Planet Mark Privacy Policy 

The Planet Mark values are living within the Business Management System to enable Quality and Resilience through the life cycles of our processes and procedures, which ensure proactive and robust management of its inputs and outputs placing significant responsibility on the correct, lawful and fair handling of all data, respecting the legal rights, privacy and trust of all individuals with whom it deals. 

 Planet Mark is committed to privacy for everyone. 

This Privacy Policy is tailored to comply with the General Data Protection Regulation ((EU) 2016/679) (GDPR) 

Under the Data Protection Act, we must comply with certain requirements which are designed to ensure that any Data you provided to us is processed with due care and attention. 

Purpose 

This policy sets out the basis on which any data we collect from you, you provide to us or processed by us and applies to those working with Planet Mark which includes staff, customers, partners and suppliers setting out the key principles to managing breach incidents. The Planet Mark DPO has overall responsibility for the day-to-day implementation of this policy. 

 Senior Leadership commitment 

This Policy is supported by the Chief Executive Officer and the organisations management team. The policy has been communicated to all Planet Mark staff and will be reviewed annually to ensure continuing control. 

 Lilly Miller 

Chief Financial Officer 

 Contact 

Email: [email protected] 

 Data Controller 

Axys House, Heol Crochendy
Parc Nantgarw, Cardiff
Wales, CF157TW

Planet Mark are registered with the Information Commissioners Office for the purposes of Data Protection 

Reference Number: ZA698767 

 1. Introduction 

1.1. We are committed to safeguarding the privacy of our website and business visitors and service users. 

1.2. This policy applies where we are acting as a data controller with respect to the data of our website or potential website visitors and service users; in other words, where we determine the purposes and means of the processing of that data. 

1.3. We will ask you to consent to our use of cookies, if applicable, in accordance with the terms of this policy when you first visit our website. You consent to our use of cookies in accordance with the terms of this policy. 

1.4. In this policy, “we”, “us” and “our” refer to Planet First Limited T/A Planet Mark 

2. How we use your data 

2.1. In this Section 2 we have set out 

a. the general categories of data that we may process 

b. in the case of data that we did not obtain directly from you, the source and specific categories of that data 

c. the purposes for which we may process data 

d. the legal bases of the processing 

2.2. We may process data about your use of our website and or services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services. 

2.3. We may process your application data, this is data provided to us to store your personal information if you have provided it to us as part of registering on our system as a client, customer or potential client or customer (“application data“). The application data may include your name, title, company, partnership, position in company or partnership, email address, postal address and telephone number. The source of the application data is you. The application data may be processed for the purposes of operating our website, any business transaction including any expert witness work or support, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent and or our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. We may also collect and store information about you in reference to an employment application and that data will be stored in accordance with the terms of this policy. 

2.4. We may process your information included in your client/contact application or application on our website if applicable or by email (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent and or our legitimate interests, namely the proper administration of our website and business and or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. 

2.5. We may process your data that are provided in the course of the use of our business and services (“service data“). The service data may include your data. The service data may be used to provide information updates and/or additional services available by us. Service data may also be processed for the purposes of operating our website, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent and or our legitimate interests, namely the proper administration of our website and business and or the performance of a contract between you and us or another and/or taking steps, at your request, to enter into such a contract. 

2.6. We may process information contained in any enquiry you submit to us regarding our services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent. We may process information about you to carry out the provision of services to you. We may access the files of credit reference agencies to allow us to make the necessary credit checks. We may also process information to ensure that we comply with our legal obligations to check your identity and prevent fraud. We use third parties to provide search facilities for credit checks and we may process your information in this manner. 

2.7. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters if applicable (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. 

2.8. We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users and candidates. 

2.9. We may process any of your data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others. We may disclose your information to comply with a legal requirement or as ordered to do so by a Court or Tribunal. We will take reasonable efforts to communicate with you prior to doing so unless we are legally restricted from doing so. We do not sell, rent or otherwise make personal information commercially available to any third party unless specified in this policy. 

2.10. We may process any of your data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks. 

2.11. In addition to the specific purposes for which we may process your data set out in this Section 2, we may also process any of your data where such processing is necessary for compliance with a legal obligation or contract to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. 

2.12. In addition, upon registration or contact, you may provide to us your name, your email address and other information. Without that information, we cannot provide our services. We have installed physical, electronic and managerial processes that keep your information safe when it is collected and subsequently stored. 

2.13. Please do not supply any other person’s data to us, unless we prompt you to do so. 

 3. Providing your data to others 

3.1. We may disclose your data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. 

3.2. In addition to the specific disclosures of data set out in this Section 3, we may disclose your data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. 

3.3. In the unlikely event that a liquidator, administrator or receiver is appointed over us or on any part of our assets, that insolvency practitioner may transfer your information to a third party purchaser of the business provided that the purchaser undertakes to use your information for the same purposes as set out in this policy. 

3.4. If Planet Mark were merged with or taken over by another organisation, your data would become available to such organisation provided that such organisation provided an undertaking only to use it for the same purposes as are set out in this policy. 

 4. International transfers of your data 

4.1. In this Section 4, we provide information about the circumstances in which your data may be transferred to countries outside the European Economic Area (EEA). Data may be transferred to countries outside of the European Economic Area (EEA). Where data is transferred outside of the EEA, that transfer will meet the requirements of the safeguarding principles in the GDPR and the Data Protection Act 2018 

4.2. You acknowledge that data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such data by others. 

 5. Retaining and deleting data 

5.1. This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of data. 

5.2. Data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. 

5.3. We will retain your data as follows 

a. Data information will be retained for a minimum period of 6 years following submission, and for a maximum period of 7 years following submission 

b. Data is destroyed by an appropriate measure. Paper documentation is not retained. Any supplied to us is considered to be confidential data is shredded. Information systems are disposed of in a confidential manner using our IT Consultants 

c. We are Cyber Essentials accredited and therefore have in place required technical and organisational measures in order to secure data subjects data. 

d. Any CV submitted to us is retained for 6 months only and is then appropriate disposed of using a secure disposal system either electronically or by shredding if provided in paper 

5.4. In some cases it is not possible for us to specify in advance the periods for which your data will be retained. In such cases, we will determine the period of retention based on the following criteria: 

a. the period of retention of data category will be determined based on an annual review and will therefore be no longer than 7 years. 

5.5. Notwithstanding the other provisions and information in this Section 5, we may retain your data where such retention is necessary for compliance with a legal or contractual obligation to which we are subject, or in order to comply with a statutory limitation period or in order to protect your vital interests or the vital interests of another natural person. 

 6. Amendments 

6.1. We may update this policy from time to time by publishing a new version on our website. 

6.2. You should check this page occasionally to ensure you are happy with any changes to this policy. 

6.3. We may notify you of changes to this policy by email or through the private messaging system on our website. 

 7. Subject personal rights 

7.1. You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to: 

a. the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address. 

7.2. We may withhold personal information that you request to the extent permitted by law. 

7.3. You may instruct us at any time not to process your personal information for marketing purposes. 

7.4. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes. 

 8. Subject legal rights 

8.1. In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. 

8.2. Your principal rights under data protection law are: 

a. the right to access 

b. the right to rectification  

c. the right to erasure 

d. the right to restrict processing 

e. the right to object to processing  

f the right to data portability 

g. the right to complain to a supervisory authority  

h. the right to withdraw consent. 

8.3. You have the right to confirmation as to whether or not we process your data and, where we do, access to the data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of data concerned and the recipients of the data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. 

8.4. You have the right to have any inaccurate data about you rectified and, taking into account the purposes of the processing, to have any incomplete data about you completed. 

8.5. In some circumstances you have the right to the erasure of your data without undue delay. Those circumstances include: the data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims. 

8.6. In some circumstances you have the right to restrict the processing of your data. Those circumstances are: you contest the accuracy of the data; processing is unlawful but you oppose erasure; we no longer need the data for the purposes of our processing, but you require data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest. 

8.7. You have the right to object to our processing of your data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims. 

8.8. You have the right to object to our processing of your data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your data for this purpose. 

8.9. You have the right to object to our processing of your data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest. 

8.10. To the extent that the legal basis for our processing of your data is  

a. consent; or 

b. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your data from us in a structured, commonly used and machine- readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others. 

8.11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. 

8.12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. 

8.13. You may exercise any of your rights in relation to your data by contacting the DPO 

 9. About cookies 

9.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server 

9.2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. 

9.3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. 

 10. Cookies that we may use 

10.1. We use cookies for the following purposes; 

a. authentication – we use cookies to identify you when you visit our website and as you navigate our website 

b. status – we use cookies to help us to determine if you are logged into our website 

c. personalisation – we use cookies to store information about your preferences and to personalise the website for you 

d. security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally 

e. advertising – we use cookies to help us to display advertisements that will be relevant to you 

f. analysis – we use cookies to help us to analyse the use and performance of our website and services 

g. cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally 

 11. Cookies which may be used by our service providers 

11.1. Our service providers may use cookies and those cookies may be stored on your computer when you visit our website if applicable 

 12. Managing cookies 

12.1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links  

a. https://support.google.com/chrome/answer/95647?hl=e n (Chrome) 

b. https://support.mozilla.org/en-US/kb/enable-and- disable-cookies-website-preferences (Firefox)  

c. http://www.opera.com/help/tutorials/security/cookies/ (Opera) 

d. https://support.microsoft.com/en- gb/help/17442/windows-internet-explorer-delete-manage- cookies (Internet Explorer) 

e. https://support.apple.com/kb/PH21411 (Safari)  

f. https://privacy.microsoft.com/en-us/windows-10- microsoft-edge-and-privacy (Edge) 

12.2. Blocking all cookies will have a negative impact upon the usability of many websites. 

12.3. If you block cookies, you may not be able to use all the features on our website