WHAT IS THE PURPOSE OF THIS DOCUMENT?
Planet Equity Group is made up of different legal entities, Planet Forward-UK, Planet Technology, Planet Forward, Planet Professional, Planet Forward Energy Solutions, Strive Consulting, and 110 Holdings, LLC (DBA Launch Consulting) (referred to as the “Group”). This privacy notice is issued on behalf of all the companies in The Planet Group so when we mention "The Planet Group," “we,” “us” or “our” in this privacy notice, we are referring to the relevant company in The Planet Group responsible for processing your data. Each entity is committed to protecting the privacy and security of your personal information.
This Privacy Notice describes how we collect and use personal information about you, in accordance with the relevant data protection legislation in force from time to time. Each company within The Planet Group is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this Privacy Notice. We are a recruitment agency and recruitment business. This Privacy Notice applies to our candidates, other people we may have contact with to find out more about our candidates or whose details have been provided in the event of an emergency, our clients and our suppliers. This Privacy Notice applies in relevant countries throughout our international network. Different countries may approach data protection in a different way but the process outlined in this notice will apply to all. This Privacy Notice does not form part of any contract. We may update this notice at any time. It is important that you read this notice so that you are aware of how and why we are using such information.
DATA PROTECTION PRINCIPLES
We will comply with data protection legislation. This says that the personal information we hold about you must be:
THE INFORMATION WE HOLD AND HOW WE COLLECT IT
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are “special categories” of more sensitive personal data which require a higher level of protection. We only hold this type of data in relation to candidates. We will collect, store, and use the categories of personal information set out below. The lists are not intended to be exhaustive and not every category of information will apply to you:
This information will have been collected by us in the following ways:
If you fail to provide certain information when requested, we may not be able to provide our services as an employment business or perform the contract we have entered into with your limited company or may be prevented from complying with our legal obligations (such as health and safety).
OTHER PERSONAL DATA RECEIVED FROM CANDIDATES
In order to provide services as an employment business and progress opportunities for individuals, we will also be provided with personal data about individuals by candidates. This includes but is not limited to referee details and emergency contact details. The information held will be limited to contact details such as name, address, email address and telephone number.
The information we hold in relation to clients is to enable us to provide our services to them as an employment business. This data will be limited and will include:
This information is usually provided by:
The information we hold in return to suppliers is to enable them to provide services to us. This data will be limited and will include:
This information is usually provided by:
HOW AND WHY WE USE YOUR PERSONAL DATA
We will only use your personal information where the law allows us to. The tables below explain what we process your data for and the legal basis for this.
Most commonly we will use your personal information in the following circumstances:
“Special Categories” of particularly sensitive data require higher levels of protection. For the purpose of this Notice, this includes criminal convictions. We need to have further justifications for processing this type of data. We may process this type of data in the following circumstances:
Less commonly we may process this information where it is needed in relation to legal claims.
HOW WE HOLD THIS INFORMATION
All the personal data we have is stored on our database and in our encrypted cloud-based server within the EU. This will also include emails if personal data was received via this method.
We will only share your personal information where it is required by law, where it is necessary to administer the working relationship with you, where we have another legitimate business interest or we have your consent.
We may share your information with the following third parties:-
PERSONAL DATA PROVIDED BY CANDIDATES
Referees personal data will be shared with any company within the Group, Service Providers and clients we provide services to.
Client data will be shared with any company within the Group, Service Providers, clients we provide services to and candidates.
Suppliers’ data will be shared with any company within The Planet Group, service providers, candidates, and clients.
TRANSFERRING INFORMATION OUTSIDE THE EU
Your data may be accessed by our companies within The Planet Group in the US, who have access to our database and it may be further processed by these companies if opportunities are being considered for you by these companies. There is not an adequacy decision by the European Commission in respect of the US. This means that the country to which we transfer your data is not deemed to provide an adequate level of protection for your personal information. However, to ensure that your personal information does receive an adequate level of protection we have trained all of our US-based employees to follow our GDPR privacy policies and measures in those cases when EU data, that is governed by GDPR, is transferred outside the EU. Our repositories for personal data are stored under certified EU-US Privacy Shield databases via our trusted suppliers. If you require further information about this protective measure, you can request it from firstname.lastname@example.org.
We have put in place measures to protect the security of your information. Details of these measures are available on our company websites. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures can be found in the security policies. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods are available in our retention policy which is available from the company website. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, 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. For candidates where you are not in an active engagement, we will seek your consent to continue to hold your data every [ 6 ] years. After this period it is likely that your data will no longer be relevant and it will be deleted subject to any legal requirements we have to hold your data. In some circumstances, we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a contractor of the company we will retain and securely destroy your personal information in accordance with our data retention policy.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes: It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us. Your rights in connection with personal information: Under certain circumstances, by law, you have the right to:
If you want to review, verify, correct or request the erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact email@example.com in writing. No fee usually required: You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact firstname.lastname@example.org. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
DATA PROTECTION OFFICER
We have appointed a Data Protection Officer (DPO), Steven Jorgenson, to oversee compliance with this privacy notice. If you have any questions about this privacy notice, please contact email@example.com. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information. If you have any questions about this privacy notice, please contact firstname.lastname@example.org.