AdGreen ["We" "Us" "Our"] is committed to being transparent about how it collects and uses the personal data including, in particular, the data of our employees, volunteers, people we engage with on a freelance basis, and actual and potential users of our tools and resources, attendees of events and subscribers of our mailing list ["Individuals" "They" "Them" "Their"]. This policy applies to the personal data of all such persons.

We process personal data in accordance with the following data protection principles:

->  We process personal data lawfully, fairly and in a transparent manner.

->  We collect personal data only for specified, explicit and legitimate purposes.

->  We process personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.

->  We keep accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.

->  We keep personal data only for the period necessary for processing.

->  We adopt appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.

We tell individuals the reasons for processing their personal data, how we use such data and the legal basis for processing in our privacy notices. We will not process personal data of individuals for other reasons. Where we rely on our legitimate interests as the basis for processing data, we will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals.

We hold personal data under the following permitted reasons provided by the GDPR- so one of these reasons will apply to your data:

->  Consent: the individual has given clear consent for you to process their personal data for a specific purpose.

->  Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.

->  Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).

->  Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.

As a data subject, individuals have a number of rights in relation to their personal data.

Subject Access Requests
Individuals have the right to make a subject access request. If an individual makes a subject access request, we will tell them:

->  whether or not their data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;

->  to whom their data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;

->  for how long their personal data is stored (or how that period is decided);

->  their rights to rectification or erasure of data, or to restrict or object to processing;

->  their right to complain to the Information Commissioner's Office (ICO) if they think we have failed to comply with their data protection rights; and

->  whether or not we carry out automated decision-making and the logic involved in any such decision-making.

We will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if they have made a request electronically, unless they agree otherwise.

To make a subject access request, the individual should send the request to or use our contact form. In some cases, we may need to ask for proof of identification before the request can be processed. We will inform the individual if they need to verify their identity and the documents we require.

We will normally respond to a request within a period of one month from the date it is received. In some cases, such as where we process large amounts of the individual's data, it may respond within three months of the date the request is received. We will write to the individual within one month of receiving the original request to tell them if this is the case.

If a subject access request is manifestly unfounded or excessive, we are not obliged to comply with it. Alternatively, we can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which we have already responded. If an individual submits a request that is unfounded or excessive, we will notify them that this is the case and whether or not we will respond to it.

Other Rights
Individuals have a number of other rights in relation to their personal data. They can require AdGreen to:

->  rectify inaccurate data;

->  stop processing or erase data that is no longer necessary for the purposes of processing;

->  stop processing or erase data if the individual's interests override AdGreen's legitimate grounds for processing data (where we rely on its legitimate interests as a reason for processing data);

->  stop processing or erase data if processing is unlawful; and

->  stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual's interests override AdGreen's legitimate grounds for processing data.

To ask us to take any of these steps, the individual should send the request to

We take the security of personal data seriously. We have internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties.

If we discover that there has been a breach of personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner's Office (ICO) within 72 hours of discovery. We will record all data breaches regardless of their effect.

Individuals are responsible for helping us keep their personal data up to date. Individuals should let us know if data provided to us changes, for example if an individual moves house or changes his/her bank details.

Employees and freelance contractors may have access to the personal data of other individuals in the course of their employment, contract, volunteer period, internship or apprenticeship. Where this is the case, we rely on employees and freelance contractors to help meet our data protection obligations as per the above.

Employees and freelance contractors who have access to personal data are required:

->  to access only data that they have authority to access and only for authorised purposes;

->  not to disclose data except to individuals (whether inside or outside AdGreen) who have appropriate authorisation;

->  to keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);

->  not to remove personal data, or devices containing or that can be used to access personal data, from Adgreen's premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device;

->  not to store personal data on local drives or on personal devices that are used for work purposes; and

->  to report data breaches of which they become aware to Project Director Jo Coombes immediately.

Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under AdGreen's disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.