1. Introduction
White Cross Offshore Wind Limited (“White Cross”, “we”, “our” or “us”) is committed to protecting and respecting your privacy.
This Privacy Notice explains how we collect, use, store, share and otherwise process personal information about individuals who interact with us. This includes information collected through our website, meetings, consultation events, surveys, questionnaires, telephone calls, emails, letters, forms and other communications.
This Privacy Notice applies to all personal information processed by White Cross in connection with the development, consenting, construction, operation and maintenance of the White Cross Offshore Wind project and our business activities.
2. Who we are?
White Cross Offshore Wind Limited is the data controller responsible for the personal information described in this Privacy Notice.
Contact details
White Cross Offshore Wind Limited
c/o Flotation Energy Limited Hobart House, 80 Hanover Street, Edinburgh, United Kingdom, EH2 1EL.
Email: [email protected]
If you have any questions about this Privacy Notice or how we process your personal information, please contact us using the details above.
3. Personal information we collect
Depending on how you interact with us, we may collect, use and store the following categories of personal information:
Identity information
- Title
- Name
- Job title and employer details
Contact information
- Postal address
- Email address
- Telephone number
- Mobile number
Correspondence information
- Details contained in emails, letters and other communications
- Records of enquiries, requests, complaints and feedback
- Notes of meetings and discussions
- Consultation responses, representations, comments and observations submitted as part of stakeholder engagement activities
- Attendance records relating to consultation events, exhibitions, meetings and workshops
Survey and consultation information
- Responses to questionnaires, surveys and consultation exercises
- Opinions, comments and feedback voluntarily provided to us
Technical information
When you use our website, we may collect technical information, including:
- IP address
- Browser type and version
- Device information
- Website usage information
- Cookie and analytics data
Marketing and communications information
- Your communication preferences
- Records of marketing consents where applicable
4. How we collect personal information
Information obtained directly from you
We may collect personal information directly from you when you:
- Visit and use our website
- Complete online forms
- Complete paper forms
- Participate in surveys or questionnaires
- Attend meetings, consultations, exhibitions, workshops or events
- Correspond with us by email or post
- Speak to us in person or by telephone
- Submit enquiries, requests, comments or complaints
- Share documents or copies of documents
Information obtained from third parties
We may obtain personal information from third parties where this is necessary for project development, stakeholder engagement, business administration or regulatory compliance.
Sources may include:
- Landowners and their professional representatives;
- Planning, environmental, technical and communications consultants;
- Business and project partners;
- Contractors and suppliers;
- Regulatory authorities and public bodies;
- Statutory consultees;
- Public registers and publicly available sources; and
- Other organisations involved in the planning, development, construction or operation of the project.
The categories of personal information obtained from these sources may include names, job titles, contact details, business affiliations, correspondence records, stakeholder engagement records and consultation-related information.
5. How we use your personal data
We use information held about you in the following ways:
- Responding to enquiries and requests
- Managing stakeholder and community engagement activities
- Conducting surveys, consultations and feedback exercises
- Communicating project information and updates
- Managing relationships with landowners, suppliers, contractors, consultants and other stakeholders
- Managing complaints and disputes
- Internal record keeping
- Operating, maintaining and improving our website
- Maintaining security and protecting our business
- Complying with legal and regulatory obligations
- Establishing, exercising or defending legal claims
6. Lawful bases for processing
Under UK data protection law, we must have a lawful basis for processing your personal information.
All data collected by us will be used for the lawful purposes of providing you with our services relating to the project including:
- to comply with our legal obligations;
- for our legitimate interests; and
- with your consent, to maintain and develop our relationship with you. You may withdraw your consent at any time by emailing [email protected]
Our Legitimate Interests
Where we process personal information on the basis of legitimate interests, those interests include:
- Developing, consenting, financing, constructing, operating and maintaining the White Cross Offshore Wind project;
- Engaging with local communities, statutory consultees, stakeholders and interested parties;
- Managing our business operations and project activities;
- Maintaining accurate records;
- Protecting our legal rights and interests;
- Ensuring the security of our people, systems and information; and
- Improving our services, communications and website.
Where we rely on legitimate interests, we balance those interests against your rights and freedoms.
7. Who we share personal information with
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 for a legitimate purpose.
We may share information with selected third-parties including:
- Business and/or project partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- Professional advisers, including lawyers, accountants and consultants
- IT service providers and website hosting providers
- Providers of software, cloud computing, data management and artificial intelligence services that support our business operations and project activities
- Survey, engagement and communications service providers
- Planning authorities, statutory consultees, environmental bodies, marine regulators and other public authorities involved in the planning, permitting, consenting, construction or operation of the project
- Courts, law enforcement agencies, regulators and government bodies where required by law or to protect our legal rights
We require all third parties to respect the security of personal information and process it in accordance with applicable data protection laws.
We do not sell personal information.
8. Use of Artificial Intelligence
We may use artificial intelligence (“AI”) and machine learning-enabled technologies to support our business operations and project activities.
These technologies may be used to assist with:
- Reviewing, organising and analysing correspondence, enquiries and stakeholder communications;
- Summarising consultation responses, feedback and engagement records;
- Drafting or reviewing project documents, reports and communications;
- Searching, categorising and managing information held within our systems; and
- Improving administrative efficiency and information management processes.
Where AI technologies process personal information, we will ensure that appropriate contractual, technical and organisational safeguards are in place to protect that information and comply with applicable data protection laws.
AI tools are used to support our personnel and service providers in carrying out their functions. Important decisions affecting individuals are not made solely by automated means. Any significant decisions involving personal information remain subject to appropriate human review and oversight.
Where AI services are provided by third-party suppliers, we may share personal information with those suppliers only where necessary and subject to appropriate data protection obligations.
We will only process personal information using AI technologies where we have a lawful basis to do so under applicable data protection laws.
9. International transfers
We may transfer your personal data to organisations located outside the United Kingdom. Where we do so, we will ensure that an appropriate level of protection is applied to your personal data and that any transfer complies with applicable data protection laws.
This may include transferring personal data to:
- Service providers, project partners, advisers or group located outside the UK; and
- Countries that have been recognised by the UK Government as providing an adequate level of protection for personal data.
Where personal data is transferred to a country that has not been granted an adequacy decision, we will implement appropriate safeguards to protect your personal data, such as the use of the UK International Data Transfer Agreement (IDTA), the UK Addendum to the European Commission’s Standard Contractual Clauses, or other lawful transfer mechanisms permitted under UK data protection legislation.
You may request further information about the safeguards we apply to international transfers by contacting us using the details set out in this Privacy Notice.
Some of our technology providers, including cloud hosting, software, artificial intelligence, and IT support providers, may process personal data from locations outside the United Kingdom. Where this occurs, we ensure that appropriate safeguards are in place to protect personal data and to comply with applicable data protection laws
10. How we protect personal information
We have implemented appropriate technical and organisational security measures designed to protect personal information against accidental loss, unauthorised access, use, alteration or disclosure.
Access to personal information is limited to those employees, contractors, advisers and service providers who have a legitimate business need to access it.
11. How long we keep personal information
We retain personal information only for as long as necessary for the purposes for which it was collected and to satisfy legal, regulatory, contractual and operational requirements.
Retention periods may vary depending upon the type of information and the purpose for which it was collected.
In particular:
- General enquiries and routine correspondence are normally retained for up to 7 years after the matter has concluded;
- Supplier, contractor and commercial records are retained in accordance with contractual, financial and statutory requirements;
- Consultation responses, stakeholder engagement records, representations, comments, objections and associated correspondence may be retained for the duration of the project lifecycle and for a period thereafter where required for legal, regulatory, audit, contractual or claims-related purposes;
- Website analytics data is retained in accordance with our website and cookie settings; and
- Information relevant to legal claims or disputes may be retained until the relevant matter has been fully resolved and any limitation periods have expired.
When personal information is no longer required, it will be securely deleted, anonymised or otherwise disposed of in accordance with our records management procedures.
12. Automated decision – making
We do not use personal information for automated decision-making or profiling that produces legal effects or similarly significant effects on individuals.
Although we may use AI and other technologies to assist with analysis, administration and decision-support activities, meaningful human involvement and oversight remain part of our decision-making processes.
13. Your data protection rights
Subject to applicable law, you have the right to:
- Request access to your personal information
- Request correction of inaccurate or incomplete personal information
- Request deletion of your personal information
- Request restriction of processing
- Object to processing carried out on the basis of legitimate interests
- Request transfer of your personal information to another organisation
- Withdraw consent where processing is based on consent
To exercise any of these rights, please contact: [email protected].
Please note that some rights are subject to exemptions and limitations under applicable data protection law. We may ask for information necessary to verify your identity before responding to a request. We will normally respond within one month of receiving a valid request.
14. Complaints
If you have concerns about how we use your personal information, please contact us first so that we can seek to address your concerns.
You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”), the UK’s independent authority responsible for upholding information rights.
Information Commissioner’s Office
Website: www.ico.org.uk
Telephone: 0303 123 1113
15. Cookies
Our website may use cookies and similar technologies to operate effectively, enhance functionality, understand how visitors use the website and improve user experience.
Where required by law, we will seek your consent before placing non-essential cookies on your device.
Further information regarding the cookies used on our website, including how to manage your preferences, is available through our cookie banner published on our website.
16. Changes to this Privacy Notice
We may update this Privacy Notice from time to time.
Any changes will be posted on our website and, where appropriate, notified to you by other means.
We encourage you to review this Privacy Notice periodically to remain informed about how we process personal information.
