Belfast Harbour is committed to protecting and respecting your privacy. We know how important it is to protect your privacy and comply with data protection law. If we need to collect, store or otherwise use your personal information, we will:
- have a legal basis for doing so, and only ask for what we need;
- do so in a fair and transparent way, letting you know why we need your information and how we will use it;
- use it in the way we said we would and not in a way you wouldn’t expect without letting you know;
- ensure that we don’t keep more than we need, for longer than we need;
- make sure it is accurate and up-to-date;
- make sure nobody has access to it who shouldn’t;
- ensure that it is kept safe and secure;
The General Data Protection Regulation (GDPR) 2018, regulates the processing of personal data. The GDPR seeks to protect your rights to your personal data by setting out, amongst other things, the conditions under which the processing of personal data is lawful, the rights of data subjects and the standards that organisations that handle personal data must adopt.
This policy and notice is applicable to all data subjects whose personal data we collect, store or use. ‘Personal Data’ means any information relating to or which identifies you. This can include items such as your name, address, phone number, identification numbers (such as an account number or your national insurance number), location data or online identifiers. Personal data can be held electronically or in hard copy. This Privacy Notice is issued in accordance with the General Data Protection Regulation (GDPR) 2018, and the Data Protection Act (DPA) 2018.
Who are we?
Belfast Harbour is a Trust Port.
Belfast Harbour Commissioners is the official name of the Independent Statutory Corporation which oversees the running of Belfast Harbour. It was created by the 1847 Belfast Harbour Act with the task of "operating, maintaining and improving" the Harbour. Its power and duties have been further defined by a range of subsequent Harbour-related legislation.
Belfast Harbour is one of 100 Trust Ports in the UK and, in common with those ports, it operates commercially. Trust Ports, however, do not have any shareholders or owners and are outside the public sector. All surpluses generated by the Port are reinvested back into the business for the benefit of its stakeholders and the development of the Harbour. Stakeholders include a diverse range of groups including port customers, port tenants, local communities and the wider economy.
The day-to-day operation of Belfast Harbour is managed by an executive leadership team which reports to the Board.
2. Our lawful basis for processing personal data
Each business process involving personal data is independently assessed to determine its lawful basis. The lawful basis is recorded in our Data Inventory. To process personal data, we need to meet one of the following conditions (or legal bases):
- you have freely given your consent – it will be clear to you what you are consenting to, for some business purposes it will be necessary for you to provide consent to avail of that service, withdrawing consent will remove our ability to provide that particular service;
- it is necessary for a contract you have entered into with us, or a contract that you intend to enter into;
- it is necessary to meet a legal obligation;
- it is necessary to protect someone’s ‘vital interests’ (a matter of life or death);
- it is necessary to perform a public task (to carry out a public function or exercise powers set out in law, or to perform a specific task in the public interest that is set out in law);
- it is necessary for our legitimate interests or that of a third party (a condition used where personal data is going to be used in ways that are reasonably expected and are not intrusive, or where there are compelling reasons for the processing);
There are further requirements for processing more sensitive, or ‘special category’, personal data. The lawful basis that we rely on to process your personal data will determine which rights are applicable to you.
3. Your rights
You have fundamental rights over your personal data. These are explained in detail on the Information Commissioners website, Belfast Harbour is committed to making it as simple as possible for you to exercise your rights.
- Right to be informed - you have the right to be aware of how we use your information, as set out within this policy;
- Right of access - you have the right to request a copy of the information that we hold about you;
- Right of rectification - you have a right to correct data that we hold about you that is inaccurate or incomplete;
- Right to be forgotten - in certain circumstances you can ask for the data we hold about you to be erased from our records;
- Right to restriction of processing - where certain conditions apply to have right to restrict the processing;
- Right of portability - under certain circumstances you have the right to have the data we hold about you transferred to another organisation;
- Right to object - you have the right to object to certain types of processing such as direct marketing;
- Right to object to automated processing, including profiling - you also have the right to be subject to the legal effects of automated processing or profiling.
4. Data Protection Principles
Belfast Harbour Commissioners are committed to complying with data protection law. The personal information we hold about you will be:
- used lawfully, fairly and in a transparent way;
- collected only for valid purposes and not used in any way that is incompatible with those purposes;
- relevant to those purposes and limited only to those purposes;
- accurate and kept up to date;
- kept only as long as necessary;
- kept securely
Belfast Harbour Commissioners will only share your personal data with third parties where we have appropriate legal grounds under data protection law which permits us to do so. Where we transfer any data to a third party we put in place all necessary controls to ensure the protection of privacy.
We keep personal data only for as long as is necessary for the particular purpose(s) for which it was collected or for as long as we are required to do so by contractual requirement, regulation or law.
7. Withdrawal of Consent
Where BHC holds personal data on the basis of consent you may withdraw your consent for BHC to hold this data at any time by contacting the Data Protection Officer at firstname.lastname@example.org. We will remove your personal data as soon as reasonably practicable and confirm this to you on completion. You should be aware that withdrawal of consent will result in removal of the service provided on the basis of this consent.
Belfast Harbour Commissioners has implemented technical and organisational measures to ensure all personal data processed remains secure, however, absolute security cannot be guaranteed. We use a range of measures to ensure we keep your personal data secure, accurate and up to date. These include:
- education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
- administrative and technical controls to restrict access to personal data based on need;
- technological security measures, including fire walls, encryption and anti-virus software; and
- physical security, such as security passes and access control measures.
The transmission of data over the internet (including by e-mail) is never completely secure, so although we use appropriate measures to protect personal data, we cannot guarantee the security of data transmitted to us or by us.
9. Third Countries
For the purposes of GDPR we are resident in the United Kingdom and regulated by the Information Commissioner’s Office. We do not carry out any data processing outside of the EEA; if that changes, we will inform you.
10. Further Information
In the event that you require further information about how your personal data is being processed by Belfast Harbour Commissioners (or by any third parties as described above), you can contact Belfast Harbour Commissioners' Data Protection Officer directly at:
email@example.com or by:
Writing to the Data Protection Officer at our registered office:
Belfast Harbour Commissioners,
The Harbour Office,
You may also contact Belfast Harbour directly through our website at:
Alternatively if you are not satisfied with the way your enquiry or complaint has been dealt with, you may contact the Information Commissioners Office (ICO). The UK Government has established the Information Commissioners Office (ICO) as the UK's independent body to uphold information rights.
The ICO's office in Belfast provides a local point of contact for members of the public and organisations based in Northern Ireland. As well as operating an advice service to address general enquiries on data protection and freedom of information, it promotes good practice in information rights by raising awareness of organisational responsibilities across all sectors.
The ICO's contact details are:
Web: https://ico.org.uk(for all UK services)
Telephone: 028 9027 8757 / 0303 123 1113
Email: firstname.lastname@example.org, or by writing to:
The Information Commissioner's Office - Northern Ireland
14 Cromac Place,
11. Changes to this policy