BROOKFIELD RENEWABLE EUROPE
DATA PROTECTION AND PRIVACY NOTICE
1.1 Brookfield is committed to ensuring that your privacy is protected. Please read the following notice which outlines our practices regarding the use and treatment of your personal data. This notice is being provided to you in accordance with Data Protection Law).
1.2 For the purposes of Data Protection Law, Brookfield acts as a data controller in respect of your Personal Data. Brookfield is responsible for ensuring that it uses your Personal Data in compliance with applicable Data Protection Law.
1.3 This notice sets out the basis on which any Personal Data about you that you provide to Brookfield, that Brookfield creates, or that Brookfield obtains about you from other sources, will be processed.
1.4 The following definitions shall apply to this Notice:
“Brookfield” “we or “us” means the European wholly and partially owned subsidiaries and affiliates of Brookfield Renewable Partners L.P;
“Data Protection Law” means any laws applicable to Brookfield in relation to the processing of Personal Data including without limitation: (i) the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016) and Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector and any legislation implementing, amending or re-enacting any of the foregoing, and (ii) any guidance and/or codes of practice issued by any supervisory authority to whose jurisdiction Brookfield may be subject;
“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Brookfield (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Brookfield or any other person in respect of an individual.
“Regulatory Body” means any regulatory body by which Brookfield is or becomes regulated.
"you" or "your" means individuals whose Personal Data we process in connection with our business.
2. THE TYPES OF PERSONAL DATA WE COLLECT
2.1 Brookfield will collect and process the following Personal Data about you:
• Information that you provide to Brookfield. We may process any information that you give us. This includes but may not be limited to:
- details of your name, contact information, address;
- details of your property.
• Information Brookfield may obtain from other sources. This may include information about you, such as:
- details of your name, e-mail address, phone number, contact information, address;
- details of your property.
3. HOW WE USE YOUR INFORMATION
3.1 Your Personal Data may be stored and processed by Brookfield in the following ways and for the following purposes:
• to investigate the possibility of developing wind farm or renewable energy sites in your area;
• to contact you regarding existing or future wind farm or renewable energy development in your area;
• compliance with any legal or regulatory obligation to which Brookfield is subject (including compliance with any request from or obligations imposed by regulatory authorities or other relevant public authorities);
• in order to carry out and administer the operation of Brookfield’s business;
• performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.
3.2 Brookfield is entitled to use your Personal Data in these ways because:
• it is necessary for our legitimate business interests in developing renewable energy projects;
• we have legal and regulatory obligations that we have to discharge;
• the use of your Personal Data as described is necessary for other legitimate business interests, such as:
- allowing Brookfield to effectively and efficiently administer and manage the operation of its business;
- maintaining compliance with internal policies and procedures; or
- in order to contact you or your family in the event of an emergency relating to a renewable energy project.
In addition to the above, we reserve the right to collate, process and disseminate any statistics based on an aggregation of data held by us provided that any individual cannot be identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.
4. PERSONS WITH WHOM WE SHARE YOUR PERSONAL DATA.
4.1 Your Personal Data may be disclosed to one or more of with the Brookfield group of companies for the management and administration of Brookfield’s business and compliance with applicable laws, rules and regulations, and internal policies and procedures across Brookfield (including statutory reporting and disclosures to regulatory authorities).
4.2 Brookfield may also share your Personal Data with third parties in the circumstances described below.
• We may share your Personal Data with third party agents, service providers and contractors for the purposes of providing services to us (for example, professional advisors, Brookfield’s IT systems providers and communications providers). These third parties will be subject to confidentiality requirements and will be restricted from using your data in any way other than to provide services to Brookfield. Brookfield requires that all such third parties enter into contractual obligations to observe security and privacy obligations as least as stringent as those set forth in this notice.
• We may disclose your Personal Data to a third party to comply with a legal obligation to which we are subject – this may include disclosure to regulatory bodies (including tax authorities, law enforcement agencies and financial regulators) or pursuant to an order of a court or tribunal.
• We may disclose your Personal Data to third party litigant in connection with the establishment, exercise or defence of any legal claims in which we are involved.
• We may disclose your Personal Data to a planning authority in connection with any wind farm development.
5. TRANSFERS OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA
5.1 Brookfield may in some circumstances need to transfer your Personal Data to other offices it may have or to Brookfield’s agents and contractors located outside the European Economic Area (“EEA”).
5.2 Where Brookfield transfers your Personal Data outside the EEA, it will ensure that it is protected in a manner that is consistent with how your Personal Data will be protected by Brookfield in the EEA. This can be done in a number of ways, for instance:
• the country that Brookfield sends the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data;
• the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data; or
• where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme.
5.3 In other circumstances the law may permit Brookfield to otherwise transfer your Personal Data outside the EEA. In all cases, Brookfield will ensure that any transfer of your Personal Data done in accordance with Data Protection Law.
5.4 You can obtain more details of the protection given to your Personal Data if it is transferred outside the EEA (including a copy of the standard data protection clauses which Brookfield has entered into with recipients of your Personal Data) by contacting Brookfield as described in paragraph 9 below.
6. DATA SECURITY
6.1 We take our Personal Data security responsibilities seriously, employing the most appropriate physical and technical measures to safeguard Personal Data. including staff training and awareness. We use industry standard security measures to protect your information and to prevent the loss, misuse or alteration of any information in our control. As effective as modern security practices are, no physical or electronic security system is entirely secure and we cannot ensure that Personal Data will never be accessed. However, we will use industry standard security measures to ensure that such information is kept as secure as possible. We also review our data security measures and procedures regularly so that these are kept as up to date with industry standards.
6.2 Unfortunately, the transmission of information by means of the internet, including through e-mail, is not completely secure. Although we will do our best to protect Personal Data, it is not possible to fully guarantee the security of data transmitted to or from us via e-mail.
7. RETENTION OF PERSONAL DATA
7.1 Brookfield wish to only retain your Personal Data for as long as this is necessary.
7.2 How long Brookfield will hold your Personal Data for will vary and will be determined by the following criteria:
• the purpose for which Brookfield is using it – Brookfield will need to keep the data for as long as is necessary for that purpose; and
• legal obligations – laws or regulation may set a minimum period for which Brookfield has to keep your Personal Data.
8. YOUR RIGHTS
8.1 You have a number of legal rights in relation to the Personal Data that Brookfield holds about you. These rights include:
• the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which Brookfield holds about you;
• in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that Brookfield transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided to Brookfield;
• the right to request that Brookfield rectify your Personal Data if it is inaccurate or incomplete;
• the right to request that Brookfield erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask Brookfield to erase your Personal Data but Brookfield is legally entitled to retain it;
• the right to request that Brookfield restrict its processing of your Personal Data in certain circumstances. Again, there may be circumstances where you ask Brookfield to restrict its processing of your Personal Data but Brookfield is legally entitled to refuse that request; and
• the right to lodge a complaint with a supervisory authority if you think that any of your rights have been infringed by Brookfield.
8.2 You can exercise your rights by contacting Brookfield using the details set out in paragraph 9 below.
8.3 The following are the supervisory authorities in the countries where Brookfield carries on business in Europe:
• United Kingdom: Information Commission; website: https://ico.org.uk/
• Republic of Ireland: Data Protection Commissioner; website: https://www.dataprotection.ie
• Portugal: CNPD – Comissão Nacional de Protecção de Dados; website: https://www.cnpd.pt
9. QUESTIONS AND CONCERNS
9.1 If you have any questions or concerns about Brookfield’s handling of your Personal Data, or about this Policy, please contact firstname.lastname@example.org. You also have the right to make a complaint to the relevant regulatory authority, the contact details of which are listed in section 8 above.
10. CHANGES TO THE NOTICE
10.1 This notice is available on the Brookfield Renewable website at http://renewableops.brookfield.com/en/presence/europe
10.2 We may update this privacy notice from time to time and will publish such updated version on our website, as appropriate.