Green Ink (“we”, “our”) are committed to protecting and respecting your privacy.
This policy and any other documents referred to in it set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller – a controller determines the purposes and means of processing personal data.
Data processor – a processor is responsible for processing personal data on behalf of a controller.
Data subject – a natural person.
Categories of data:
Personal data – the GDPR applies to “personal data”, meaning any information relating to an identifiable person who can be directly or indirectly identified, in particular by reference to an identifier (as explained in Article 6 of GDPR). For example, name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories of personal data – the GDPR refers to sensitive personal data as “special categories of personal data” (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations that is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
GREEN INK PUBLISHING SERVICES LTD is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: Company no: 3593589 Registered in England and Wales; Registered office: Unit 7, Ball Mill, Top Business Park, Main Road, Hallow, Worcester, Worcestershire, England, WR2 6LS, UK. For all data matters, contact Heather Broad at email@example.com.
We use your personal data for the following purposes:
With reference to the categories of personal data described in the definitions above, we may process some or all of the following categories of your data as needed:
We have obtained your personal data in one or more of the following ways: directly from you when doing business with you (including previous business); through completing a webform on our website; from publicly available sources such as those published on company websites; collected from correspondence with others (e.g. other individuals in your organization and you are cc’d); referrals from other clients or individuals; business cards from networking.
a) Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data is as follows:
|Lawful basis||Personal data covered|
CONTRACTUAL INFORMATION WITH CLIENTS OR SUPPLIERS.
PHOTOGRAPHS of clients for inclusion in publications for clients.
BANK DETAILS for suppliers for remuneration as per terms of contract, or occasionally for clients if a refund is required.
CVs of existing suppliers for performance of contract with client.
||INVOICES – preparation and storage of invoices in accordance with HMRC requirements.|
||PHOTOGRAPHS OF SUPPLIERS for the purposes of marketing.*|
||CONTACT DETAILS of existing or potential customers or potential suppliers. We have conducted a Legitimate Interest Assessment (LIA) to verify that this is the correct lawful basis for the processing of these data.
CVs of potential suppliers – used for assessment of suitability for potential assignments. We have conducted a Legitimate Interest Assessment (LIA) to verify that this is the correct lawful basis for the processing of these data.
*A consent form is issued when obtaining the relevant photograph(s) as of 25 May 2018
More information on lawful processing can be found on the ICO website.
Your personal data will be treated as strictly confidential and will be shared only with online contact management tools.
We keep your personal data for no longer than reasonably necessary and we retain your data only for the following purposes, and use the following criteria to determine how long to retain your personal data.
|Contact details – clients and suppliers||Unlimited||Fulfilling our contract with you.
Offering you relevant opportunities to engage us to work with you.
|Contractual information||Unlimited||Creating quotes and establishing working practices for current contracts.
Taking steps to enter into contracts with you.
|Bank details – clients||Deleted after use||Only on occasion that a refund is required.|
|Bank details – suppliers||Unlimited||For remuneration of current and future contracts.|
|CVs – suppliers||Unlimited||Decision making for future contracts.|
|Invoices – clients||7 years||For fulfilling our legal obligation to HMRC for accounting records.|
|Invoices – suppliers||7 years||For fulfilling our legal obligation to HMRC for accounting records.|
|Photographs – suppliers||Unlimited||Marketing.|
|Photographs – clients||Unlimited||In project archives for relevant projects.|
a) You are under no statutory or contractual requirement or obligation to provide us with your personal data below.
But failure to provide data will have the following consequences.
b) We require your personal data below as it is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data.
Some personal data may be transferred outside the European Economic Area.
We do not use any form of automated decision making in our business.
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing, and setting out the relevant purposes and processing conditions.
Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy notice.
To exercise all relevant rights, queries or complaints, please in the first instance contact Heather Broad at firstname.lastname@example.org.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioner’s Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
If you wish to opt out of future marketing communications from Green Ink†, please complete the form below:
†Note that this opt out does not apply to communications regarding the operation of any contract we have with you.