How the Association Collects and Uses Personal Information Fairly and Transparency

The first principle of data protection is that personal data must be processed fairly and lawfully. The DPA says that in order for the processing to be fair, the data controller (the organisation in control of processing the data) has to make certain information available to the data subjects (the individuals whom the data relates to), so far as practicable.   Legislation (GDPR) which comes into effect in May 18, extends the rights of individuals.

This document is the RHANI policy document which sets out our position and policy as follows:

  • who the data controller is; The Renewable Heat Association Northern Ireland Limited (RHANI) is a not-for-profit organisation formed as a limited company without shares.  Andrew Trimble, the Executive Chair is responsible and accountable for the lawful and appropriate use of personal information collected, processed and retained by RHANI.
  • the purpose or purposes for which the information will be processed are:
    • To capture contact information for RHANI members of all classes.
    • To secure and then record positive consent from our members for the processing of their personal data and positive consent for the distribution of information to members;
    • To be able to communicate with members by electronic means;
    • To understand the business classifications/types of members;
    • To provide appropriate financial reports and returns required of RHANI to HMRC, to Companies House and to respond to direction from the Courts about our member interests.
  • any further information which is necessary in the specific circumstances to enable the processing to be fair?
    • RHANI will analyse personal data published by OFGEM and DfE on their websites in order to ensure that members’ circumstances are properly reflected and recorded.
    • RHANI will analyse the scale and pattern of usage of our website and webservices.
    • RHANI will collect contact information from private company websites for the purposes of communications with companies.
    • RHANI will conduct an annual data verification exercise and will provide members with a copy of their membership application form from which personal data was taken for our records and will provide an opportunity for members to correct any incorrect information.

This applies whether the personal data was obtained directly from the data subjects or from other sources.

  • What information is being collected?
    • Member and organisation names, addresses, telephone numbers, number of RHI (NI) accredited boilers and the OFGEM/DfE accreditation number of each boiler, financial information to include sums invoiced, VAT liable and sums paid.
  • Who is collecting it?
    • The Renewable Heat Association Northern Ireland Limited;
  • How is it collected?
    • By submission by members of completed membership application forms/renewal forms, invoices and receipts;
    • By comparison with data published on-line by DfE (NI) and OFGEM.
    • By observation of the interaction with RHANI web—based services and the website www.rhani.org.
  • Why is it being collected?
    • To properly administer RHANI;
    • To properly manage RHANI and to identify the financial contribution each member makes to the maintenance of the Company;
    • To be in a position to make appropriate financial distribution to paid-up members pro-rata upon the wind-up of RHANI Ltd.
    • To meet with HMRC requirements for the recording and the submission of VAT in respect of services rendered and proper reporting of the retained surplus.
    • To ensure the proper function and use of web-based services.
  • How will it be used?
    • To enable and facilitate communications with members;
    • To properly control finances and manage resources;
    • To make statutory returns and reports;
    • To support the maintenance of Company financial reports and returns;
    • To issue invoices and receipts and to prepare to make a proper distribution of the assets of the Company;
    • To ensure the proper action of web-based services for members.
  • How Long Will it be Held?
    • Data will be held no longer than is necessary;
    • Data will be retained in order to meet the commitment to redistribute retained funds once the aims and objectives of the Company have been met, records of contributions made in each calendar year will be held for twelve months after the wind-up of the Company;
    • E-mails (and attachments) will be deleted after 24 months.
    • Financial data, invoices, receipts and reports and returns to Companies House will be retained in line with the statutory requirement – 1 + 7 years.
  • Who will it be shared with?
    • Administrative functions on behalf of the Company are discharged by a limited number of employees of Action Renewables who have a “need to know” in order to discharge their administrative function.  In this instance, Action Renewables process information for RHANI.
    • Technical and procedural controls are in place to ensure that personal information is inaccessible by all other members of Action Renewables.
    • On completion of the task, Action Renewables will surrender all processed data to RHANI.
    • MASSIVE PR has a role in facilitating communications with RHANI members.  MASSIVE are provided only with e-mail addresses of members in order for them to distribute the RHANI newsletter.
    • On completion of the task, MASSIVE PR will surrender all processed data to RHANI.
  • What will be the effect of this on the individuals concerned?
    • The above information is communicated with RHANI members and is a function of all interactions on the Company website.
  • Is the intended use likely to cause individuals to object or complain?
    • It is unlikely that the use and processing of personal data is likely to cause reason to object or complain.  Any complaints should be addressed to the Executive Chair, RHANI in writing, preferably by email to the email address:  rhani.exec.chair@gmail.com.