PG Paper Company Ltd Privacy Policy
Updated 2023
How we look after personal data that we collect from you or that you provide to us
PG Paper Company Ltd (“PG”, “PG Paper”, “we”, “us”, “our”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after the personal data that we collect from you when you use our online channels (regardless of where you visit them) and tell you about your privacy rights and how the law protects you. You may interact with PG Paper in other ways, for instance, if you are a member, in which case there may be a separate privacy policy which describes how we use that data.
We keep our privacy policy under regular review. This version of our privacy policy was last updated in December 2022. Historic versions of the policy can be obtained by emailing us at info@pgpaper.com
1) Important information and who we are
Purpose of this privacy notice.
This privacy policy aims to give you information on how PG Paper collects and processes your personal data through your use of its online channels, including as part of your work with us, when you apply to work with PG Paper, or when you subscribe to our newsletters, publications or communications; or participate in our surveys. It covers information that could identify you (personal information) and information that could not. In the context of the law and this notice, “process” means to collect, store, transfer, use or otherwise act upon information.
Our policy complies with UK Law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR). The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at Know Your Privacy Rights. We regret that if there are one or more points below with which you are not happy, the only recourse is to leave our website immediately.
PG Paper's website (www.pgpaper.com) is not intended for children and we do not knowingly collect data relating to children through this website. We do not sell products or provide services for purchase by children, nor do we market to children. It is important that you read this privacy policy together with any other privacy policies or fair processing notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other privacy policies and notices and is not intended to override them.
Controller
PG Paper Company Ltd is a private limited company registered in Scotland with company number SC2568090002. This privacy policy applies to all PG Paper Company entities and references to “PG”, “PG Paper” "we", "us" or "our, apply accordingly. This privacy policy relates to information obtained by PG Paper for which PG Paper is the Data Controller.
To contact PG Paper in regard to this privacy policy or any aspect of its implementation, to make a complaint, to request access to your personal information, or to request correction of your personal information or any other rights associated with your personal information: please contact us using the details set out below:
Contact details
By post:
PG Paper Company Ltd
Ground Floor, West Wing,
Custom House
Custom House Quay,
Greenock
PA15 1AL
By email: info@pgpaper.com
By telephone: 01505 874266
Complaints
You have the right to make a complaint at any time to your data protection supervisory authority. In the UK, this is the Information Commissioner's Office or ICO. We would, however, appreciate the chance to deal with your concerns in good faith, before you approach the ICO or other supervisory authority, so please contact us in the first instance.
When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint.
Changes to your personal data
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, so that we can update our records.
Third-party links
PG Paper's website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Encryption of data
We use SSL certificates issued by Cloudflare, Inc., to verify our identity to your browser and to encrypt any data you give us. Whenever information is transferred between us, you can check that it is done by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar. The certificate details can be verified by clicking on the padlock in the URL bar.
Review of this privacy policy
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. You may wish to print a copy for your records.
If you have any questions regarding our privacy policy, please contact us via email.
Here you can find our previous privacy policy.
2) The data we collect about you
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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier (usually email address), marital status, title, date of birth and gender, job title and place of work, nationality;
- Contact Data includes personal address, email address and telephone numbers, business contact details, emergency contact details (where you apply to work with us);
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website;
- Profile Data includes your username and password, your interests, preferences, feedback and survey responses;
- Usage Data includes information about how you use our website;
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences;
- Biographical Data any information you might provide to us in your application, curriculum vitae or in your interview and more generally, as part of the recruitment process, for example, test results, health questionnaires, proof of identity and professional qualifications and information that we may collect from you or from background check providers or referees;
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data (or “Sensitive” Personal Data) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data and criminal convictions and offences) unless;
- you have applied to work with us; or
- have provided that information as part of a survey.
Special Categories of Personal Data will be processed in accordance with applicable law, this privacy policy, and any other privacy notice we give to you when you communicate with us.
We only collect personal data relevant to the type of transactions or interaction you have with PG Paper. Whatever your interaction with us, this information will be minimal and linked to the purpose for which we need it.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you but we will notify you if this is the case at the time.
In particular if you fail to provide information when requested which is necessary for us to consider your application for employment with PG Paper, we may not be able to take your application further.
3) How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your personal data by filling in forms or corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- subscribe to our newsletters, publications or communications;
- request marketing, event or other information to be sent to you;
- apply to work with us;
- complete a survey; or,
- give us feedback or contact us
- Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see the section below on Cookies for further details. In addition to Google Analytics, this site uses Active Campaign, LLC to analyse traffic and help us to improve your user experience. We have not configured Active Campaign, LLC not to collect any personally identifiable information or to set cookies. Please see Active Campaign’s privacy policy for more information.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Analytics providers and search information providers, such as Google based outside the UK or European Union (“EU”);
- Publicly available sources such as the UK Companies House or equivalent in other countries that we do business in;
- Recruitment agents;
- Named referees in connection with a job application;
- Background check providers in connection with an application to work with us as a consultant or employee including due diligence checks;
- Providers of psychometric testing in connection with a job application
- When you use PG Paper's online channels, including social media, streaming services, and newsletters, we might also obtain personal data through your use of social media and streaming services, depending on your settings or the privacy policies of these services. Email newsletter services we use may also collect personal data. To change your settings on these services, please refer to their privacy notices, which will tell you how to do this. We have also listed links here:
- Facebook Privacy Policy (USA and Canada: Facebook Inc., 1601 Willow Road, Menlo Park, California 94025, USA; all other countries: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland).
- Instagram Privacy Policy (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland).
- Google/ YouTube Privacy Policy (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland).
- Twitter Privacy Policy (Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 Ireland).
- LinkedIn Privacy Policy (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland).
4) Purposes for which we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Where we need to perform any contract we are about to enter into or have entered into with you.
- Where we have your consent. Generally, we do rely on consent as a legal basis for processing your personal data internally, or by third-party processors in relation to sending marketing communications to you via email, WhatsApp, and other direct comms platforms, including Active Campaign, LLC and Microsoft.
You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To manage our relationship with you which may include notifying you about changes to our terms or privacy policy |
|
|
| To administer and protect our business (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
|
| To deliver relevant website content to you |
|
|
| To provide newsletters and other project related information and marketing and to share with our client for the same purpose. |
|
|
| To improve our website, services, marketing, and relationships |
| Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our strategy) |
| As part of our recruitment process which includes assessing your suitability for a role, carrying out background and reference checks, keeping records etc. |
|
|
| To provide services to clients, to gain additional work and to provide you with further opportunities if you are working with us. |
|
|
| For security purposes |
|
|
| To enable you to complete a survey |
|
|
How we use Special Categories of Personal Data in Recruitment
We will use sensitive personal information (Special Categories of Personal Data) where you apply to work with us in the following ways:
- We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment and selection process;
- We will use information about your race or national or ethnic origin, religious, sexual orientation to ensure meaningful equal opportunity monitoring and reporting; and
- Depending on the role you are applying for, we will collect and process information about criminal convictions.
The lawful basis on which we process special category data is set out in our Recruitment Policy.
Automated Decision-Making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing. You can exercise your right to unsubscribe from marketing material at any time by contacting us at info@pgpaper.com
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of any other transaction which we will continue to use, provided we have a lawful basis to do so.
Payment requests
We do not accept any form of payment via the website. Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.
Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded. We record information such as the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at info@pgpaper.com
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.
5) Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Companies within the PG Paper group of companies
- External third parties as follows:
- Service providers acting as processors who provide IT and system administration services;
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services and security advisers;
- Credit reference agencies should you apply for finance;
- Our Suppliers including where we provide services to clients, including our logistic partners;
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;
- Third parties for the purposes of processing an application to work with us such as organisations for due diligence purposes or providers of testing services and recruitment agents;
- Clients or potential clients for marketing purposes;
- Regulators law enforcement agencies and other agencies and authorities
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties we engage as processors to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our written instructions.
Additionally, our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people. Examples include:
- posting a message on our forum
- posting a product review
- posting a service review
In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it. We do not specifically use this information except to allow it to be displayed or shared. We do store it, and we reserve a right to use it in the future in any way we decide. Once your information enters the public domain, we have no control over what any unknown individual third party may do with it. We accept no responsibility for their actions at any time.
6) International transfers
We may share your personal data with companies (who may or may not be part of the PG Paper group of companies), service providers, regulators and other parties outside of the UK and the EU. This will involve transferring your data outside the UK and European Economic Area (EEA) in some instances to jurisdictions where privacy rights and standards may be less stringent than they are in the UK and the EU. Where we share your personal data outside of the UK or EEA to parties, we will ensure a similar degree of protection as that in the UK and the EU is afforded to your personal data and ensure that there are appropriate safeguards are in place to protect your personal data and rights in respect of that data. In some cases, there may be a legally binding agreement or administrative arrangement in place between both our organisation and the processor, approved by a supervisory authority, further relating to protection of your information.
If you apply to work with us on a project based outside the UK or EEA, your personal data may be provided to our staff, consultants, suppliers, clients and other organisations working with us on the project and who are located in countries outside of the UK or EEA where standards of data protection are not as stringent as those that apply within the UK or EEA. Such transfer shall be necessary for considering your application or for our proposal to be considered by a client.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.
7) Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority or regulator of a breach where we are legally required to do so.
8) Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
In the case of an application for a vacancy submitted using an PG Paper site, we may retain your information for 3 years from the advertised closing date after which it will be destroyed unless you request otherwise. If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.
9) Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data as set out below.
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have to override legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent or any processing that we are carrying out under another lawful basis. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us
No fee is usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these 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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.