Benchmark Consumer Privacy Policy
Benchmark (referred to in this document as ‘Benchmark’, ‘data controller’, ‘data processor’, ‘we’, ‘our’ or ‘us’), is committed to protecting and respecting your privacy and the security of your personal data. This privacy policy aims to be clear and transparent about what we do with any personal data we collect and/or process on behalf of manufacturers and installers.
About us
Benchmark is a nationally recognised scheme administered by the Heating & Hotwater Industry Council (HHIC), which outlines the responsibilities of both manufacturers and installers, regarding safety and efficiency of domestic and commercial heating and hot water products. HHIC is a division of Energy & Utilities Alliance whose registered office is Camden House, Warwick Road, Kenilworth, Warwickshire, CV8 1TH.
If you have any questions, requests or comments regarding this privacy policy, you can email info@benchmark.org.uk. You can also contact us at the above postal address.
Applicable laws
The UK General Data Protection Regulation (UK GDPR), the Privacy and Electronic Communications Regulations (PECR) and the Data Protection Act 2018 (DPA 2018) seek to protect and enhance the rights of UK and all other data subjects worldwide. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the movement of personal data out of the UK.
Data processing
Benchmark is both a data controller and in the case of the Benchmark App a data processor. The Benchmark App is used by manufacturers and installers to record installation information concerning domestic and commercial heating and hot water products.
When working as a data processor, Benchmark will be acting on the instructions of the manufacturers and installers, and will work hard to ensure that all services provided are fully UK GDPR compliant. This may include, for example, supporting product manufacturers with data subject access requests. Where Benchmark is acting as a data processor, the manufacturers and their associated companies’ privacy policies and cookies policies will be the applicable documents in determining how personal data is processed.
Benchmark app
Some of the information stored on the Benchmark App includes personal identifiable information which may include names, addresses and other contact information. Consumers registered on the Benchmark App are responsible for checking and maintaining the accuracy of data input via the registration page. The registration is linked to the address/property in order to support appropriate management of the heating system.
Personal data collection
We may collect personal data from you in the following circumstances, when you:
- Complete a form on our site www.benchmark.org.uk or app. This includes information provided at the time of registering to use our site or app, and completing the Contact Form.
- Visit our site: we may automatically collect traffic data, location data, browser, usage and other communications data via cookies;
- Report a problem with our site or app;
- Interact with us via social media;
- Complete any surveys we send to you.
- And via information shared by equipment manufacturers and fitters
When you visit our website or our social media sites’ we will automatically collect technical information via cookies, such as the internet protocol (IP) address used to connect your device to the Internet, where you connected to our service, your internet service provider (ISP), device type, unique device identification numbers, browser type, broad geographic location (e.g. country or city location) and other technical information. We may also collect information about how your device has interacted with our site or app, including the pages accessed and links clicked. We use cookies and similar technology to distinguish you from other users of our site. This helps us to provide you with a good experience when you use our site and also allows us to improve our site. Please see our separate cookies policy.
Our legal basis for processing your data
When you contact us using the Contact Form on our website or support email, we may store your personal data. The legal basis for this is ‘legitimate interest’. Where we process your personal data under this basis, we perform an assessment that balances your rights and freedoms alongside our interests, to ensure that what we do with your personal data is what you would reasonably expect.
We may communicate with you by email or push notification, for example to provide safety information on the basis of your vital interests. We may also provide opt in service reminders on the basis of legitimate interests. For marketing purposes any communications will be on the basis of consent.
We may ask you to complete surveys for research purposes. The legal basis for these is normally legitimate interest, performance of a contract or legal obligation. You have the right to withdraw your consent at any time unless we are under a legal obligation to provide the survey.
If you want us to stop sending you non-essential information by email, you can opt out at any time by selecting the ‘unsubscribe’ link on any email we send you. You can also email us via info@benchmark.org.uk or write to us at: Benchmark, Heating & Hotwater Industry Council, Camden House, Warwick Road, Kenilworth, Warwickshire, CV34 5YQ.
How we share your personal data
We may disclose your information to third parties if we:
- Have a duty to disclose your personal data to comply with any legal obligation. This includes sharing information with other organisations for the purposes of fraud prevention.
We are required to have written contracts in place with any third parties we use to process your personal data.
This is to ensure that third party processors only act on the documented instructions of the data controller, and to ensure that all parties understand their responsibilities, especially in regard to safeguarding personal data.
Third parties we store, share or process data with are listed below:
- Product manufacturers and any associated group companies
- Google Firebase & Analytics (anonymised analytics)
- Sentry (app crash reporting which may include device and user details)
- Benchmark App via AWS London
- Mailgun Technologies
- Red C Red C Mobile Limited (London), a data sub processor
In particular, please note that product manufacturers and their associated companies could have access to your personal data (including your name and contact information, product warranty and servicing details) and may use such information for purposes which include: (i) assessing the warranty position or servicing history of a product installed for you; and/or (ii) contacting you with relevant offers. By using our site (www.benchmark.org.uk) or app, you will be deemed to consent to the processing of your data. You can withdraw your consent at any time but this may mean that you are unable to enjoy the full benefits of the site and/or app. In exceptional circumstances even if you unsubscribe manufacturers may need to communicate in your vital interests such as product recalls which will override your ability to withdraw consent.
How long we keep your personal data for
We only keep personal data for as long as we have a legal basis to do so, and we adhere to the principle of data minimisation. This means that we only keep the minimum amount of information necessary for specific processing. The retention period for hardware is the lifetime of the product, which is typically 15 – 20 years. The default period for everything else is eight years. For HR information please contact us using the contact information provided at the start of this privacy policy.
- We keep personal data you provide by registering on our site or app or filling in a form, unless or until you unsubscribe or delete your account. If you unsubscribe, we retain minimal information about you to ensure that we know you have unsubscribe.
Security of personal data
We are committed to the security of your personal data. All personal information entered into Digital Benchmark is stored on secure encrypted servers hosted in the UK. Where you have chosen a password that enables you to access the website or app, you are responsible for keeping this confidential.
Your rights
You have certain rights under data protection law, and you can make requests to us about any personal data we hold about you. Contact us on info@benchmark.org.uk
- Right to be informed. You have the right to be informed about the collection and use of your personal data, as detailed in this Privacy Policy;
- Right to access. You have the right to request a copy of the information we hold about you. If you want to request a copy you can contact us as detailed above;
- Right to rectification. We want to make sure that your personal information is accurate and up to date. You have the right to ask us to correct or remove information you think is inaccurate.
- Right to erasure. You have the right to ask us to delete your personal data. You can ask us to erase your personal data where there is no good reason for us to continue to process it. This will apply for example where the purpose we collected your information for is no longer relevant, or where you withdraw consent, if consent was given to start with;
- Right to restriction. You have the right to request the restriction or suppression of your personal data under certain circumstances. This means you can limit how we use your personal data. This might apply if for example you believe the processing is unlawful;
- Right to data portability. You have the right to ask for a copy of your personal data in a form that lets you copy or transfer it to another IT system in a machine readable way, and / or another organisation. This will apply where the processing is based on consent or a contract, and the processing is by automated means;
- Right to object. You have the right to object to the processing of your personal data in some circumstances. You have the right to stop your data being used for direct marketing purposes;
- Right not to be subject to automated decision making including profiling. Where such processing produces legal effects or similarly significantly affects;
- Right to withdraw consent. Where our processing is based on your consent, you have the right to withdraw this consent at any time;
- Right to complain to a supervisory authority. If you are concerned about how we are handling your personal data, you have the right to complain to the data protection authorities. In the UK, this is the Information Commissioners Office https://ico.org.uk/concerns/ or 0303 123 1113
To access what personal data is held, identification will be required.
Benchmark will accept the following forms of ID when information on your personal data is requested: a copy of your driving licence or passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required.
If Benchmark is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to info@benchmark.org.uk, or by writing to us at: Benchmark, Heating & Hotwater Industry Council, Camden House, Warwick Road, Kenilworth, Warwickshire, CV34 5YQ
Changes to our privacy policy
Amends to this privacy policy may be made to ensure it is kept up to date and to ensure regulatory requirements are met. You have a responsibility to view this policy from time to time to be aware of any such change.
More information
For more information on UK GDPR and your rights please see:
https://ico.org.uk/for-organisations/data-protection-reform/overview-of-the-gdpr/
