1.0 Introduction

Electricity Distribution Company (GEOMETRIC) is an electricity distribution company licensed by the Nigerian Electricity Regulatory Commission to distribute electricity in the South Eastern States of Nigeria.

GEOMETRIC collects a lot of information about our customers, vendors and employees (data subjects). Some of this information is processed, stored electronically and/or transmitted across networks to other computers. We understand that the personal data used for business activities should be secured and it is our responsibility to keep it confidential for the company to be trusted. Employees/third parties may have access, handle or process personal data concerning colleagues, customers, and vendors. It is essential that GEOMETRIC protects personal data and ensure that the requirements stipulated by the Nigeria Data Protection Regulation 2019 (NDPR) are complied with. Breach of data security could lead to business losses, lawsuits and financial loss.

2.0 Definitions

• GEOMETRIC - Electricity distribution Company
• NDPR – Nigeria Data Protection Regulation 2019
• Personal Data – Any data relating to an identified or identifiable natural person (data subject); it can be anything from name, address, a photo, an email address, bank details, etc.
• Data Subject – Any person who can be identified, directly or indirectly.
• Data Subject Access Request – The process for an individual to request a copy of their data under a formal process.
• DPO – Data Protection Officer
• DPO – Data Protection Officer
• Processing – Any operation or set of operations which is performed on data or sets of personal data.
• Personal Data Breach – Breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed.
• Responsible Person – The person responsible for handling data within the department or company.

3.0 General Provisions

• This policy applies to all personal data collected, stored, transmitted and processed by GEOMETRIC.
• Our partners and vendors who process personal data on our behalf are mandated to observe the principles in this policy
• Where applicable, GEOMETRIC shall register with relevant agencies as an organization that processes personal data.
• Personal data shall not be shared without proper authorization. • Personal data shall always be captured with consent from the data subject; Data shall be encrypted when stored or transmitted electronically.
• Personal data captured shall be processed in a secured environment and by authorized persons.

4.0 Policy Principles

GEOMETRIC is committed to processing data in accordance with its responsibilities under the Nigerian Data Protection Regulation (NDPR) and Global Data Regulations. This policy therefore highlights GEOMETRIC’s resolve to always ensure that data storage and handling is carried out in a fair and transparent manner and also takes cognizance of the rights of data subjects. In consonance with the Nigerian Data Protection Regulations, GEOMETRIC takes the following considerations and principles in the collection and processing of personal data:

• GEOMETRIC processes the personal data of data subjects upon such subjects’ consent and upon contract, legal obligation, vital interests, public task or lawful and legitimate interest. Such consent of the Data subject is obtained in a manner devoid of fraud, coercion or undue influence.
• Personal Data of Data Subjects collected by GEOMETRIC are for specified, explicit and legitimate purposes with such purposes duly communicated to the data subjects.
• GEOMETRIC maintains data that is accurate and up to date without prejudice to the dignity of the data subjects. GEOMETRIC further ensures that personal data that are inaccurate with regards to the purposes for which they are processed are erased or rectified without delay.
• GEOMETRIC keeps the Personal Data of its data subjects in a form and manner that permits identification of data subjects for only necessary periods and for the particular purposes for which the personal data are being processed. Where necessary, personal data may be stored for longer periods insofar as the personal data will be processed for archiving purposes in the public interest, scientific or historical or statistical purposes subject however to requisite technical and organizational measures.
• When data is stored on paper, it shall be kept in a secured storage where it cannot be illegally accessed and discarded printouts shall be shredded and disposed-off securely.
• When data is stored electronically, it shall be protected from unauthorized access, accidental deletion and malicious hacking attempts. 4.1Individual Rights
• Data subjects also have the right to object to the use of their personal data for non-essential purposes. Any such requests should be made via email to dataprotection@disco.com
• Data subject(s) may ask GEOMETRIC to access, amend, obtain a copy or delete personal data (subject to terms and condition) that are handled and processed on their behalf. Any such requests shall be made via email to dataprotection@disco.com

5.0 Lawful, Fair and Transparent Processing

• All data processed by GEOMETRIC must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
• To ensure its processing of data is lawful, fair and transparent, GEOMETRIC shall maintain a Register of Systems.
• The Register of Systems shall be reviewed at least annually.
• Individuals have the right to access their personal data and any such requests made to GEOMETRIC shall be dealt with in a timely manner.
• Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
• Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in GEOMETRIC’s systems.

6.0 Monitoring

GEOMETRIC shall monitor how personal data is collected, stored, processed and transmitted and this shall be done in compliance with applicable regulations. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, GEOMETRIC shall promptly assess the risk to people’s rights and freedoms and if appropriate report to relevant supervisory authority within 72 hours of becoming aware of the breach.

7.0 Confidentiality

GEOMETRIC hereby undertakes to treat as strictly confidential any information received in whatever form whether or not it is expressly designated as being confidential, and which comes to our knowledge;, and hereby undertakes to make use of such information only for the purpose for which it is given. GEOMETRIC shall take all necessary actions to ensure that this obligation of confidentiality is respected by its employees and subcontractors. Provided however that such information may be provided by GEOMETRIC if required under any order of a competent court or the relevant government authority. GEOMETRIC shall ensure compliance with this confidentiality clause from all the employees/workers/third-party agents associated with GEOMETRIC’s operation.

PRIVACY NOTICE

The Electricity Distribution PLC (GEOMETRIC), (together “GEOMETRIC” or “disco”, “we” or “us”) respect your concerns about privacy. This Privacy Notice applies to the personal data that we collect and handle for the purposes of maintaining and providing electricity supply service-related information to visitors of this website. For the purposes of this Privacy Notice, “personal data” means any information relating to an identified or identifiable individual.

What data do we collect

GEOMETRIC collects the following personal data to effectively carry out everyday business functions and activities and to provide the products and services defined by our business type. Such data is collected from employees, customers, and vendors and includes (but is not limited to), name, address, email address, and mobile telephone number

Data You Provide to Us

Any data that you voluntarily provide to GEOMETRIC, including your name and email address, will be used for the sole purpose for which the information was provided to us. In addition, communication exchanges on GEOMETRIC’s website are public (not private) communications. Therefore, any message that you post on this website will be considered and treated as available for public use and distribution.

Data We Collect by Automated Means

Like many websites, the GEOMETRIC website use “cookies” and “web beacons”. This site uses cookies to optimize functionality and give you the best possible experience. We obtain certain information by automated means when you visit this site, such as the IP address of the device you use to connect to the Internet and the pages accessed. By collecting this information, we learn how to best tailor the website to GEOMETRIC visitors. We collect this information through various means, including “cookies” and “web beacons”.

Data We Collect from Third Parties
This website does not collect any data on you from other sources.

Data We Share
GEOMETRIC does not sell or otherwise disclose personal data collected as set out above, except as described in this Privacy Notice. The data may also be shared with third-party service providers who perform services for GEOMETRIC. These service providers are not authorized by GEOMETRIC to use or disclose the personal data, except as necessary to perform specific services for us. disco requires its partners and service providers to appropriately safeguard the privacy and security of personal data they process on our behalf.

Specific Purpose of Processing

The purpose of data collection on this website is to process your orders and manage your account. To email you on additional services or products we think you may like. We may also collect and process personal data of visitors and subscribers to this website who request email subscription services from us.

Types of Processing

Any personal data collected on this website is done through manual and automated processes to enroll visitors to the subscription service that they requested. The data collected on this site also undergoes automated processing for the sole purpose of website functionality and user experience. Manual processing may be applied if problems are discovered on the site.

How We Protect the Data

GEOMETRIC maintains appropriate technical and organizational safeguards against unauthorized processing of personal data and against accidental loss, destruction or damage.

How Long We Keep the Data

Your personal data will be kept only as long as necessary for the purposes set out in this Notice and in accordance with GEOMETRIC’s applicable records retention and disposition schedules.

Questions or concerns

Please contact GEOMETRIC’s Data Protection Office at Dataprotection@disco.com

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