Privacy Notice – Candidates, Clients and Suppliers

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:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

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:

Candidate Data

• Name
• Title
• Address
• Email address
• Telephone number
• Age/date of birth
• Birth certificate
• Proof of name change
• Sex/gender
• Marital status
• Education details
• CV/work history
• Job preferences including role, geographical areas, and salary
• Any other work-related information you provide, for example, education or training
• Proof of qualifications or training
• Industry registration
• Emergency contacts and details of any dependants
• Referee details
• A copy of your passport/identity card
• Permits and visas
• Immigration status
• Nationality/citizenship/place of birth
• A copy of your driving license
• National insurance number/Social Security Number
• Full details of job offers and placements
• Disclosure and Barring Service (DBS) checks
• Drug screening results
• Education verifications
• Employment history verifications
• Diversity information including racial or ethnic origin, religion or similar beliefs, physical or mental health including disability related information
• Medical information
• References
• Details of current remuneration package and benefits
• Financial information (including but not limited to payment terms, bank statements, payroll details, HMRC data, pension scheme details, Court orders, and statutory payments)
• Personal credit details
• Self-employed/business credit details
• Information in relation to your limited company including certificate of incorporation, insurance policy, VAT certificate, and tax registration documents
• Any extra information you tell us, your references tell us, our clients tell us or from third party sources such as job board
• A log of our communications with you by email and telephone

This information will have been collected by us in the following ways:

• Provided by you directly through our website, application forms or registration process
• Provided by a third party who we work with such as a job board company or another employment business or our clients or referral
• Other third-party searches such as LinkedIn and other job sites
• If you like our page on Facebook or follow us on Twitter we will receive information from these sites
• Your references will be provided by your previous employers or other named referees.
• Medical information may be supplied by your doctor, consultant or occupational health.
• DBS checks, other background checks, where relevant, will be supplied by the Disclosure and Barring Service or other external companies

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.

Client Data

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:

• Name
• Telephone number
• Email address
• Information about the business

Supplier Data

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:

• Name
• Telephone number
• Email address

This information is usually provided by:

• The individuals themselves
• By third parties

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.

Candidates

Most commonly we will use your personal information in the following circumstances:

1. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override these interests, i.e. providing you with our service
2. Where we need to comply with a legal obligation
3. Where you have given consent.

"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:

• With your explicit written consent.
• Where we need to carry out our obligation or exercise rights in connection with employment law.
• Where it is needed in the public interests such as equal opportunity monitoring.

Less commonly we may process this information where it is needed in relation to legal claims.

Other personal data received from candidates

Clients

Suppliers

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.

Data sharing

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.

Candidates

We may share your information with the following third parties:

• Prospective employers and our clients with your consent to secure a placement and if you are successful to enable the placement to proceed
• Any of the companies with the Group to find you a role and/or for administrative purposes
• HMRC or local tax authorities for tax reasons
• Pension providers to facilitate access to the scheme
• External companies for the purpose of undertaking DBS or other background checks, where required by law or where your consent has been obtained
• External companies for the purpose of paying you
• To previous employers or other nominated referees for the purpose of obtaining a reference
• To legal advisors to establish, exercise or defend legal claims
• To a new owner of the business should we merge or be acquiesced by another business
• Service Providers, if any, who perform functions on our behalf, including lawyers and IT support

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

Client data will be shared with any company within the Group, Service Providers, clients we provide services to and candidates.

Supplier's Data

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 privacy@theplanetgroup.com.

Data Security

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.

Data Retention

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 unauthorised 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:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

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 privacy@theplanetgroup.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 privacy@theplanetgroup.com. 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 privacy@theplanetgroup.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 privacy@theplanetgroup.com.