Privacy Policy

Whom to contact about privacy and data protection at East Belfast Enterprise

East Belfast Enterprise is a ‘Data Controller’ in the definition of the General Data Protection Regulations which came into effect across the UK on 25 May 2018.  This means it uses and stores personal data, like its client’s email addresses and telephone numbers, to carry out its work.

Its identity and contact details as a Data Controller is:

East Belfast Enterprise, City East Building, 68 – 72 Newtownards Road, Belfast, BT4 1GW Tel 028 90942010, email reception@eastbelfast.org

The person to contact about Data Protection and privacy queries is the Data Protection Champion:

Lauren Shaw, East Belfast Enterprise, City East Building, 68 – 72 Newtownards Road, Belfast, BT4 1GW Tel 028 90942010, email lauren@eastbelfast.org

Why East Belfast Enterprise processes personal data and the legal basis for it to do so

There are six different types of stakeholder whose personal data may be stored and processed by East Belfast Enterprise from time to time:

  • Existing tenants who are accommodated within property owned by East Belfast Enterprise in the City East Building and at the site at 308 Albertbridge Road, Belfast, BT5 4GX

Contact details and subject preferences are retained for this category of Data Subject or ‘natural person’.  This data:

  1. Is necessary for performance of contract – represented by the provision of tenancy related services by East Belfast Enterprise to its tenants.
  2. Is with the consent of the natural person – in that it is explicit when signing up to tenancy with East Belfast Enterprise that East Belfast Enterprise needs to communicate to the Data Subject about tenancy related matters and services.
  3. Is in the legitimate interests of the controller, or a third party, except when overridden by the interests or fundamental rights and freedoms of the natural person – in that these data are needed by East Belfast Enterprise in order to fulfil the delivery of the agreed tenancy services, including the provision of property related matters and event information, to its tenants.
  • Prospective tenants enquiring about tenancy within the property sites owned and managed by East Belfast Enterprise. Contact details, completed enquiry forms and application forms are held for this category of Data Subject. This data:
  1. Is necessary for performance of contract – represented by the provision of tenancy related services by East Belfast Enterprise to its clients.
  2. Is with the consent of the natural person – in that it is explicit from sharing contact details with East Belfast Enterprise (e.g. by handing over a business card) or from supplying a completed enquiry form or application form that the Data Subject expects communication from East Belfast Enterprise.
  • Clients Receiving Training and Advice

Contact details, completed programme application forms. This data:

  1. Is necessary for performance of contract – represented by the fulfilment of training and advisory services to clients jointly by East Belfast Enterprise and its partners.
  2. Is with the consent of the natural person – in that it is explicit that these data are required for the services to be provided to the Data Subject.
  3. Is in the legitimate interests of the controller, or a third party, except when overridden by the interests or fundamental rights and freedoms of the natural person – in that these data are needed by East Belfast Enterprise in order to fulfil the delivery of training and advisory services to its clients jointly with its partners.
  • Staff and volunteers

Contact details, CV information, completed recruitment application forms, medical information and bank details are held for this category of Data Subject.  This data:

  1. Is necessary for performance of contract – represented by the provision of labour by staff to East Belfast Enterprise and pay and benefits in return.
  2. Is in compliance with legal obligation – in order for East Belfast Enterprise to fulfil its employment and welfare obligations to staff.
  3. Is with the consent of the natural person – in that it is explicit that these data are required to process pay and benefits and manage welfare issues.
  4. Is in the legitimate interests of the controller, or a third party, except when overridden by the interests or fundamental rights and freedoms of the natural person – in that these data are needed by East Belfast Enterprise in order to fulfil the delivery of the agreed pay, benefits and welfare services to its staff.
  • Delivery Partners of East Belfast Enterprise

Contact details, completed programme application forms. This data:

  1. Is necessary for performance of contract – represented by the fulfilment of services to clients jointly by East Belfast Enterprise and its partners.
  2. Is with the consent of the natural person – in that it is explicit that these data are required for the services to be provided to the Data Subject.
  3. Is in the legitimate interests of the controller, or a third party, except when overridden by the interests or fundamental rights and freedoms of the natural person – in that these data are needed by East Belfast Enterprise in order to fulfil the delivery of services to its clients jointly with its partners.
  • Suppliers to East Belfast Enterprise

Contact details and bank account details are held for this category of Data Subject. This data:

  1. Is necessary for performance of contract – represented by the fulfilment of services to staff and contractors jointly by East Belfast Enterprise and its partners.
  2. Is with the consent of the natural person – in that it is explicit that these data are required for services to be provided to the Data Subject e.g. payroll and pension administration.
  3. Is in the legitimate interests of the controller, or a third party, except when overridden by the interests or fundamental rights and freedoms of the natural person – in that these data are needed by East Belfast Enterprise in order to fulfil the delivery of pay, benefits and employment welfare to its clients jointly with its partners.

The categories of personal data East Belfast Enterprise may store or process from time to time

Data revealing racial or ethnic originHealth dataLocation data
Political opinionsBasic personal identifiers, eg name, contact detailsGenetic or biometric data
Religious or philosophical beliefsIdentification data, eg usernames, passwordsCriminal convictions, offences
Trade union membershipEconomic and financial data, eg credit card numbers, bank details
Sexual orientation dataOfficial documents, eg driving licences

Transfers to third countries and safeguards

East Belfast Enterprise does not store or process data outside of the European Union (EU).

Providers of its ICT ‘cloud’ storage and data processing software, including storage providers like ‘Google Drive’ or Survey Distribution suppliers like Mailchimp, are certified as storing data in the EU.  This is a condition of East Belfast Enterprise working with these suppliers.

Your rights as a ‘Data Subject’

People whose data East Belfast Enterprise has enjoy a range of rights under a range of legislative measures presented under the aegis of the GDPR regulations.  They include:

  • The right for people to withdraw their consent for East Belfast Enterprise to use their personal data, where relevant at any time.
  • The right to lodge a complaint about East Belfast Enterprise’s data protection and privacy measures with a supervisory authority like the Information Commissioner’s Office.
  • The right to ask for the source of the data East Belfast Enterprise holds on an individual, including if it came from a publicly accessible source.
  • The right to know whether an individual’s personal data is stored or processed as part of a statutory or contractual requirement, and what the consequences would be to the individual if East Belfast Enterprise failed to obtain the personal data.

Note that East Belfast Enterprise does not process personal data using any ‘automated decision-making’ tools. For example, it does not use software to ‘profile’ job candidates or shortlist people.

East Belfast Enterprise has a policy to let people know about this privacy notice at the time that they themselves first engage with it.   If we contact you using contact details that we first obtained from a source in the public domain, like a website, we will let you know where we got it in our first communication with you.  East Belfast Enterprise will not ever disclose your contact details, unless we get your permission first.