Privacy Policy

H2O Logistics Ltd (“H2O”) takes the protection and privacy of personal data very seriously. This Privacy Notice explains to prospective Consultants, Suppliers and Service Providers (herein “Service Providers”) how we process personal data before, during and after being a Service Provider to H2O.

Our address for all queries related to Data Protection:

H2O Logistics Limited,9 Bank Road, Kingswood BS15 8LS

The team responsible for Data Protection issues can be emailed at compliance@h2ologistics.co.uk.

What personal data do we collect about you, how do we use that personal data, and what is our legal basis?

In order to ensure your trust and to comply with the law, we need a legal basis in order to process your personal data. Any of your personal data we process is because:

We have your express consent to do so;
It is necessary for the performance of the Contract for Services we have in place with you (or you wish to consider a contractual relationship with us);
We have a legal obligation to do so; or
It is a legitimate business activity that doesn’t unduly compromise your data protection rights.

On occasion, we may seek your consent to process your personal data for anything we may consider to be beneficial or advantageous for you, but you are free to refuse.

When you are a Service Provider, or wish to become a Service Provider of H2O, we collect and process your personal data:

in order to fulfil our Contract for Services with you;
to fulfil our legal obligations under UK legislation;
where the activity is a legitimate one for a business reason; and
with your express consent for anything else.

RELATIONSHIP STAGES

Pre-engagement Stage:

Before you have become a Service Provider and we are discussing and evaluating our relationship we will process your data to communicate with you, assess your suitability for being a Service Provider and check your legal documents necessary for undertaking services.

In order to communicate with you and perform basic due diligence we may process personal data such as:

your name;
email address;
driving license number;

home or registered address;
telephone number(s); and
date of birth.

We process this information with your consent, and also with a legitimate interest where you have requested information from us, or made enquiries into engaging with us.

To ensure compliance with our (and sometimes our client’s) policies on safe working we will check the details of your driving license against the data held by the relevant authority.

To ensure safe working practices and prevent road traffic incidents, Service Providers who will be driving on public roads must be subject to drug and alcohol screening. By ticking the relevant box on our Supplier Registration form you consent to be subject to drug and alcohol testing facilitated by our partner, Eurofins NFC UK Limited.

In order to comply with our legal obligations under UK immigration and Home Office legislation we need to confirm your identity and right to work in the UK. To prevent fraud and comply with UK immigration law we cannot have a Contract for Services with you unless we can verify your identity, nationality, home address and right to work in the UK. We may process any combination of the following documents to perform the required checks:

A passport showing the holder, or a person named in the passport as the child of the holder, is a British citizen or a citizen of the UK and Colonies having the right of abode in the UK;
A passport or national identity card showing the holder, or a person named in the passport as the child of the holder, is a national of a European Economic Area country or Switzerland;
A Registration Certificate or Document Certifying Permanent Residence issued by the Home Office to a national of a European Economic Area country or Switzerland;
A Permanent Residence Card issued by the Home Office to the family member of a national a European Economic Area country or Switzerland;
A current Biometric Immigration Document (Biometric Residence Permit) issued by the Home Office to the holder indicating that the person named is allowed to stay indefinitely in the UK, or has no time limit on their stay in the UK;
A current passport endorsed to show that the holder is exempt from immigration control, is allowed to stay indefinitely in the UK, has the right of abode in the UK, or has no time limit on their stay in the UK;
A current Immigration Status Document issued by the Home Office to the holder with an endorsement indicating that the named person is allowed to stay indefinitely in the UK or has no time limit on their stay in the UK;
National Insurance number and their name issued by a Government agency or a previous employer.
A full birth or adoption certificate issued in the UK which includes the name(s) of at least one of the holder’s parents or adoptive parents;
A birth or adoption certificate issued in the Channel Islands, the Isle of Man or Ireland;
A certificate of registration or naturalisation as a British citizen;
A current Residence Card (including an Accession Residence Card or a Derivative Residence Card) issued by the Home Office to a non-European Economic Area national who is a family member of a national of a European Economic Area country or Switzerland or who has a derivative right of residence;
A current Immigration Status Document containing a photograph issued by the Home Office to the holder with a valid endorsement indicating that the named person may stay in the UK, and is allowed to do the type of work in question;
A Certificate of Application issued by the Home Office under regulation 17(3) or 18A (2) of the Immigration (European Economic Area) Regulations 2006, to a family member of a national of a European Economic Area country or Switzerland stating that the holder is permitted to take employment which is less than 6 months old;
An Application Registration Card issued by the Home Office stating that the holder is permitted to take the employment in question; and/or
A Positive Verification Notice issued by the Home Office Employer Checking Service to the employer or prospective employer, which indicates that the named person may stay in the UK and is permitted to do the work in question.

Engagement Stage:

When you have signed a Contract for Services, supplied all relevant due diligence and documentation and are a Service Provider to H2O we will process your personal data for the purposes of communicating, agreeing assignments, routes, organising available work, providing health and safety briefings and checks, monitoring performance against agreed deliverables, processing payments and debits.

We process the following data whilst you’re providing services to H2O. Our legal basis to do so is because we have a contract with you or you would like to enter into a contract with us. We cannot provide you with a contract without this information.

your name;
home, or registered business address;
home phone number;
mobile phone number;
National Insurance number;
Unique Tax Reference (UTR) Number;
company registration number;
email address;
Nationality;
VAT registration number;
invoice data;
details of receiving a health and safety briefing; and
IP address (DocuSign)
V5 Document (to obtain the relevant VIN details).

Once you become a Service Provider with H2O we will assign you a unique identifier number as this is a legitimate activity in order to avoid any system errors or mistakes in making payments.

If you have a beneficiary or next of kin, we will collect and process their name, address, phone and DOB as this is a legitimate activity for us. Next of kin will only be contacted in emergency circumstances if it is in your vital interest that we do so.

If you have sourced a vehicle through H2O in order to provide services to us, the vehicle will be fitted with a tracking device that records vehicle location, speed, start and stop times. This data is processed by us to monitor operational efficiency, provide valuable business intelligence related to our operations and costs, and to protect our assets. Our legal basis for processing this data is by virtue of the contract and/or rental agreement we may have in place with you.

Post Termination Stage:

How long do we hold your personal data?

We will hold your personal data that was collected over the two relationship stages above for five years from when your contractual relationship with H2O is terminated, after which it will be destroyed. This is a legal obligation.

We will hold your name, email and phone number to send you marketing information as long as you would like us to do so. If you withdraw your consent, we will hold this data for five years in a suppression list so that we don’t market to you against your wishes.

If you have started the process to become a Service Provider and then changed your mind, or if you are not accepted as a Service Provider, we will hold your data for two years, after which it will be destroyed. We hold it for two years in case it is required for by law enforcement agencies, the Home Office or for legal reasons.

Do we use any automated decision making?

We do not use any automated decision making in our data processes.

Who do we share your personal data with?

Depending on your personal circumstances we may share your personal data with the following recipients:

Amazon UK Ltd as a key client of H2O for the purposes of confidential data, security, safety, performance and quality audits;
Blackbeard Consulting Ltd in the capacity of a professional adviser and business consultancy to H20;
Disclosure Scotland for the purposes of accessing information from the Disclosure and Barring Service related to unspent criminal convictions only;
Eurofins NFC UK Limited for the purposes of drug and alcohol screening;
Her Majesty’s Revenue & Customs for the purpose of compliance with relevant personal and business taxes;
Smart Tax and Accountancy LTD, who can provide personal Tax and VAT management services for H2O Service providers and its sub-contractors, whom we intend to share your data with, including emails and phone numbers.
K&O Contracting LTD in the capacity of a professional adviser and business consultancy to H20;
High Court Enforcement Officers Association for the purposes of enforcing High Court writs to seize and sell assets to settle unpaid judgements;
Home Office for the purpose of any right to work checks or queries;
Organisations that verify publicly available, or private documents and information (e.g. DVLA, Home Office);
Information Commissioners Office in the event of a request for information or breach;
Insurance companies for the purposes of assessing risk;
Legal advisors and business consultants, as required from time to time, for the purposes of providing their services to H2O Logistics Limited;
NatWest Bank Plc for the purpose of making payments; and
Remote Asset Management Ltd for the purposes of providing vehicle tracking systems and telematics data;
Third party social media platforms, Facebook Inc and WhatsApp Inc for the purposes of communication;
Our various software providers, technology applications and database providers (DocuSign UK Ltd, Dropbox Inc, Google Plc and Microsoft that are necessary for recording, securing and updating your personal details and administering services internally as well as external communications);
Where relevant, we have contracts and/or data sharing agreements in place with the above parties to ensure that all your personal data is treated with the same level of privacy, confidentiality and protection as it would be by H2O.

Do we transfer your personal data outside of the EU or EEA?

Your data is kept in the EU or EEA, with the exception of Dropbox Inc, certain Microsoft Corporation applications and services, Google LLC, Facebook Inc and WhatsApp Inc who have computer servers and electronic data storage facilities in the United States (“US”).

These organisations comply with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use and retention of personal data transferred from the European Union, the European Economic Area, the United Kingdom and Switzerland to the United States.

These organisations have certified to the Department of Commerce that they adhere to the Privacy Shield Principles with respect to such data. More information about Privacy Shield can be found online at:

https://www.privacyshield.gov.

Your Rights

By law, you have certain rights in respect of our processing of your personal data.

You have the right:

to have access to your personal data and information about our processing of it. You also have the right to request a copy of your personal data (but we will need to remove any confidential, irrelevant or personal data relating to others people);
To rectify incorrect personal data that we are processing;
To request that we erase your personal data if:
- we no longer need it;
- if we are processing your personal data by consent and you withdraw that consent;
- if we no longer have a legitimate ground to process your personal data; or
- we are processing your personal data unlawfully;
To object to our processing if it is by legitimate interest;
To restrict our processing if it was by legitimate interest; and
To request that your personal data be transferred from us to another company if we were processing your data under a contract or with your consent.

If you wish to exercise any of these rights, please email our Data Protection team on compliance@h2ologistics.co.uk, or write us at:

H2O Logistics Limited,
9 Bank Road,
Kingswood,
Bristol, BS15 8LS

You also have the right to lodge a complaint about our processing with the UK’s Information Commissioner’s Office (“ICO”), however the ICO recommends that we seek to resolve any issues relating to Data Protection between ourselves prior to them being notified.

Anti Bribery & Corruption

1. ABOUT THIS POLICY

1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
1.2 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any Service Provider or supplier who breaches this policy may have their contract terminated with immediate effect.
1.3 This policy does not form part of any employee’s or worker’s contract of employment or engagement and we may amend it at any time.

2. WHO MUST COMPLY WITH THIS POLICY?

2.1 This policy applies to all persons working for, or providing services to us, or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

3. WHAT IS BRIBERY?

3.1 ‘Bribe’ means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.
3.2 ‘Bribery’ includes offering, promising, giving, accepting, or seeking a bribe.
3.3 All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with a representative of the Management Team either in person or by email to compliance@h2ologistics.co.uk.
3.4 Specifically, you must not:
a)   give or offer any payment, gift, hospitality, or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
b)   accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else;
c)   give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure;
3.5 You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

4. GIFTS AND HOSPITALITY

4.1 This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.
4.2 A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).
4.3 Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in our name, not your name.
4.4 Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers, and business partners.

5. RECORD-KEEPING

5.1 You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.
5.2 All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.

6. HOW TO RAISE A CONCERN

6.1 If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify a representative of the Management Team either in person or by email to compliance@h2ologistics.co.uk.