Privacy Notice - Shareholders

IGas Energy plc (the “Company”) processes information provided by you, or on your behalf, which relates to you as a past or present individual shareholder (and therefore data subject under the current data protection laws, the General Data Protection Regulations (GDPR)), and includes information that you or your agents may provide on application forms, in letters, via electronic messages or over the telephone. For the purposes of GDPR, the Company is a ‘data controller’ and determines how and why your personal data will be processed.

Personal data

The information processed by the Company may also include personal data, meaning any information from which a person can be identified. Personal data does not include data where the identity has been removed (anonymous data). There are ‘special categories’ of personal data which require a higher level of protection; the GDPR calls this category of data ‘special data’. We will not collect or process your special data without your consent. The types of personal data most commonly processed by the Company include: your name and contact details (telephone, e-mail, fax), your home address, date of birth, gender, nationality, national ID, tax number, bank details (bank name, sort-code and account number), the votes you cast and the Reference Number attributed to you by the Company, and power of attorney details.

Using your personal data

We will only use your personal information when the law allows us to do so. Most commonly we will use your personal information in the following circumstances:

• Where we need to perform the contract we have entered into with you (as indicated below by *).
• Where we need to comply with a legal obligation (as indicated below by **).
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (as indicated below by ***).

The situations in which we will use your personal data are listed below:

• compile and update our shareholder records to keep them up to date (** and ***);
• fulfil our obligations under our articles of association (* and **);
• to investigate or prevent fraud or other crimes (** and ***);
• process the shareholder rights you exercise (* and **);
• contact you with shareholder information and related communications (*, ** and ***);
• carry out research and statistical analysis regarding our shareholder register (***);
• disclosing copies of register of members or to inspect reports on information about shareholders’ interests in shares made under a valid statutory request (and to the extent necessary to fulfil the same, for example, in line with best practice we may not provide registered shareholders home addresses as these would not relate to the inspection request)(**);
• provide services of benefit to shareholders such as routine dealing with probate, powers of attorney, tracing exercises for shareholders or share dealing services (***).

We only process data to the extent necessary for the above including collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

To whom we provide your personal data

We may transfer or disclose your personal data to the following recipients or categories of recipients:

• other members of the IGas Group;
• Computershare Investor Services PLC, as the Company’s Registrar, and which assists in the Company’s provision of registry services, depositary interest services, corporate sponsored nominee services and other associated shareholder services. Computershare may also sub-process to the following for the following purposes:
  • to other members of the Computershare Group, in respect of any of the processing carried out on behalf of the IGas Group;
  • to stockbrokers and market makers, in respect of personal data in the execution of trades where  instructed by the Company;
  • to appointed tax agents, in respect of personal data in the calculation of tax liabilities where instructed by the Company;
  • to custodians, in respect of personal data in the provision of services supporting the safe custody of assets;
  • to outsourced back-office service providers, in respect of the personal data in the provision of such back-office services such as IT support and electronic and postal mailing;
  • to banks and other regulated financial services providers, in respect of personal data in the performance of financial services required for the effective delivery of the shareholder services provided to the Company;
  • to global payment service providers, in respect of personal data in the making of global payments; and
  • to technology service providers used in the administration (including voting arrangements) of the Company’s general meetings (annual or otherwise) or other statutory meetings, to facilitate shareholder voting at such meetings;
• its brokers, including Investec Bank plc, which assist the Company with research and statistical analysis in relation to its shareholder register and composition;
• any third party at your request or with your consent;
• our suppliers, service providers, including information technology providers, professional advisers including our brokers and Nomad, legal advisors, agents and auditors;
• local or foreign regulators, government authorities, law enforcement authorities, courts, tribunals and arbitrators or other judicial committees;
• if the law requires or permits disclosure, or there is a duty to the public to reveal it;
• the FCA, the London Stock Exchange or any other relevant regulatory authority or exchange in the UK or overseas;
• any individual or company to whom we propose to transfer our obligations and rights in relation to the administration of the Company share register; and
• any other person that requires access to or receipt of your personal data in connection with or as a result of any agreement we may have with or concerning you, or our arrangements with you.

The Company also engages Orient Capital Ltd to assist with compiling statutory reports on shareholders’ interests in shares.  Accordingly, Orient Capital Ltd may process your personal data on the Company’s behalf.

The Company or its agents or its suppliers might transfer your personal data to places outside the European Economic Area (EEA) and store it there, where the Company’s or its suppliers’ personnel might process it for the purposes outlined above. If your personal data is transferred outside the EEA the Company will ensure that it is protected in accordance with the legal requirements of the GDPR. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Consent

Please note that we are permitted to process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. We will not process your special data without your consent. In limited circumstances, we may separately approach you for your written consent to allow us to process such special data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data security

We have put in place appropriate security measures to assist in the prevention of your personal information being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Retention or personal data

We (and our agents and suppliers) will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. The 

following is a table containing the ordinary retention periods for the majority of shareholder records we or our agents on our behalf process:

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Your rights

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you (see further below).
• Right of rectification – you have a right to request that we correct data that we hold about you that is inaccurate or incomplete.
• Right to request erasure – you can ask for the data we hold about you to be erased from our records where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Right to restriction of processing – you have the right to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Right of portability – you have the right to have the data we hold about you transferred to another party.
• Right to object – you have the right to object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Right to object to automated processing, including profiling – you also have the right not to be subject to a decision evaluating your personal aspects that is based solely on automated processing, including profiling, and which produces legal effects concerning or significantly affecting you.
• Right to judicial review: in the event that we refuse your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.

• All of the above requests will be forwarded on should there be a third party involved (as outlined in this notice) in the processing of your personal data.

   

  If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer in writing.

   

  You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

   

  We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

   

  Complaints

  You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) https://ico.org.uk/concerns/handling/, the UK supervisory authority for data protection issues. However, please consider contacting our Data Protection Officer via [email protected] in the first instance.

   

  Data Protection Officer

  We have appointed a Data Protection Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, you can contact the Data Protection Officer here: [email protected]

   

  Updating this notice

  We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.