Using, photographs and/or film footage, and/or audio or voice recordings or content of individuals for internal and external communications materials including, but not limited to on-line content, print material, videos and/or event materials in connection with the Activities.
Disclosure of your information:
We will share your personal data:
- When required by law, regulatory requirement or government regulators of competent authority
- Where relevant with Balfour Beatty group companies, our auditors or relevant professional advisers
- With the Company’s nominated production providers or third party marketing and/or communications agency suppliers where necessary to carry out the Activities or to create materials or content in relation to the Activities
- With our customers or approved supply chain partners where necessary to carry out joint Activities or to create materials or content in relation to joint communication Activities
- Or persons in connection with any sale, merger, acquisition, disposal, reorganisation or similar change in the Company or its group companies.
Personal data shall not be transferred to or stored at a destination outside the United Kingdom and or EEA.
Legal basis for processing:
Data Protection Laws require that We meet certain conditions before We are allowed to use your personal data as described in this Privacy Notice.
For personal data which does not fall within ‘special categories of personal data’ under Data Protection Laws, unless otherwise notified, We rely on the following legal basis:
- Processing is necessary for legitimate interests of the Company in relation to the undertaking internal and external communication campaigns which provide an accurate portrayal of the Company’s culture and awareness of key information and individual contacts within the Company as necessary in relation to its core business ventures and/or projects and on the basis that only individuals over 18 years age are approached and all affected individuals are requested to agree to a Release Agreement and have a reasonable expectation of how their personal data will be used during the Activities.
We will ensure that the collection and processing of your personal data:
- Is kept to a minimum with regards to the amount of data collected and the extent of any processing
- Will not be overly intrusive to you
- Will be proportionate in order to meet our legitimate interests, as above.
Your rights in relation to your personal data:
Under Data Protection Laws you have the following rights in relation to your personal data:
- Right to access your personal data by subject access request
- Right to have your personal data rectified if inaccurate/incomplete
- Right to object to direct marketing
- In certain circumstances, the right:
- to have your data erased or removed, and where the personal data has been made public, that other controllers processing the personal data also erase links to, or copy or replication of, such personal data
- to restrict the processing of your data
- of data portability, namely to obtain and reuse your data for your own purposes across different services
- to not be subjected to automated decision making (including profiling) where it produces a legal effect or a similarly significant effect on you
- the right to bring a civil action if there is a breach of the Data Protection Laws.
Contact Us and complaints:
You may contact Us in relation to the above rights (which include engaging your right to object to the processing of your data) by contacting the Company’s group Data Protection Officer at: dataprotection@balfourbeatty.com requests will be administered free of charge.
If you are not happy with the way in which your personal data is held or processed by Us, or if you are not satisfied with our handling of any request by you in relation to your rights, We would request that you raise a complaint with our Data Protection Officer at the contact details set out above in the first instance, however, you always have the right to complain re: data protection matters to the Information Commissioner Office (ICO). The ICO is the UK's independent body set up to uphold information rights. You can find out more about the ICO on its website (https://ico.org.uk/).
Changes to this Privacy Notice:
This Privacy Notice is correct as at April 2023 however We keep this Privacy Notice under regular review, and We reserve the right to change it at any time on notice to you and will notify you where We:
- Are making substantial changes
- Are doing something with your personal data, which you might not expect based on what We have told you in this Privacy Notice.