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Data Protection Policy

Last updated Spring 2018

 

DEFINITIONS

  • Organization

    means We Mean Business

  • GDPR

    means the General Data Protection Regulation

  • Responsible Person

    means Robin Knight

  • Register of Systems

    means a register of all systems or contexts in which personal data is processed by the Organisation


1. DATA PROTECTION PRINCIPLES

The Organisation is committed to processing data in accordance with its responsibilities under the
GDPR.

Article 5 of the GDPR requires that personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to individuals;
  2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest,scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
  6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

2. GENERAL PROVISIONS

  1. This policy applies to all personal data processed by the Organisation.
  2. The Responsible Person shall take responsibility for the Organisation’s ongoing compliance with this policy.
  3. This policy shall be reviewed at least annually.

3. LAWFUL, FAIR AND TRANSPARENT PROCESSING

  1. To ensure its processing of data is lawful, fair and transparent, the Organisation shall maintain a Register of Systems.
  2. The Register of Systems shall be reviewed at least annually.
  3. Individuals have the right to access their personal data and any such requests made to the Organisation shall be dealt with in a timely manner.

4. LAWFUL PURPOSES

  1. All data processed by the Organisation must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
  2. The Organisation shall note the appropriate lawful basis in the Register of Systems.
  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
  4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Organisation’s systems.

5. DATA MINIMISATION

  1. The Organisation shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

6. ACCURACY

  1. The Organisation shall take reasonable steps to ensure personal data is accurate.
  2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

7. ARCHIVING / REMOVAL

  1. To ensure that personal data is kept for no longer than necessary, the Organisation shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
  2. The archiving policy shall consider what data should/must be retained, for how long, and why.

8. SECURITY

  1. The Organisation shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
  2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
  3. When personal data is deleted this should be done safely such that the data is irrecoverable.
  4. Appropriate back-up and disaster recovery solutions shall be in place.

9. BREACH

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Organisation shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).

END OF POLICY

Harness climate action

as a driver of innovation, competitiveness, risk management and growth.

take action

The transition to a zero carbon economy is inevitable. Now is the time for companies to start preparing for a zero carbon future.

Jill Duggan, Director of The Prince of Wales’s Corporate Leaders Group

This milestone [Paris] Agreement is an important step in ensuring we can maintain quality of life on our planet for future generations.

Neil McArthur, CEO Arcadis

Now businesses are enabled to work together with governments and communities to shape the policies and take the actions necessary to transition to a low carbon future.

Richard Lancaster, CEO of CLP

We are entering an era of system transformation. Business is already playing a leadership role through global collaboration and low carbon partnership initiatives to drive innovation and structural change.

Peter Bakker, President of WBCSD

The global transition to a low-carbon economy is urgent, inevitable, and accelerating faster than we ever believed possible.

Paul Polman, CEO of Unilever and Chairman of the World Business Council for Sustainable Development

We are already not only bending the curve of emissions but actually already in a global consensus about the inevitability of the major shift that will occur in this century.

Christiana Figueres

Investors are interested in our total water stewardship as it is directly linked to our business strategy, long-term growth and company acceptance.

Coca-Cola HBC

In anticipation of changing weather patterns and potential shortages of water, we have made water efficiency a key strategic ambition shaping our product range.

Syngenta

Water risks pose social, environmental and ultimately financial risks. Therefore it is obligatory for all sites, affiliates and operations to include a water risk assessment within their overall risk assessment procedures.

Roche Holding

As corporations make an effort to enhance energy productivity there will be innovation and development of new technologies that will change the way we live and work.

Anirban Ghosh, CSO, Mahindra Group

We find that many of our suppliers can reduce their energy consumption by 5% or more with basic training and implementation of low-cost/no-cost improvement measures.

Clay Nesler, Vice President for Global Energy & Sustainability at Johnson Controls

Reducing energy consumption will be the primary vehicle in achieving our goals. We are very pleased to be the first property company to sign up to EP100, ensuring we will increase our energy productivity for the benefit of our customers.

Robert Noel, Chief Executive, Land Securities

For a company with our global footprint, increasing our energy productivity by two-thirds as we have done since 2002 means that we are spending over US$100 million less in energy bills each year than if our energy productivity had remained constant.

Clay Nesler, Vice President for Global Energy & Sustainability at Johnson Controls

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Marc Engel, Chief Supply Chain Officer, Unilever

Climate change is a huge risk to the long-term supply of safe, high quality ingredients for Nestlé’s products as crop yields fall and production areas shift. We are determined to play our part in taking climate action by purchasing renewable electricity.

Pascal Gréverath, Head of Environmental Sustainability, Nestlé

Renewable energy plays a key role in achieving our ongoing commitment to carbon neutrality, as we aim to use 100% renewable energy to meet our global electricity needs by 2020.

Anthony Cammarata, Managing Director, Goldman Sachs

Electricity costs are one of the largest components of our operating expenses at our data centers, and having a long-term stable cost of renewable power provides protection against price swings in energy.

Urs Hölzle, Senior Vice President, Technical Infrastructure, Google

By investing in renewables we can not only reduce our emissions but also future proof the business.

Laurel Peacock, Senior Manager of Sustainability, NRG

We wouldn’t be doing this if it didn’t make business and economic sense… It is the way the market is trending and what our customers are demanding.

Laurel Peacock, Senior Manager of Sustainability, NRG

Our target puts us in a good position vis-à-vis government regulation. We are fully compliant with the UK government’s existing targets, and would be well placed were they to introduce more stringent regulation for companies.

Tom Byrne, Energy Manager at Land Securities

We want to know how exposed a particular business is to the changing context on climate and what it is practically doing to make the changes required; including its targets, timeframes and the extent of its ambition.

Andy Howard, Head of Sustainable Research at Schroders

By doubling the efficiency of our US fleet [over five years], Walmart avoided the emission of nearly 650,000 metric tons of CO², while also saving nearly US$1 billion in the past fiscal year.

Rob Walton, Walmart

Ambitious greenhouse gas reduction goals help our teams rally around low-carbon innovation. Of course knowing that our goals are backed by the current climate research increases buy-in and commitment at all levels of the company.

Alexandra Palt, Chief Sustainability Officer, L’Oreal

We are working towards building a clean energy future. Expanding the share of renewables is key to addressing the chronic energy crisis our country is facing today.

Ramadas Kamath, Executive Vice President and Head – Infrastructure and Sustainability, Infosys

I believe that companies are, above all, agents of transformation. We all work at an intersection of economic, political, social and environmental dimensions and have either positive or negative impacts on all of them.

Guilherme Leal, B Team Leader and one of the founders of Natura Cosméticos

I spend a lot of my time saying to business leaders, we are citizens of the world. We cannot just leave things to the social sector and to the politicians to speak up about these climate change issues. We have as much clout as they, if not more than some of them, and we have the responsibility to speak out. And it makes good business sense.

Richard Branson, Founder, Virgin Group

…we’re working in partnerships even with our competitors, but also with governments and other industries. But to help us get there, we need policymakers to play their role. We need them to give us certainty. We need them to level out the playing field.

Hannah Jones, Vice President Sustainable Business & Innovation, Nike

When it comes to climate change, there is some concern about the regulatory policy system. We’re fearful of sudden government interaction. Nothing happens for four or five years and suddenly you are slammed with a huge regulatory system that you were unprepared for. Better to introduce it carefully and voluntarily now – rather than have it unleashed upon us.

Mike Barry, Director of Sustainable Business, Marks & Spencer

From a policy perspective, General Motors and businesses in general look for long-term certainty and clarity. When you get the market, the customers, our products and policy all aligned, that’s when you can drive true transformation of an industry.

David Tulauskas, Director Sustainability, General Motors

Two fiscal policy tools can drive decarbonisation: carbon pricing and the end of fossil fuel subsidies. Paying a price for emissions while, at the same time, encouraging the activity that causes them is perverse.

Sandrine Dixson-Declève, Director of The Prince of Wales’s Corporate Leaders Group

No CEO would survive if they said climate change is not real

Mike Bloomberg, Former NYS Mayor

Moving capital toward a low-carbon economy protects their beneficiaries’ returns, and is one of the fastest ways to address global warming. Companies take note when investors take action, and when money moves, the world moves too.

Lance Pierce, President of CDP North America

California’s political and business leaders arrived (in Paris) with the clear conviction that climate is not only real, but demands action. Our experience offers a wealth of practical lessons for how to make rapid, sustainable progress toward the clean energy future.

Tony Earley, Chairman, CEO and President, PG&E

Science shows that climate change will reduce food productivity and food security at the same time our world’s population is growing and requiring us to feed more people with fewer natural resources.

John Bryant, CEO, Kellogg Company

As a global food company, we recognize the significant impacts climate change can have on our business if left unaddressed.

Ken Powell, CEO, General Mills

(Climate change) is absolutely a threat. And that’s why we’re doing all that we’re doing today.

Barry Parkin, CSO, Mars

I think what we’ve shown already in North Carolina is that when you provide the incentives – the investments tax credits for solar; when you have the renewable energy portfolio — it works.

Letitia Webster, Senior Director, VF

Low-carbon, sustainable investments are key to our future.

Tom DiNapoli, New York State Comptroller

We want the underlying companies in our ($300 billion) portfolio to be aligned with the transition to a low-carbon global economy.

Anne Simpson, Global Governance Investment Director, CalPERS

If you can do one thing for me today, please, never refer to clean energy as “alternative energy” again.

Michael Liebreich, Founder & Chairman of Bloomberg New Energy Finance Advisory Board

Getting to the Paris Agreement was the easy component, it meant setting the starting line. Now we have to turn those intentions into implemented activities and projects.

Christiana Figueres, Executive Secretary, UNFCCC

There seems to be a tendency to believe that now that the Paris Agreement is done, it is now up to governments. But the real action starts now. The business community and civil society need to push governments so that they will keep this agreement.

Ban Ki-Moon, Secretary-General, United Nations

The once unthinkable has now become unstoppable. This train is moving. It started at the Paris station, it has to go and move.

Ban Ki-Moon, Secretary-General, United Nations

The entry into force of the Paris Agreement just ten months after COP21 is a defining moment for the global economy.

Paul Polman, CEO of Unilever and Chairman of the World Business Council for Sustainable Development

The global transition to a low-carbon economy is urgent, inevitable, and accelerating faster than we ever believed possible.

Paul Polman, CEO of Unilever and Chairman of the World Business Council for Sustainable Development

We are entering an era of system transformation. Business is already playing a leadership role through global collaboration and low carbon partnership initiatives to drive innovation and structural change.

Peter Bakker, President of the World Business Council for Sustainable Development

Now businesses are enabled to work together with governments and communities to shape the policies and take the actions necessary to transition to a low carbon future.

Richard Lancaster, CEO of CLP

This milestone Paris Agreement is an important step in ensuring we can maintain quality of life on our planet for future generations.

Neil McArthur, CEO Arcadis

The significance of the Paris Agreement and its universal impact cannot be underestimated. The transition to a zero carbon economy is inevitable. Now is the time for companies to start preparing for a zero carbon future.

Jill Duggan, Director of The Prince of Wales’s Corporate Leaders Group

What the Paris Agreement means for business

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