Privacy Notice
The protection of your personal data is important to West African Gas Pipeline Company Limited (WAPCo). Please take note of the following information pertaining to the collection and processing of your personal data based on your interactions with us, doing business with us, or whilst contacting us via various channels, including our online platforms.
WAPCo collects, uses and allows access to your personal data in accordance with the laws pertaining to privacy and data protection.
In this Privacy Notice, personal data (“data”) refers to all information that can be used to determine who you are, for example your name, your e-mail address and IP address.
The Company’s website is intended to provide information about WAPCo to potential customers, stakeholders, participants in the oil and gas industry, and the public. Such information about WAPCo may include, without limitation, a description of its activities and services, performance and potential employment opportunities. Job applicants and employees of WAPCo are subject to recruitment and human resources policies and procedures as applicable.
WAPCo is committed to protecting the privacy of individuals and the safety of the information we gather from the users who visit our website and who make use of the on-line facilities. This Privacy Notice covers the treatment of personally identifiable information from users collected by WAPCo, through a website owned and operated by WAPCo, or which may come to be part of the Company’s databases.
This Privacy Notice does not apply to the practices of companies that WAPCo does not own or control, or of persons that WAPCo does not employ or manage, including any third-party content contributors bound by contract and any third-party website to which the WAPCo website might link. Therefore, we recommend that when users are redirected to external sites, they should always check such sites’ respective privacy statements before providing their data or information.
You can visit the WAPCo website without revealing any personal information. However, WAPCo needs certain personal information if you wish to receive our newsletter or use certain WAPCo services. Where required, this information may include your personal contact information and/or your company contact information. WAPCo will use this information to reply to your enquiries, to provide you with requested services and to contact you regarding our services.
Except as specifically noted above, no right or license is granted to you under any copyright, patent, trademark or other intellectual property law to use, copy, reproduce, re-transmit, display or create derivative works from materials, logos and content contained within the WAPCo website.
Please read this Privacy Notice carefully to ensure informed consent. We take your privacy seriously and we will not abuse your trust by disclosing, exporting, or dealing with your personal data in a manner that is contrary to this Privacy Notice or applicable laws.
Responsible Body and Data Protection
WAPCo is the data controller and therefore responsible for collection and processing of your personal data. If you have any questions regarding our data processing activities, your rights or any of the contents of this privacy notice, please contact our Data Protection Supervisor at privacy@wagpco.com
Principles of Data Protection
We are obligated to comply with data protection principles whenever we process your personal data and to inform you about these principles. These principles include:
- We will inform you about the personal data we have about you, and the lawful basis for processing it.
- We will not use your personal data for any other reason that is not compatible with the reason we collected it except we have informed you and relied on an appropriate lawful basis.
- We will only collect personal data about you that is only necessary to meet the required purpose and nothing more.
- We will only use your correct personal data during our processing activities.
- We will not store or keep your personal data in our custody beyond the period necessary to fulfil the purpose for which it is collected.
- We will ensure that your personal data in our custody is protected from unauthorized use, alteration or corruption.
- We will take measures to ensure and demonstrate compliance with these principles.
Our lawful reasons for processing your personal data
At WAPCo, we respect your privacy and value the trust which you place in us. As a result, we will only process your data when we have a valid reason do so. Our lawful reasons for processing your personal data will most commonly include:
- Performance of a contract, which includes processing of personal data required to enter into a contract with you or the organization for whom you work, alternatively for purposes of concluding a contract of employment with you and/or the conducting of pre-contractual measures including but not limited to, background checks and assessing your fitness and suitability for a position applied to at WAPCo;
- Compliance with a legal obligation placed on WAPCo
- Where it is necessary for our legitimate interests (or those of a third party) and your privacy right(s) do not override those interests;
- We may also use your personal data in the following situations, which are likely to be rare:
4.1. where we need to protect your (or someone else’s) interests, or
4.2. where it is necessary in the public interest or for official purposes;
- Operational reasons that include access control, investigations and access permit/card process (screening) when visiting any WAPCo sites or premises.
- We may also process your personal data based on your consent
In regard to specific processing activities, we may provide supplementary privacy notices to facilitate transparency, where the lawful basis, purpose or processing activities may need further elaboration.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason, that is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you (by means of direct communication to you, a revised privacy statement or other appropriate means) and we will explain the legal basis which allows us to do so.
The Personal Data We Hold
Based on the lawful reasons above, we may collect, store, and use the following categories of personal data about you:
- basic information, such as your name, your employer, your title or position and your relationship to a person;
- contact information, such as your physical address, email address and phone number(s);
- financial information, such as bank account details;
- technical information (including your IP address), such as information from your visits to our website or any applications or in relation to materials and communications we send to you electronically;
- information you provide to us for the purposes of attending meetings and events, including access and dietary requirements;
- information you provide to us when answering any surveys you may participate in;
- identification and background information provided by you or collected by us as part of our business acceptance processes;
- identification and background information collected or generated by us as part of our conflict-of-interest management processes (including gift, entertainment and hospitality declaration processes);
- identification, background and employment information, professional experience and affiliations, as part of your application for employment with WAPCo;
- personal data provided to us by or on behalf of our clients or generated by us in the course of providing services which may include special categories of data;
- details of your visits to any of our offices;
- publicly available information in order to facilitate our business dealings with you or your employer;
- and any other information relating to you which you may provide to us.
How We Use Particularly Sensitive Personal Data
“Special Categories” of particularly sensitive personal data are afforded higher levels of protection. Reference to special categories of data includes race or ethnic origin, trade union membership, political persuasion, health or medical information and criminal behaviour.
We will only collect, store and/or use your personal data which falls within this category, if we have a valid justification for processing. As required by applicable law(s), we have appropriate policies and safeguards in place, when processing these categories of information. We may process special categories of personal data under the following justifications:
- with your explicit written consent.
- where we need to carry out our legal obligations or exercise rights in connection with any contract, we may have with you or the organization for whom you work; or
- where it is needed in the public interest.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your (or someone else’s) interests and you are not capable of giving your consent, or where you have already made the information public.
Data Sharing
We may have to share your personal data with various internal WAPCo functions and various third parties, including third-party service providers who are engaged to perform services on our behalf such as product or service delivery, credit reference checks, or due diligence exercises.
Where appropriate, before disclosing personal data to a third party, we shall contractually mandate the third party to take adequate precautions to protect that data and to comply with applicable law.
In the event of a merger / acquisition / sale or company re-structure, your personal data may be part of the transferred assets and is likely to be disclosed to the purchaser / new company.
Sharing Data With Third Parties
All our third-party service providers are required to take appropriate security measures to protect your personal data 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 and applicable legal requirements.
“Third parties” includes third-party service providers (including contractors and designated agents), professional registrations, legal, other advisors to WAPCo; and independent service providers. This list is not exhaustive.
Transferring Data Regionally
WAPCo has designed and implemented its data collection and handling policies, processes and procedures with the most stringent global privacy and data protection laws and regulations in mind. Accordingly, we consider the highest legal standards when processing and transferring your data.
We are a regional organization with offices and sites in multiple locations around West Africa. Accordingly, we may transfer your personal data to WAPCo regional locations or to third parties / business partners who are in various countries around the world. The regional nature of our organization means your personal data may be sent to countries in which standards of privacy protection differ from the standards of your country of residence.
Please note, we have implemented measures to safeguard your personal data should it be transferred to another country. Such measures include standard data protection contractual clauses and adherence to the principles of the General Data Protection Regulation (GDPR). Should you so wish, you may obtain from WAPCo’s Data Protection Supervisor, further details on our safeguards.
What Constitutes Consent
We rely on consent to process some of your personal data. Where we require your consent, providing your personal data in a form or document, ticking a yes/no box, endorsing your signature in a form or document, and clicking “accept/submit button” on our website will constitute consent.
If you do not consent to the collection, use or disclosure of your personal information as outlined in this notice, please do not provide any personal information to WAPCo. If you have provided personal information to WAPCo and no longer consent to its use or disclosure as outlined herein, please notify WAPCo using: privacy@wagpco.com.
Data Security
WAPCo strives to secure the confidentiality, integrity and availability of your personal data by taking appropriate, reasonable, technical and organizational measures to prevent loss of, damage to, unauthorized use or destruction, and unlawful access to, or processing of your personal data. To this extent, we have due regard to generally accepted information security practices and procedures, and a dedicated information security team, which constantly reviews and improves our personal data security measures.
We endeavour to secure your personal data stored on WAPCo information systems and held in hard copy. Personal data contained in hard copy (paper) format is kept secure and safe in lockable cupboards.
Data Retention
We will only retain your personal data, in accordance with our records retention policies. We will retain personal data for as long as it is necessary to fulfil the purposes for which we collected it or where we are legally entitled / obligated to do so. This includes for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the purpose for which we process personal data, the volume, the nature, and sensitivity of the personal data.
We further consider the potential risk of harm from unauthorized 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.
Once we no longer have a lawful basis to process your personal data, we will securely destroy your personal data in accordance with our records management policies and applicable laws.
Cookies and Similar Technologies
We may use cookies and similar tracking technologies to enhance your experience on our website. Cookies are small data files stored on your device that help us:
- Recognize you when you return to our site.
- Understand how you interact with our content.
- Improve site performance and functionality.
- Deliver targeted advertising and measure its effectiveness.
Purposes of Data Processing:
It is necessary to store data for a limited period to be able to effectively deliver the website to your browser with the necessary functionality. With the help of this data, we also obtain statistical information on how our websites are used. We also collect the data to secure, prevent and track access, or misuse of our websites and IT systems.
Links to WAPCo Social Media Pages
WAPCo website has links to its various social media pages. If you visit these platforms, the privacy policy / notice / statement and terms and conditions of the specific platform apply.
Data Collected When You Contact Us
- Processed data:
When you contact us via a contact form, via email or phone, we process the personal data you communicate to us, e.g., your name, your email address and your request. The data will be stored in a WAPCo repository. The data marked as mandatory must be provided to action your request. Refusal to provide certain information may result in WAPCo being unable to action your request.
- Purposes of data processing:
We use your data to process and respond to your request.
- Legal basis:
We process data to take steps to fulfil your request, as it relates to our business activity.
- Retention period:
We store your data as long as it is necessary to fulfil the purposes mentioned above. Should the business activity referred to above result in the conclusion of a contract or other business relationship to which you are party, your personal data may be stored as necessary according to that contract.
Your Rights and Duties
- Privacy a fundamental right
At WAPCo we respect your fundamental right to Privacy. Your trust and confidence are of paramount importance to us. Please see your privacy rights below, relating to the use of your personal data which may be exercised under certain circumstances.
1.1. Right to withdraw your consent:
You may withdraw your consent to the processing of your personal data at any time. Please note that the revocation does not affect the legality of the data processed thus far. However, we may be obliged by law to retain your personal data despite the withdrawal of your consent. You have the right to object to processing of your personal data for direct marketing purposes, at any time.
1.2. Right to object:
You may object to processing of your personal data where we are relying on a legitimate interest and there is something about your situation which makes you want to object to processing on this ground.
1.3. Right to access:
This right enables you to access the personal data we hold about you and to check that we are lawfully processing it.
1.4. Right to correction
The right enables you to have any incomplete or inaccurate information we hold about you corrected.
1.5. Right to data portability
Under certain circumstances you may have the right to request the facilitation of a transfer of your personal data to another party.
1.6. Right to Deletion
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing.
1.7. Right to Prevent Processing for Direct Marketing
Your personal data cannot be used for direct marketing, without your prior written consent.
1.8. Right to Prevent Processing
You have the right to stop the processing of your personal data, if processing causes or is likely to cause unwarranted damage or distress.
1.9. Right to Notice and Restriction of Solely Automated Decision-Taking
You have the right to be notified about significant solely automated decisions that affect you. You also have the right to request that such decisions not be based on automated processes alone.
2. Your Duties
As the party responsible for the lawful processing and security of your personal data, we endeavour to treat your personal data according to this privacy notice, applicable law and international best practice. To facilitate the protection of your personal data, you have the following duties:
- duty to inform us when there are changes to your personal data;
- duty to safeguard your personal data; and
- duty confirm your identity in order to action your rights.
3. Contact point for asserting your rights:
Should you wish to exercise any of the privacy rights above, you can direct your queries to privacy@wagpco.com.
Our dedicated team would appreciate any comment or complaint, on this privacy notice, or our privacy practices, to assist us with ensuring we respect your privacy as you would reasonably expect.
Updates
We reserve the right, at our sole discretion, to modify, add or remove sections of this Privacy Notice at any time. This Notice (and any updates to or amended versions) may be published on WAPCo’s website as well as any other channels we may find appropriate.
Your continued use of the WAPCo website after any such amendments signifies your acceptance thereof.
Contact Us
If you have any questions or concerns about this Privacy Notice or our data practices, please contact the WAPCo Data Protection Supervisor using: privacy@wagpco.com