Note: Following the implementation of SEC MP111 on 22nd January 2021, all SMDA services are being delivered through the Smart Energy Code Company Ltd (SECCo) and as such, this privacy notice applies to SMDA and SECCo services, including the SMDA and SECCo websites. For more information about what this means for you, please contact us at: SMDASO@gemserv.com or email@example.com
For the purposes of relevant legislation, Gemserv Ltd (“Gemserv”) and SECCo Ltd (“SECCo”) are data controllers in their own rights (i.e. responsible for and control the processing of your personal information).
This website is not intended for children, and we do not knowingly collect data relating to children. This website is also not intended to cover personal data processed for recruitment or employment purposes.
Who are we?
Full company details of SECCo are as follows:
Name: Smart Energy Code Company Limited,
Company number 08430267
Registered office address: 8 Fenchurch Place, London, EC3M 4AJ
Full company details of Gemserv are as follows:
Name: Gemserv Limited,
Company number 04419878
Registered office address: 8 Fenchurch Place, London, EC3M 4AJ
Personal information collected
We typically collect personal information when you use this website or register for our services, including when you:
|Purpose of Processing||Data Types||Lawful Basis|
|Accessions to the SEC code||Name
|To send documentation to, and ensure quoracy of meetings with, members||Name
|To allow website users to sign up to our newsletter||Name
|To carry our assessments under the SEC||Name
|To register to Codeworks to view digitised SEC||Name
|To respond to communications, including enquiries and complaints, received through our website contact form||Name
Contents of message
|Legitimate interest to respond to your communications|
|To allow current SMDA members who are not SEC Parties to continue to access SMDA Material||Name
Purchase Order information (if required)
|SEC Parties requesting access to SMDA material||Name
|When you submit online forms, including the Accession application form, Smart Energy Code (SEC) Party contact form, Change of Party Details form, Security Assessment Application form, etc.
|To register for a user account||Name
|Respond to questionnaires and surveys||Name
|To process invoices||Name
Bank account details
|To process your application for device testing||Name
|To receive device Assurance confirmation and device testing reviews including (final test report, Statement of Assurance and Rectification plan)||Name
|To be listed as a SMDA Sub-Committee Member on the website||Name
We also collect personal data through Cookies. Please see the Cookies section below for more information, as well as our Cookie Banner.
How we use your personal information
We will use your personal information for the purposes described to you at the time you provided your data to us. These purposes include:
- Responding to and keeping a record of your enquiries;
- To enable us to record the details of parties wishing to accede to the SEC;
- To provide services required under the SEC, including organising events and meetings related to SEC activities;
- Maintaining relevant databases in relation to the SEC Party contact details;
- Sending Newsletters or information about our work and services;
- Any other processing for which you have given your consent;
- Any processing required by any law or regulation and/or requested by regulatory bodies or law enforcement organisations.
Disclosure of your information
Your information may be disclosed to any or all of the following:
- On our website, to other SEC Parties;
- Our employees, contractors or other personnel;
- Third-party service providers who may store your personal data or use it in the course of services we request, including our SMDA testing houses;
- The Data Communications Company (DCC) as needed for services that the DCC will provide to you;
- The energy regulator, Ofgem, if needed for regulatory purposes;
- As necessary in order to investigate, respond to, and address any issues or complaint raised by you;
- As otherwise stated when your information was provided or collected; and/or
- As otherwise required to enforce the SEC or comply with legal or regulatory obligations or requests, such as with governmental departments such as BEIS and Ofgem;
- Auditors, contractors or other professional advisers of SECCo; and
- Shareholders, officers or directors of SECCo.
We require all third parties to respect the security of your personal data in accordance with legal requirements under the GDPR. Additionally, we do not allow third parties to use your data for purposes other than those we have specified.
Marketing and Opting-Out
We will only contact you by email about our work and its progress if you have asked us to do so. If you have changed your mind and would prefer us not to contact you, then you can opt out at any time. See further “Your Rights in relation to your information” below.
Cookies are small files saved to your computer’s hard drive that track, save and store information about your interactions and usage of our website. Cookies allow us to store your preferences to correctly present content, options or functions throughout our website. They also enable us to see information like how many people use our website and what pages they tend to visit.
Cookies have different durations. Temporary cookies, such as those only valid for your browsing session, expire when you close your browser. Permanent cookies, however, will remain on your computer for a longer period until you delete them. We may also use the information gathered from Cookies to compile reports to improve the functionality and user experience of our website.
Cookies can be set by different actors. Typically, this occurs in two cases:
- First-party cookies: These are cookies set by this website for our visitors.
Cookies have different purposes. We typically use the following cookies:
- Functional Cookies: Cookies that are strictly necessary to enable you to move around our websites or to provide certain basic features. This includes basic features such as playing videos, and storing information already entered (e.g. username, language, location). These include:
- WordPress (WordPress_sec, wordpress_logged_in, PHPSESSID, euCookie, wpfuuid): These cookies are required by our website software and store no personal information. Duration: Session only;
- Complianz cookies (cmplz_all, cmplz_choice, cmplz_id, cmplz_stats, cmplz_consent_status): These record which cookies you consent to. Duration: 1 year (consent is stored for 62 years).
- Statistics: Cookies that monitor the popularity of sections of our website. These include:
- Google Analytics (_ga, _gat, _gid, analytics.js): Used to understand how users navigate through our website. This service is provided by Google Inc. Duration: Session cookies; others maximum 2 years.
- Marketing: These cookies may track users and display advertisements relevant to them but can also include some otherwise functional cookies. The websites use Captcha to ensure that registration and queries come from real people. This is classified as a Marketing cookie, and in order to register as a User or to use the Simple Contact Form Users must consent to Marketing cookies. The websites make no other use of Marketing cookies.
Your rights in relation to cookies.
We generally only place cookies with your consent when you first visit this website, apart from for Functional cookies, which are mandatory for this website to operate. If you want to avoid this website placing Statistics and Marketing Cookies on your browser, you can choose to deselect all cookies besides the Functional Cookies on visiting this website. You may also set your browser settings to attempt to reject all cookies or manually delete the Cookies and may still use this website.
We will use technical and organisational measures to safeguard your personal information from being accidentally lost, used or accessed in an unauthorised manner, altered or disclosed. In particular, we use strict access and authentication controls on our databases, and, where possible, use encryption in transit when sharing files via email.
Whilst we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the Internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any personal data or other information that is transferred from you or to you via the Internet.
Additionally, we have put into place procedures to deal with any suspected data breach and will notify you of such when we are legally required to do so.
Updating your details
If any of the information that you have provided to us changes, please let us know the correct details by sending an email to SMDASO@gemserv.com where we have the facility to log in to the website and update any user details.
Storage of your personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we have collected it for (as outlined above), or as long as we are required to maintain it by law.
|Purpose of Processing||Retention Period|
|Accessions to the SEC code||Duration of membership of SEC, otherwise up to one year|
|To send documentation to, and ensure quoracy of meetings with, members||Duration of membership of SEC/Committee/Board (whichever is longer)|
|To allow website users to sign up to our newsletter||Duration of membership|
|To carry out assessments under the SEC||Duration of membership of the SEC|
|To register to Codeworks to view digitised SEC||5 years|
|To respond to communications, including enquiries and complaints, received through our website contact form||7 years|
|When current SMDA Members who are not SEC Parties apply to continue accessing SMDA material||Duration of membership of the SMDA|
|SEC Parties requesting access to SMDA materials||Duration of membership of the SMDA/SEC|
|When you submit online forms, including the Accession application form, Smart Energy Code (SEC) Party contact form, Change of Party Details form, Security Assessment Application form, etc.;||Duration of membership of SMDA/SEC|
|To register for a user account||For the duration of your membership of SMDA/SEC|
|To respond to questionnaires and surveys||For as long as you consent to this processing, or 6 years|
|To process invoices||7 years|
|To process device assurance||For the duration of membership of SMDA|
Use of your personal information submitted to other websites
SECCo/Gemserv cannot be responsible for the privacy policies and practices of other non-SECCo websites, even if you accessed the third-party website using links from our website, or you linked to our website from a third-party website.
We may need to transfer your personal information to countries located outside of the European Economic Area for the purposes of providing our services to you. Rest assured that we will always ensure any such transfer is subject to appropriate security measures to safeguard your personal information.
Your Rights in relation to your information
Under certain circumstances, you may have certain rights under data protection laws in relation to your personal data which are as follows:
Request access to your personal data – This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data – This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data – This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
Object to processing of your personal data.
Request restriction of processing your personal data – This enables you to ask us to suspend the processing of your personal data in specific circumstances.
Request transfer of your personal data to you or to a third party – We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Right to withdraw consent, where consent has been given to the processing.
You can write to us to request access to your personal information and other rights at:
Smart Energy Code Company Limited
8 Fenchurch Place
We will require proof of your identity before responding to any request from you.
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) on any data protection issues.
These terms shall be governed by and construed in accordance with the laws of England and you and we agree to submit to the exclusive jurisdiction of the courts of England and Wales.