Privacy policy
1. Scope
All data subjects whose personal data is collected, in line with the requirements of applicable data protection laws including DPL and LGPD, referred to as Data Protection Law (DPL) in this policy.
2. Responsibilities
2.1 The DPL Owner is responsible for ensuring that this notice is made available to data subjects prior to Enco Insights Ltd collecting/processing their personal data.
2.2 All Employees/Staff of Enco Insights Ltd who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.
3. Privacy notice
3.1 Who are we?
We are an expert network solely focused on the global energy and commodities markets. We are part of the wider HC Group, which is a global recruitment firm identifying and recruiting business-critical talent for organisations involved in the energy, agriculture and metal supply chains.
Our DPL Owner and data protection representatives can be contacted directly here:
DPO Team
segurancaprivacidade@hcgroup.global
The personal data we would like to collect on you is:
Personal data type: Source
Name: Publicly available profiles, directly given
Address: Publicly available profiles, directly given
Contact details: Publicly available profiles, directly given
Qualifications: Publicly available profiles, directly given
Career history: Publicly available profiles, directly given
References: Publicly available profiles, directly given
The personal data we collect will be used for the following purposes:
Placement and recruiting
Affinity assessment for suitable placements
Our legal basis for processing personal data:
Contractual obligations
Processing on basis of data being manifestly made publicly available
Consent based processing
Any legitimate interests pursued by us, or third parties we use, are as follows:
Government mandated release of information
Interests perused by public authorities
Enco Insights Ltd does not process any special categories of data specified under the DPL which includes religion, health and trade union membership amongst others specified.
3.2 Consent
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.
Consent is required for Enco Insights Ltd to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
You may withdraw consent at any time by contacting the organisation DPL owner and submitting a subject access rights request form.
3.3 Disclosure
Enco Insights Ltd will not pass on your personal data to third parties without obtaining your consent or doing so under legitimate interests under legislation.
3.4 Retention period
Enco Insights Ltd will process personal data for an indefinite period as needed to conduct placements. Where it is clear that personal data is no longer needed as there is no longer potential to place that data will be deleted under the retention of data policy.
3.5 Your rights as a data subject
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.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances, you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
Right to judicial review: in the event that Enco Insights Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.
3.6 Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Enco Insights Ltd (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Enco Insights Ltd’s data protection representatives DPL Owner.
Data subject access requests are to be sent to the DPL owner.
The details for each of these contacts are:
Supervisory authority contact details
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
+44 303 123 1113
DPL Owner contact details
DPO Team
segurancaprivacidade@hcgroup.global
Document Owner and Approval
The DPL Owner is the owner of this document and is responsible for ensuring that this policy document is reviewed in line with the review requirements stated above.
A current version of this document is available to all members of staff in the company documentation.
This policy was approved by the Board of Directors and is issued on a version-controlled basis under the signature of the Chief Operating Officer.
Change History Record
Created: 27 September 2023