Privacy & GDPR.
Penpole Consulting Ltd. Client and Contractor Privacy Notice
This privacy notice tells you what to expect us to do with your personal information.
- Contact details
- What information we collect, use, and why
- Lawful bases and data protection rights
- Where we get personal information from
- How long we keep information
- How to complain
Contact details
Post
Penpole Consulting Ltd, 29 Great George Street, Bristol, BS8 1QT
Telephone
01173790086
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
- Names and contact details
- Addresses
- Occupation
- Payment details (including card or bank information for transfers and direct debits)
- Employment details (including salary, sick pay and length of service)
We collect or use the following personal information for the operation of client or customer accounts:
- Names and contact details
- Addresses
- Purchase or service history
- Account information, including registration details
- Information used for security purposes
- Marketing preferences
We collect or use the following personal information for information updates or marketing purposes:
- Names and contact details
- Marketing preferences
- Purchase or account history
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 to provide and improve products and services for clients 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.
- 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.
Our lawful bases for collecting or using personal information for the operation of client or customer accounts 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.
- 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.
Our lawful bases for collecting or using personal information for information updates or marketing purposes are:
- 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:
Cybersecurity and digital transformation within the NHS are business-critical issues and our communications are relevant to the professional roles we target (e.g. CISOs, risk professionals, CIOS, DPOs, senior decision makers). Providing relevant information helps organisations strengthen their security, meet regulatory expectations and modernise their systems making them more resilient.
There is a broader public benefit because we are helping NHS Trusts achieve their digital transformation goals as mandated by policy and we are also raising cybersecurity threat awareness and compliance obligations which supports stronger information security practices across industries, contributing to wider resilience and data protection standards.
If we couldn’t go ahead with the processing our business development objectives would not be able to be achieved as getting individual consent would be practicable. As an SME this would have a huge impact on our ability to operate as a business and ultimately could lead to the business having to cease operations. This processing is necessary as direct, targeted B2B email outreach is the most effective and proportionate method to raise awareness of Penpole Consulting among relevant professionals. Other channels such as advertising and social media are less targeted and more intrusive. The emails are tailored to recipients’ professional roles which limits unnecessary data use.
The following data will be processed:
- Recipient’s name
- Business email address (e.g. name@company.com)
- Job title and organisation
- Industry sector where relevant
None of this data is considered particularly ‘private’ and often is publicly available information, e.g. found on company websites, LinkedIn etc. The data will solely be used by Penpole Consulting Ltd for direct B2B marketing purposes and will not be sold or shared externally. Business contact data will be reviewed annually and removed if it becomes outdated, irrelevant or upon request/opt-out. Professionals using corporate email address can reasonably expect to receive B2B communications relevant to their work function and in some cases, we are connected in with the individual on LinkedIn. The data is obtained from publicly available corporate sources, e.g. company websites, LinkedIn and from search engines e.g. Google. The processing cannot be seen as intrusive as the communication is limited to professional matters, minimal in frequency and always offers an opt-out.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Where we get personal information from
- Directly from you
- Publicly available sources
How long we keep information
Contractor Data
|
Category of data |
Examples |
Retention Period |
Rationale/Legal Basis |
|
Personal Identification |
Name, address, date of birth, contact details, ID documents |
6 years after contract end |
Limitation Act 1980 (contractual claims) |
|
Financial/payment data |
Bank account details, invoices, payment records |
6 years after tax year end |
HMRC/accounting obligation |
|
Contractual records |
Contracts, NDAs, correspondence |
6 years after contract termination |
Limitation Act 1980 |
|
Compliance documents |
Insurance certificates, right-to-work, incorporation |
2 years after contract end |
Business need; potential re-engagement |
|
Communications |
Emails and messages relating to engagement |
3 years after last contact |
Business need; dispute management |
Client Data
|
Category of data |
Examples |
Retention Period |
Rationale/Legal Basis |
|
Contact details |
Name, job titles, business email addresses, phone |
3 years after last meaningful contact |
Legitimate interest, CRM management |
|
Contractual records |
Agreements, proposals, correspondence |
6 years after termination |
Limitation Act 1980 |
|
Billing /financial |
Invoices, remittances, purchase orders |
6 years after tax year end |
HMRC/financial record keeping |
|
Marketing and communications |
CRM entries, event attendance, email preferences |
Until opt out or 3 years of inactivity |
Legitimate interests/consent |
|
Complaints or dispute records |
Correspondence, resolution documents |
6 years after closure |
Legal defense/audit purposes |
General/Admin Records
|
Category of data |
Retention Period |
Rationale/Legal Basis |
|
Internal audit and compliance reports |
6 years |
Accountability evidence |
|
Data subject access requests (SARs) |
2 years |
ICO best practice |
|
Data breach logs |
6 years |
ICO guidance and audit readiness |
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
Last updated
October 2025
