Fair Processing Notices

Reference Number – FPN1 CLS

This Statement

This Fair Processing and Privacy statement (Known as the Statement) is written in accordance with the EU General Data Protection Regulation (GDPR) that takes effect from May 2018.

The statement establishes how ISS uses the information we collect about all users / customers (Known as “you”) of the Crew Change Service (Also known as the “service”). Please read them carefully before using the Service. By using or accessing this service, you acknowledge your acceptance of this statement. Without such an acknowledgement, you may not use this service.

Accessing or using the service confirms your agreement to be legally bound by the statement and acknowledge that Inchcape Shipping Services (Holdings) Ltd (“ISS”) is the owner and operator of this service. ISS reserves the right to amend or vary this statement and any of the contents of this Service from time to time in its sole discretion. Amendments or variations will take effect when posted on this Service. This statement, as amended or varied from time to time, applies to all your interactions with the Service both now and in the future.

In order for ISS to fulfil legal, contractual, and business responsibilities, it will collect, hold and process considerable amount of information. Where this information is considered personal data, that is information that identifies you such as your name and address, then we will comply with the relevant legal and regulatory that apply to personal data such as the EU General Data Protection Regulation. (GDPR)

Where this involves sensitive personal data, information about you of a private nature such as the state of your health, then there will be additional requirements imposed

ISS is committed to protecting your privacy. This statement explains how we use the information we collect about you, how you can instruct us about the use of that information and procedures that we have in place to safeguard your privacy.

We use the information we collect about you to help efficiently administer the service. We take privacy seriously and endeavor to be as open as possible in terms of how your information is used.

What we need

Inchcape Shipping Services (Holdings) Ltd (“ISS”) will be consider the Data Controller of the personal data you provide to us. ISSs registered address is 8th Floor, 60 Fenchurch Street, London EC3M 4AD.

We may collect and process information that you provide by submitting this (In soft or hard copy) to the relevant Port Agent.

This information includes your name, address, email address, mobile telephone number, date of birth, passport information and other information relevant to performing a crew change. We treat all such data as personal data for the purposes of legislation.

If you visit ISS websites, further information may be collected and these will have their Statement.

When you register to use an ISS information system, we will require certain corporate details that are not subject to this Statement.

Why we need it

We need the details of named individuals for the purpose of facilitating embarkation and / or disembarkation of crew members for this vessel in the respective port.

We will also use information about you in the following ways:

  • Completion of relevant paperwork on behalf of you to aid your smooth and effective transition to and from vessels (E.g. customs / visas, immigration and other declarations)
  • Arranging hotels and taxi services
  • Completing OK to Board process to airlines in order to facilitate embarkation of the aircraft

This information will be processed via email, through completion of hard copy forms and relevant information systems that are put in place to capture such data

We may give your personal data to third parties where:

  • There is a legal requirement to provide this to government agencies to ensure that you can legally enter and exit the port / country
  • There is a need to provide your details to our partners for the purpose of booking hotels and taxis and arranging collection / drop off services

We will not sell or pass your personal data to a third party for the purposes of direct marketing.

What we do with it

All personal data is processed by ISS staff for the purposes above and is located on information technology systems owned and operated by ISS, or that of verified third parties. All information you provide to us is stored on our secure servers.

Non-ISS employed third parties do not have access to your personal data unless the law or a contractual agreement allows them to do so.

ISS staff, our agents, and sub-contractors will use your data to communicate with you on any matter relating to the provision of the services in general use this information. We also use the information we collect to notify you about important changes to the Service and new ISS services.

In the event that our business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers’ advisers and will be passed on to the new owners of the business.

ISS does not sell / trade or rent your personal information to others. ISS may provide aggregate statistics about our customers; sales, traffic patterns and related site information to reputable third parties, but these statistics will include no personally identifying information. Please note, however, that ISS may be required to disclose your personal information to third parties because of a court order or pursuant to a statutory or governmental order or decree or to comply with any search warrant or similar presented to ISS by any to law enforcement or government officer.

Unfortunately, the transmission of information via the internet or email is not completely secure and although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted over the internet to our site or by email; any transmission is at your own risk.

Once we have received your information, we will use all necessary procedures and security measures to try to prevent unauthorized access, loss, disclosure, or amendment. All personal data collected is subjected to an Information Security and Data Protection regime which is in place to oversee the effective and secure processing of your personal data.

More information on the policies underpin this regime can be found on our corporate website WWW.ISS-SHIPPING.COM

How long we keep personal data

We will retain your basic personal data until such time as it is no longer required for business purposes and will then dispose of your personal data after this period unless we are legally required to retain this data for longer.

Your information which we use for general correspondence, updates on alternative services and marketing purposes will be retained until you notify us that you no longer wish to receive this information or we deem it no longer necessary to continue to hold whichever is sooner.

You can find more information on data retention in our Data Protection statement on our corporate website WWW.ISS-SHIPPING.COM

Your consent

By submitting your information as per the relevant process, you consent to the collection and use of that information by ISS as set out in this Statement. If we decide to change our Statement, we will post those changes on this page so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it. We will also e-mail you should we make any changes so that you may consent to our use of your information in that way. Continued use of the service will signify that you agree to any such changes.

What are your rights?

You have the right to see what data we hold about you

This includes a description of the data processed, the purposes of processing, and any recipients to whom we have disclosed the data.

To exercise this right, you must make a subject access request in writing, stating the information you require, to: DATA.PROTECTION@ISS-SHIPPING.COM

We may contact you to verify your identity or to clarify the precise information you require before processing your request, and will answer your request within 30 calendar days.

You have the right to ask us not to process your personal data.

We will not pass your information to third parties for direct marketing purposes.

You have the right to correct your personal data at any time.

If at any point you believe that the information that we process on you is incorrect, you can request to see this information and have it corrected / deleted. Please contact: DATA.PROTECTION@ISS-SHIPPING.COM

You have the right to prevent any unwarranted processing likely to cause damage or distress.

If you feel that this situation has arisen or may arise, please contact: DATA.PROTECTION@ISS-SHIPPING.COM

Please note that this will not include processing where a legal obligation for us to process the information exists.

Transfer of personal data outside the European Economic Area

Because the Internet is global, as is ISS’s business, the information you provide may be transferred to countries outside the European Economic Area that do not have similar data protection legislation during use, as set out in this Statement. However, we have taken the steps outlined above to try to improve the security of your information. By submitting your information to us, you consent to these transfers.

We will not actively transfer your personal data out of the European Economic Area without ensuring the protection of that your rights and freedoms as a data subject.

Please send any objections, complaints, concerns, requests for further information, requests for copies of your personal data, and / or application of the Rights of the Individual via email to DATA.PROTECTION@ISS-SHIPPING.COM

If you are not satisfied with our response or believe we are processing your personal data in a manner not in accordance with relevant legislation, you can complain to the Information Commissioners Office (ICO) – WWW.ICO.ORG.UK

In summary

We are committed to protecting your privacy. We use the information we collect on the site to enhance you overall ISS experience. We do not sell / trade or rent your personal information to others. If you do not want to receive any communication from us, please unsubscribe from our correspondence.

Tell us what you think

ISS welcomes your questions and comments about data protection and privacy via e-mail to DATA.PROTECTION@ISS-SHIPPING.COM