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Data Protection

Penman Consulting customer privacy notice and DPA 2018/GDPR statement

This privacy notice tells you what to expect us to do with your personal information. It was generated using tools provided by the Regulator (ICO).

Contact Details

Email: data-protection@penmanconsulting.com

Data controller: Penman Consulting – ICO Registration details

Responsible person: We are not required to employ a DPO. Responsibility lies with Marsh Penman, I.T Manager.

What information we collect, use, and why

We collect or use the following information for the operation of customer accounts and guarantees:

  • Account information, including registration details
  • Information used for security purposes

We collect or use the following information to comply with legal requirements (principally as employers):

  • Name
  • Contact information
  • Any other personal information required to comply with legal obligations
  • Health and safety information

We collect or use the following information for recruitment purposes:

  • Contact details (eg name, address, telephone number or personal email address)
  • Date of birth
  • National Insurance number
  • Copies of passports or other photo ID
  • Employment history (eg job application, employment references or secondary employment)
  • Education history (eg qualifications)
  • Right to work information
  • Security clearance details (eg basic checks and higher security clearance)

We collect or use the following personal information for dealing with queries, complaints or claims:We collect or use the following personal information for dealing with queries, complaints or claims:

  • Names and contact details
  • Account information
  • Purchase or service history
  • Customer or client accounts and records
  • Financial transaction information
  • Correspondence

We collect or use the following personal information for marketing and communications

  • Identity and contact information – This may include your name, title, job role, company, email address, telephone number, and postal address
  • Marketing Preferences and Feedback – If you opt in to receive marketing communications, we may collect details such as your name, email address, areas of interest, and communication preferences. We also keep a record of when and how you gave consent. If you respond to a survey or provide feedback, any personal data included in your responses will also be collected. Participation in surveys is optional, and you can choose to respond anonymously.
  • Online Data (Website Usage) – When you visit our website (www.penmanconsulting.com) or interact with our online services, we automatically collect some data using cookies and similar technologies.
  • Technical Data – This may include your IP address, browser type and version, device type, operating system, and device identifiers. We use this information to ensure the website functions correctly across devices and to troubleshoot technical issues.
  • Usage Data – Information about how you use our website—such as the pages you visit, time spent on pages, links clicked, and the referring page. We use analytics tools (like HubSpot) to gather this data in aggregate form to understand and improve site performance. These tools may set cookies on your browser, and we obtain consent for non-essential cookies where required by law.
  • Cookies and Similar Technologies – Cookies may collect and store information such as user preferences (e.g. login or language settings) or browsing behaviour. 

We collect or use the following personal information for events, conferences and surveys 

  • Identity and contact information – This may include your name, title, job role, company, email address, and telephone number.
  • Marketing preferences and feedback – If you opt in to receive updates or follow-ups, we will use your contact details to share event-related information or post-event surveys.

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

  • Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
  • Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
  • Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
  • Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
  • Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
  • Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
  • Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information for the operation of customer accounts and guarantees are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for legal requirements are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for recruitment purposes are:

  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • Applicants\’ personal information is recorded so that we can judge their suitability for the role they have applied for. It is kept so that we can easily offer them employment, create an employment contract, or offer the candidate future roles.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Where we get personal information from:

  • Directly from you
  • Previous employers
  • Third parties:
  • Businesses to whom we provide services, hosted services and SaaS will provide us with basic user data to allow their employees and agents to use our products.

Our lawful bases for collecting or using personal information for marketing and communication

Penman Consulting may use your contact details to share updates about our services, events, or content that we believe may be of interest to you. This may include:

  • Industry insights,  regulatory updates, company news, or service updates
  • Invitations to webinars, workshops, or events
  • Follow-ups after events (e.g. sharing materials or related information)

Consent (Article 6(1)(a) GDPR) – We will only send you marketing communications if you have opted in, for example by ticking a box on a form or requesting updates. You can withdraw your consent at any time using the unsubscribe link in our emails or by contacting us directly. We also keep a record of your consent, when and how it was given. 

Legal Obligation (Article 6(1)(c) GDPR) – Occasionally, we may need to collect or use information to comply with legal requirements.

Legitimate Interests (Article 6(1)(f) GDPR) – In some cases, particularly for existing clients or professional contacts, we may send relevant information under our legitimate business interests. We ensure communications are proportionate, relevant, and include a simple opt-out option. We also respect any marketing preferences you’ve previously expressed.

How we manage marketing data 

We conduct marketing in a compliant manner: you will receive our email marketing only if you have affirmatively opted in. For instance, if you have opted to receive updates, we will add you to our marketing contacts. If you are an established client contact, we might send you related service info under a soft opt-in basis permitted by law (e.g., the UK PECR). Every marketing email from Penman Consulting includes a clear unsubscribe link so you can opt out at any time. 

We manage our marketing communications using trusted third-party platforms (such as HubSpot), which may track engagement metrics like email opens or link clicks. This helps us assess interest at an aggregate level only.

We do not share your personal data with third parties for their own marketing without your explicit consent. If we co-host an event with a partner, we will always let you know and give you the option to consent before sharing your details.

How long we keep information

We will only keep your personal information for as long as we need it for the purpose we collected it. You have a right to ask us to delete your personal information at any time, unless we must keep it to comply with our legal obligations. However, if we delete your personal information we may be unable to provide various services and benefits.

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

Who we share information with

We will not sell or rent your personally identifiable information to anyone.

Data processors

  • Most SaaS providers we use
  • This data processor does the following activities for us: Where employee details are needed by the SaaS providers we use to provide tools for employees, the minimum necessary data is shared to make use possible by the employee. Where a SaaS provider processes personal data for us, for example H.R and payroll data, we provide the minimum necessary data to fulfil our obligations to the individual.
  • Insurance providers
  • This data processor does the following activities for us: We provide the minimum necessary personal data to insurers in order to provide employee healthcare benefits.

Others we share personal information with

  • Insurance companies
  • Professional or legal advisors
  • Relevant regulatory authorities
  • Organisations we’re legally obliged to share personal information with

Sharing information outside the UK

Where necessary, we will transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

Organisation name: Various service providers as noted above.

Category of recipient: SaaS, insurers, payroll providers.

Country the personal information is sent to: United States, inside the EEA, and nations with adequacy decision.

How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)

Accuracy and access

We will do our best to maintain the accuracy of the personal information you supply to us. You have the right to access and correct your personal information at any time and if you wish to do so please contact us.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

Linked websites

Our site may be linked to other relevant sites and where this is the case, this Privacy Policy will not apply to those other sites once you have visited them. We are not responsible for the content or the privacy practices of other sites.

Privacy notice changes

If we decide to change our Privacy Notice, we will post those changes here so that you will always know what information we gather, how we might use that information and whether we will disclose it to anyone.

Last updated: June 2025

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For more information on Data Protection and GDPR, please contact us.

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