Effective date: 11 January 2021
General Nuclear System Limited, China General Nuclear Power Corporation and our group companies in the United Kingdom (collectively “we“, “us“) take the security and privacy of data seriously. We need to gather and use certain information or ‘data’ about you in order to manage our relationship with you and comply with our legal obligations. In addition, we are also required to comply with our legal obligations under UK Data Protection Legislation.
This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Notice applies to:
- personal information that we collect through our websites and, in particular, our feedback form at https://comment.ukhpr1000.co.uk/admin/b24f4d96/consultation/intro/ (“Websites“)
- personal information that you provide when you call any of our helplines, as identified on our websites (“Helplines“); and
- any other personal information you provide to us electronically (e.g. via email). This may, from time to time include Special Category Data, as set out under section “What data do we collect and why?” below.
It does not apply to external visitors to our facility or to our employees, to whom we make available separate privacy notices.
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.
What do we do?
We design, build and operate nuclear power stations in the United Kingdom. We are regulated by the Office for Nuclear Regulation, which imposes strict security and data retention requirements. Security is therefore essential to the operation of our facilities and we must operate comprehensive security and monitoring systems in order to protect our facilities.
What data do we collect and why?
We will collect, process and retain information about you that you provide voluntarily, that we collect automatically and that we obtain from third party sources. In general, we will use the personal data that we collect from you only for the purposes described in this Privacy Notice, or for purposes that we explain to you at the time we collect your personal data (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes), if and where this is permitted by applicable data protection laws.
- Information that you provide voluntarily
Certain parts of our Websites and Helplines may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details in order to provide feedback to us and/or to submit enquiries to us. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information. In particular, in our feedback forms we collect:
- Name and contact information including email address.
- Demographic information such as postcode, preferences and interests.
- Your views and opinions relevant to our business and technology.
- Other information relevant to our business.
- Information that we collect automatically
When you visit our Websites, we may collect certain information automatically from your device. In some countries, including the United Kingdom, this information may be considered personal information under UK Data Protection Legislation.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Websites, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Websites, where they come from, and what content on our Websites is of interest to them. We use this information for our internal analytics purposes, to improve the quality and relevance of our Websites to our visitors and for compliance with our legal obligations (particularly those that we owe to the Office for Nuclear Regulation).
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.
- Information that we obtain from third party sources
From time to time, we may obtain personal information about you from third party sources (such as your organisation’s own website or from social media platforms) in order to check who you are or what your qualifications are in relation to any feedback that you have provided on our Websites. We may use the information we receive from third party sources to maintain and improve the accuracy of the records that we hold about you for the purposes described in this notice.
- Special Category Data that you provide voluntarily
The UK Data Protection Legislation recognises certain types of information as being particularly sensitive and requiring a higher level of protection (“Special Category Data”). Special Category Data includes:
- race or ethnic origin;
- political opinions;
- religious or philosophical beliefs;
- trade union membership;
- health information;
- genetic or biometric data; and
- sexual health and orientation.
There are circumstances in which you may provide us with information voluntarily (such as through feedback forms or via the telephone) and you may choose to include Special Category Data. We do not proactively collect Special Category Data and it is completely optional for you to provide such information when engaging with us. When you provide us with this information you consent to us processing your Special Category Data in accordance with this Privacy Notice. We may use any Special Category Data that you provide us with to develop our project and to manage our relationship with you.
We are unable to filter Special Category Data from any engagement you have with us and therefore if you would prefer that your Special Category Data is not processed by us, we ask that you do not include such information in your engagement.
If you have provided us with Special Category Data and subsequently change your mind regarding its processing you have rights set out under “Your Data Protection Rights” below.
In addition to the purposes described above, we also collect and use your personal data for the purposes of:
- complying with the Office for Nuclear Regulation’s legal and regulatory requirements;
- complying with any other applicable laws, regulations, industry codes of practice and good industry practices.
Who do we share your personal data with?
We may disclose your personal data to the following categories of recipients:
- to our group companies, business partners, third party contractors and services providers or suppliers who provide data processing services to us (for example, to provide security services to us for the management of our facilities), or who otherwise process personal data for purposes that are described in this Privacy Notice or notified to you when we collect your personal data;
- to the Office for Nuclear Regulation and Environment Agency for the purpose of complying with our legal and regulatory requirements;
- to any other competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- to a buyer of any part of our business, provided the buyer complies with this Privacy Notice in respect of its processing of your personal data; and
- to any other person with your consent to the disclosure.
Legal basis for processing your personal data
Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it.
However, we will normally collect personal data where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Our legitimate interests include:
- the need to keep our facilities secure and to manage them properly;
- to manage our customer and government relationships;
- to communicate regarding our services and for our PR and internal analytics purposes;
- managing our supply chain;
- performing contracts with our business and governmental partners, and to process and fulfil orders;
- improving or identifying areas for improvement of our technology and our business.
We take measures to ensure that your personal data is kept secure and to limit our processing activities to what is necessary for our legitimate interests. We also give you the right to object to processing that we undertake for our legitimate interests (please see the section entitled “your data protection rights” below); however please note that if you exercise your right to object to some of our processing activities we may need to restrict access to our Websites or particular parts of them.
In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person (e.g. for the purposes of contacting the Office for Nuclear Regulation if you provide information about our business or technology that we are required to report to them).
If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data).
Our legal basis for collecting and using your Special Category Data will normally be explicit consent, unless stated otherwise upon collection.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided under the “How to contact us” heading below.
Cookies and similar tracking technology
Who will process your personal data and where will it be processed?
Your personal data may be processed by us and by those categories of third parties to whom we are entitled to disclose your personal data. Your personal data may be transferred to and processed in countries other than the United Kingdom. These countries may have data protection laws that are different to the laws in the United Kingdom (and, in some cases, may not be as protective).
- our group companies operate in countries including the United Kingdom and China; and
- China General Nuclear Power Corporation may use service providers in China.
Where we do transfer your personal data outside of the United Kingdom, we will endeavor to take appropriate safeguards to require that your personal data will remain protected in accordance with this Privacy Notice. This may include implementing Standard Contractual Clauses for transfers of personal data requiring third parties to protect personal data they process from the UK in accordance with UK Data Protection Legislation. This may also involve asking you to complete a consent form in respect of transferring your personal data to the People’s Republic of China or other countries outside of the United Kingdom.
How do we keep your personal data secure?
We use appropriate technical and organisational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data.
How long will we retain your personal data?
We retain personal data that we collect about you where we have an ongoing legitimate business need to do so (for example, to maintain the security of our facilities or to comply with applicable legal or regulatory requirements).
Where we have no ongoing legitimate business need to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
In general, we will keep personal data that is relevant to our ability to comply with the Office for Nuclear Regulation in accordance with our regulatory requirements. Therefore, we may hold on to your personal data until approximately 2 years from actual completion of the Generic Design Assessment process.
Your data protection rights
You have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal data, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
- In addition, you can object to processing of your personal data or ask us to restrict processing of your personal data. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
- Similarly, if we have collected and process your personal data with your consent, then you can withdraw your consent at any time. However, withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.. Our regulator in the United Kingdom is the Information Commissioner’s Office: https://ico.org.uk/global/contact-us/.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Please note that, if you exercise your data protection rights in a way that will impact on the normal operation of our Websites, then we may need to restrict your access to our Websites or certain parts of them.
Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the “effective date” displayed at the top of this Privacy Notice.
How to contact us
General Nuclear International Limited, General Nuclear System Limited and China General Nuclear Power Corporation are each separate and independent controllers of your personal information.
China General Nuclear Power Corporation has appointed General Nuclear International Limited as its representative for handling any complaints in relation to this policy or China General Nuclear Power Corporation’s processing of your personal information.
If you have any questions or concerns about our use of your personal data, please contact us using the following details:
E-mail the Legal Director (Legalteam@cgnuk.co.uk) or write to the Legal Director at the address below:
Rex House (Floor 5)
4-12 Lower Regent Street
London, SW1Y 4PE