Water Stewardship Assurance Services (WSAS) takes your data privacy seriously. In the course of Registering for Certification or becoming a contracted supplier with us, we collect and use personal data which means that we are a ‘Data Controller’ and we are responsible for and committed to complying with Data Protection Laws including the UK General Data Protection Regulations (UK GDPR), the EU General Data Protection Regulations, the Data Protection Act 2018 and any subsequent laws.
In this Privacy Notice, we want to inform you about what information we collect, how we use it and what rights individuals have in relation to the collection and processing of their personal data.
Our Contact Details:
Water Stewardship Assurance Services Address: 2 Quality Street, North Berwick, Scotland, EH39 4HW
If you have any questions in respect of this Privacy Notice or how we manage your personal data, please contact us using the above details.
Who’s personal data do we collect and process?
We process information about Clients, Auditors, Suppliers and individuals making an enquiry about our services.
What personal data do we collect and process?
In the course of working with you, we can collect the following types of data:
• General contact details such as, Name, Address, Email address, and Telephone number
• Details of your role and business activities if applicable
• General correspondence between you and us in relation to our services
• Details of the services provided to you
• Contact details of nominated contact points and key stakeholders
• Financial details, such as payment information
• Registration details, including log in and account details
• For Auditors and Suppliers o Qualification and Education History o Previous Employment and Background checks
Special Categories of Personal Data that we collect:
We do not collect any special category personal data
How we collect your information
In most cases we collect your data directly from you. We collect data and process it when you:
• Complete an online ‘contact us’ form
• Complete an application for Certification
• Provide information during a meeting or a call
• Correspond with us or send us details in respect of a Certification.
• Email or write to us to enquire about or use our services or provide feedback. In relation to potential onboarding of Auditors, we collect data and process it when you:
o Send us a CV o Complete an application form o Take part in an Interview
o Provide information relating to a potential contract o Provide references
We also receive your data indirectly from the following sources:
• Public sources – demographic data, market research
• Credit agencies and publicly available company data
• Social media and professional network sites
• Other firms in our group of companies Including Alliance for Water Stewardship and their subsidiaries
• From the person applying on behalf of your organisation where you are nominated as a contact point or named as a key stakeholder
Please remember: Where you provide any of this information relating to or on behalf of another individual such as a nominated contact point, you must remember to ensure that you have the consent of the individual and provide them with a copy of or access to this Privacy Notice.
Why do we collect your information?
Where we collect and process personal data, we are required to identify both the purpose and our legal basis for doing so. There are 6 possible legal bases which are:
Consent – where we have your consent for processing your personal data for one or more specific purpose
Contract – where the processing is necessary for the performance of a contract or potential contract with you.
Legal Obligation – The processing is necessary for our compliance with a legal obligation Vital Interests – Where our processing is necessary in order to protect the vital interests of the data subject or another natural person
Public Interest – Where the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority
Legitimate Interests – Where the processing is necessary for the purposes of our legitimate interests except where such interests are overridden by your interests or fundamental rights and freedoms.
Our various purposes and legal basis for the information we collect, are detailed below:
Our Purpose Our Lawful Basis
To understand your requirements prior to entering into a contract of Certification or Services with you
The processing is necessary for the performance of an anticipated Contract
To understand all requirements to ensure that any contract of Certification or Service meets our customer’s needs
The processing is necessary for the performance of a Contract with you
To fulfil our Certification or service contract with you and provide you with the agreed services therein
The processing is necessary for the performance of our Contract with you
To manage our business operations and comply with any internal policies and procedures by understanding what needs to be changed
It is in our legitimate interests to use your personal information to ensure that we can provide and adapt our services at all times
To notify you about changes to our Certification Process or services
It is in our Legitimate Interests to use your personal information to keep you informed about any changes that may affect you
To record discussions and communications to respond to future queries or complaints in relation to previously agreed services
It is in our Legitimate Interests to record discussions and communications in relation to services agreed to enhance and improve our services
For electronic Marketing of services to potential new clients via personal business email addresses
It is in our Legitimate Interests to use personal business email addresses for marketing purposes where we can
support individual’s rights
To comply with our legal obligations, law enforcement, court and regulatory bodies requirements
To comply with our Legal Obligations
To identify and prevent fraud
It is in our Legitimate Interests to act as a responsible business
To decide whether to enter into a contract of Services with a Supplier
The processing is necessary when considering a supplier Contract
To carry out background and reference checks in relation to supplier onboarding
The processing is necessary when considering a supplier Contract
To communicate with you about a potential contract for service or Certification
The processing is necessary for the performance and compliance with any Contract
Where we rely on your consent you have the right to withdraw this consent at any time by contacting us.
Legitimate Interests – Where the processing of personal data is based on our Legitimate Interests, it is to deliver and improve on our service and security and maintain accurate records. It is also in an aim to prevent fraud or illegal activity in favour of the wellbeing of our customers, trustees, shareholders and employees.
We may send you details of similar services to those you have enquired about or contracted with us previously. You can opt out of receiving this information from us at any time by contacting us at the above address or clicking ‘unsubscribe’ on any messages you may receive.
We will never share or sell your information to any other party for marketing purposes.
Who do we share your information with?
From time to time and in the general course of our business, we may share your personal information with some of the following:
• Other firms in our Group of Companies including Alliance for Water Stewardship and its subsidiaries
• Board Members and Certification advisory committee
• Our Accountant or Payment Service Providers
• Regulators and Governing bodies, Lawyers
• Auditors, Suppliers, Contractors, Professional Consultants and Service Providers including Certification Partners
• Software and Cloud storage providers
• Fraud detection Agencies and Credit Reference Agencies
• Police and Law Enforcement agencies where reasonably necessary for the prevention or detection of crime
• Selected Third Parties in connection with any future sale, transfer or disposal of our business
International data transfers
With today’s modern technology including Cloud Storage and software, some recipients of your personal data can be located outside your country or have offices in countries where data protection laws may provide a different level of protection than the laws in your country.
Where this is the case, we make sure that additional safeguards are in place such as ensuring that those countries have a decision of adequacy under the UK GDPR or have entered into Standard Contract Clauses with us in their terms to support and safeguard the protection of your data.
Automated decision-making or Profiling
We do not process personal data for automated decision making or profiling.
How Long do we keep personal data for?
The following details the criteria used to establish the retention period set out within our policy.
Where it is still necessary for the provision of our Services
This includes the duration of any contract for services we have with you and for a period of 3 Years after the end of any contractual agreement with a view to maintaining and improving the performance of our products, keeping our systems secure, and maintaining appropriate business and financial records. Most of our retention periods are determined on the basis of this general rule.
Where required by Statutory, contractual or other similar obligations
Corresponding storage obligations may arise, for example, from laws or regulation. It may also be necessary to store personal data regarding pending or future legal disputes. Personal data contained in contracts, notifications and business letters may be subject to statutory storage obligations depending on national law.
Your Rights as a data subject
As a data subject, you have rights in relation to your personal data. These are:
Access – You have the right to request details of personal information held or processed and to copies of this data. We do not usually charge for this service.
Rectification – You have the right to request that any information be corrected that you believe is inaccurate or to complete any information that you believe is incomplete.
Erasure – You have the right to request that we erase your personal information with some exceptions.
Restrict Processing – You have the right to request that we restrict the processing of your personal data under certain circumstances
Object to Processing – You have the right to object to our processing of your data, under certain conditions.
Data Portability – In some circumstances, you have the right to request that we transfer the data that we have collected to another organisation or directly to you.
You also always have the Right to Withdraw Consent where you have previously provided this.
To exercise any of these rights, or if you have a complaint please contact us using the details at the beginning of this notice.
If after contacting us, you remain unhappy with the outcome, you also have the right to complain to the Supervisory Authority. Where you wish to report a complaint or feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office at:
Information Commissioners Office
Cheshire SK9 5AF
Helpline: 0303 123 1113
Online Enquiries: https://ico.org.uk/global/contact-us/
Contractual Obligations and Consequences
In some circumstances, the provision of personal data is partly required by law (for example, tax regulations, employment and legal obligations) or can also result from contractual provisions. This means that sometimes we cannot complete our agreed service without that information and so if you aren’t able to provide it or ask that we delete it, there is a possible consequence that our contract would need to be cancelled.
Cookies & similar technologies
To learn more about how to manage your browser cookie settings in general please see www.allaboutcookies.org
When clicking on external links via our website, where you find us via social media platforms, or where you register or sign up to training or webinar video platforms please remember, we have no control over the privacy settings on these domains, so please review the privacy information on those sites and set your preferences in line with their own policies and cookie controls separately.
We aim to protect your personal data through technical and organisational security measures to minimise risks associated with data loss, misuse, unauthorised access and unauthorised disclosure and alteration.
We store customer records in cloud-based services and data centres which have controlled and restricted access. We operate records management and Information security policies which detail physical security, cloud storage security monitoring, access control and password security measures. We also maintain and use anti-virus and malware software and firewalls.
Changes to our Privacy Notice
Water Stewardship Assurance Services keep our Privacy Notice under regular review. This Privacy Notice was last updated on 16 September 2021.