Privacy Notice

Platinum Compliance (Guernsey) Limited (“Platinum”) is a company incorporated under the laws of Guernsey with registration number 62717. The responsible person for Data Protection is Lynn Philp who can be contacted by phone on 01481 725775, by email at Lynnp@platinumcompliance.co.uk or in writing (to Platinum’s registered office or business address detailed at the end of this Privacy Notice (“Notice”).

As Data Controllers for the information obtained by you, and Data Processors where applicable, we are committed to protecting your privacy. This Notice provides transparency on how data is collected and used in order to meet data protection obligations in accordance with The Data Protection (Bailiwick of Guernsey) Law, 2017 (the “Law”).

This Privacy Notice will be reviewed annually, or on revision of the Law and you will be notified of any material changes.

The date of the last review is 17th March 2022.

It is important to Platinum that the information we hold about you is accurate and up to date. Should your circumstances change, we ask that you notify us promptly using the contact details below.

When Personal Data is collected

Platinum will only process your Personal Data, unless through a Contract for Services with us or in relation to recruitment, in the circumstances below.

When Personal Data is collected by email sent to contact@platinumcompliance.co.uk or directly to a platinumcompliance.co.uk email address

Personal data collected for this purpose is processed to exercise any right or power or perform or comply with any duty conferred or imposed on us. Any information supplied to us by email will be processed using standard email applications such as Microsoft Outlook and Exchange, and we may also maintain a record within our Microsoft Office 365 database. Data processed by Microsoft Officer 365 on Platinum’s behalf may be transferred to, and stored and processed in, the United States or any other country in which Microsoft or its Sub processors operate.

When Personal Data is collected as part of the sign-up process for our alerts and newsletters

We process your personal data in relation to our alerts/newsletter sign-up process and, if this is the only service we provide to you, your email address will be maintained for the sole purpose of sending this information to you.

The legal basis of “consent” is used to process your data in this way. You are therefore free to withdraw your consent at any time by clicking on the unsubscribe link included in each alert/newsletter.

When Personal Data is collected as part of registering to attend our training or social events

Your personal data is processed by us in relation to such events under the basis of “entering into and performance of a contract.” When registering directly with us, your name, mobile number address and email address will be requested. Only information in relation to the event you have signed up for will be sent to you. We use Wix to register you on our events if you book via our website, please click here for further information on the Privacy Policy in place with Wix.com.

When Personal Data is collected as a result of enquiries by phone or in person

We process your personal data by maintaining information with Microsoft Office 365 when enquiries are made by phone or in person as necessary for us to exercise any right or power, or perform or comply with any duty, conferred or imposed on the controller by an enactment.

Sharing of Information

Your Personal Data will only be shared with trusted service providers where a contract is in place with us, such as:

Microsoft Office Online (“Microsoft”)
Professional advisors
IT Consultants
Newgate Compliance Limited (in relation to Platinum Gateway only)

Any request for the Data made by a financial services regulator or public authority or governmental body with jurisdiction over us shall be complied with.

We will take into account the risks that are presented by processing the Data, in particular from a Data Breach and shall take reasonable steps to ensure the reliability of any employee, agent or contractor of Platinum or any such approved sub-processor who may have access to Data, ensuring that all such individuals are subject to confidentiality undertakings or other contractual, professional or statutory obligations of confidentiality.

Platinum shall only use sub-processors to process Data where they offer the same level of protection for Data at a minimum which meet the requirements of the Law.

Data Retention

All Personal Data obtained will be retained securely and only used for the purposes set out in the DP Law and in accordance with Platinum’s retention policy.

Analytics

When using www.platinumcompliance.co.uk, we use Visitor Analytics through Wix.com. Visitor Analytics is a simple website analytics service which measures the traffic and visitors’ general details of the customers' websites. We collect these statistics to enhance your experience (e.g., which pages they visit and when, where they are approximately located, where does a user land first or if they are coming from a specific referral) and to improve services offered by us.

Basically, as a website owner using Visitor Analytics, we are using cookies to collect data about visitors' device type and screen size, approximate location, browser, OS, IPs, page visits, bounce rate, conversions and popular content on the website. All this data is pseudonymized and Visitor Analytics will never use the collected data to identify individual users or to match it with additional information on an individual user. Each visitor has control over the cookies placement. You can control and/or delete cookies as you wish by checking your browser settings on each device you use - for details see aboutcookies.org.

Complaints

Should you wish to complain to Platinum, please do so in writing to either address stated in the “Contact Us” section below.

Section 67 of the Law provides a right for you to complain directly to the Office of the Data Protection Authority for the Bailiwick of Guernsey. Sections 82 and 83 of the Law provides for rights of appeal. Where that complaint relates to the processing of your Data by Platinum, specific procedures can be found on the Authority’s website www.odpa.gg.

Your Rights

You have a number of specific legal rights and responsibilities. These rights have been summarised below. Full information on your rights can be found within the Law. You should write directly to Platinum to make any requests.

Right to information for personal data collected from data subject

You have a right to be given various information about the data we hold about you along with a statement as to whether the provision of your Data is a statutory or contractual requirement, or a requirement necessary to be met in order to enter into a contract, and whether you are obliged to provide the Data, and the possible consequences of failure to provide that Data.

Right to Data Portability

You may also ask us to move, or ‘port,’ your personal information to another organisation electronically. We will only port personal information that you have provided to us, that we have processed based on your consent or performance of a contract, or that has been processed automatically. We will port your personal information without charge and within one month, where technically feasible.

Right of Access

You have the right to request a copy of the information that we hold about you by submitting a Subject Access Request.

Right to Object

You have the right to require us to cease processing of your Data for direct marketing purposes, on grounds of public interest or for historical or scientific purposes.

Right to Rectification

We want to make sure that your personal information is accurate and up to date. You may ask us to correct, update or remove information you think is inaccurate or incomplete, and we ask that you inform us promptly of any changes to your circumstances.

Right to Erasure

You may also ask us to erase your personal information from our systems, in certain circumstances. There are some specific circumstances where the right to erasure does not apply and we are permitted to hold your Data. We will explain the reason for this at the time if this should occur.

Right to Restriction of Processing

You have a right to request that we restrict the processing of your Data in certain circumstances. We will inform our third parties to whom we have disclosed your Data that they must also restrict processing. We will inform you when the restriction on processing your Data ends.

Right not to be subject to decisions based on automated processing

You have a right not to be subjected to an automatic decision and we would only allow automated processing with your consent or if it is necessary to protect your vital interests.

Platinum can be contacted as follows:

Telephone: (01481) 725775

Email: compliance@platinumcompliance.co.uk

Registered Office Address:

1st Floor, Windsor House

Le Pollet

St Peter Port

Guernsey

GY1 1WF

Updated as at 29 March 2022