Data privacy notice for clients and suppliers

Introduction

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”).

1. Definitions

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.

2. Who are we?

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 14, Elgar Business Centre, Moseley Road, Hallow, Worcester, WR2 6NJ, UK. For all data matters, contact Heather Broad at h.broad@greenink.co.uk.

3. The purposes of processing your personal data

We use your personal data for the following purposes:

  • To correspond with you
  • To offer our services
  • To enter into contract negotiations
  • For the performance of any contract with you
  • To send out invoices to clients and follow up on payment of these
  • To make payments to suppliers
  • To maintain our own accounts and records
  • To adhere to legal requirements
  • To inform individuals of news, events or activities
  • You may give us information about you by filling in forms on our site www.greenink.co.uk (“our site”) or by corresponding with us by phone, email or otherwise.

4. The categories of personal data concerned

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:

  • Personal data:
    • Contact information, which may include, for example, some or all of your name, business address, email address, Skype address, phone number, social media links
    • Invoices sent by suppliers or generated by Green Ink for clients
    • Photographs supplied by clients for the purposes of fulfilling a contract
    • Photographs supplied by suppliers for the purposes of marketing
    • Contractual information agreed between both parties
    • Bank details supplied by yourself
    • CVs supplied by yourself.

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.

5. What is our legal basis for processing your personal data?

a) Personal data (article 6 of GDPR)

Our lawful basis for processing your general personal data is as follows:

Lawful basis Personal data covered
  • Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract
 CONTACT DETAILS.
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.
  • Processing necessary for compliance with a legal obligation
 INVOICES – preparation and storage of invoices in accordance with HMRC requirements.
  • Consent of the data subject
 PHOTOGRAPHS OF SUPPLIERS for the purposes of marketing.*
  • Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject
 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.

6. Sharing your personal data

Your personal data will be treated as strictly confidential and will be shared only with online contact management tools.

7. How long do we keep your personal data?

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.

Personal Data Retention Purpose
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.

8. Providing us with your personal data

a) You are under no statutory or contractual requirement or obligation to provide us with your personal data below.

  • Potential customer: contact details.
  • Supplier: contact details, CVs, photographs and bank details.
  • Clients: photographs are required only for some contracts, where the client wishes their photographs to appear in the publication.

But failure to provide data will have the following consequences.

  • Potential customer: we will not be able to offer relevant opportunities for you to use our services.
  • Supplier CVs and bank details: we will not be able to offer you work or pay you for your services.
  • Any photographs not provided cannot be included in your publication.

b) We require your personal data below as it is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

  • Existing customers: contact details, contractual information (including information necessary for invoicing).
  • Suppliers: invoices in order to be paid; contractual information.

9. Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data.

  • The right to request a copy of the personal data that we hold about you.
  • The right to request that we correct any personal data if they are found to be inaccurate or out of date.
  • The right to request that your personal data are erased where it is no longer necessary to retain such data.
  • The right to request that we provide you with your personal data and where possible, to transmit those data directly to another data controller (known as the right to data portability, where applicable, i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means).
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
  • The right to object to the processing of personal data (where applicable, i.e. where processing is based on legitimate interests or the performance of a task in the public interest/exercise of official authority; direct marketing and processing for the purposes of scientific/historical research and statistics).
  • The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data.

10. Transfer of Data Abroad

Some personal data may be transferred outside the European Economic Area.

11. Automated Decision Making

We do not use any form of automated decision making in our business.

12. Further processing

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.

13. Changes to our privacy notice

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.

14. How to make a complaint

To exercise all relevant rights, queries or complaints, please in the first instance contact Heather Broad at h.broad@greenink.co.uk.

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:

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†Note that this opt out does not apply to communications regarding the operation of any contract we have with you.