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PMK-POL-IT-01 · Version 0.1 DRAFT

Privacy Notice

What we collect, why, who sees it, how long we keep it, and your rights

Draft. This notice is being settled by a solicitor alongside our terms, and the details in square brackets are added once the company is registered.
  1. Who We Are
  2. Two Roles
  3. What We Collect and Why
  4. The Verify Page
  5. How We Use AI
  6. Who We Share It With
  7. How Long We Keep It
  8. Your Rights
  9. Cookies
  10. Keeping It Safe, and Changes

1. Who We Are

Passmark builds compliance documents for trade and construction businesses and keeps them up to date. This notice explains how we handle personal information: yours if you use our website or buy from us, and your people's if you are a customer.

Who we are
[Passmark legal name] Ltd, a company registered in England and Wales, number [company number], registered office [address].
How to contact us
hello@mypassmark.co.uk. Write to us at the registered office.
ICO registration
[registration number]

2. Two Roles

For most of what we hold we are the controller: we decide why and how it is used. That covers the people who visit our website, create an account, onboard, buy from us or contact us.

For information about a customer's own people, such as names, job titles and copies of their cards and tickets, we are a processor. The customer is the controller and we use the information only to build and keep their documents current, under our terms and a Data Processing Agreement. If you work for one of our customers and have a question about your information, ask your employer first; we will help them answer it.

3. What We Collect and Why

WhoWhatWhy, and the lawful basis
Website visitorsWhat your browser sends to any website, such as your IP address and browser type, kept in our host's server logs.To run and protect the website. Legitimate interests.
Anyone who creates an accountName, business name, email address, password (stored scrambled, never readable), or your Apple or Google sign-in.To give you an account and send you your onboarding link and reminders about it. Taking steps to enter a contract with you.
Customers, during onboarding and while their plan runsYour answers about your business, your logo, your existing documents, your certificates and insurance schedules, the names and contact details of the people who approve documents, and our messages with you.To build, review, deliver and keep your documents current, and to run your account. Performance of our contract.
Customers who payYour plan, prices, invoices and payment history. Card and bank details go straight to our payment providers; we never see or store your full card number.To take payment and keep tax records. Contract, and our legal obligations.
A customer's peopleName, job title, and copies of cards and tickets with their expiry dates (for example CSCS, PASMA, IPAF, Gas Safe ID). Only what the customer chooses to send.On the customer's instructions, to name people in their documents and track when cards expire. We are the processor.
Anyone who checks a company on our Verify pageNothing beyond the server logs above. We do not ask who you are.Legitimate interests.

We never ask for, and do not want, health information, right to work checks or disciplinary records. If they reach us we do not keep them and we tell the customer.

4. The Verify Page

Each customer has a public Verify page, opened with their company code or the code on their documents. It shows business details only: the business name, town, trade and company number, the status of their plan, review dates, their Passmark certificate, and the evidence on file by type, for example "Public liability insurance, copy held" or "PASMA cards held for the team".

It never shows anything personal about a customer's people: no names, photos, card numbers or dates of birth. A sole trader's business name may be their own name; they agree to it appearing when they agree our terms, and can ask us to show a trading name instead.

5. How We Use AI

We use an AI service to read the documents customers send us, to draft content around their business and to check our own work. A person reviews everything before it is released. The AI provider processes the information on our behalf only, under contract, and does not use it to train its models. It is named in the list below.

No decision with legal or similarly significant effects on anyone is made by AI alone.

6. Who We Share It With

We do not sell personal information and we do not share it for marketing. We use these suppliers, each under a written contract that only allows them to act on our instructions:

SupplierWhat for
Anthropic (Claude)The AI service described above. [Region and transfer basis to be confirmed]
[Website and app hosting]Hosting the website, the onboarding app, the Passmark app and the Verify page
StripeCard, Apple Pay and Google Pay payments
GoCardlessDirect Debit
[Email service]Sending account, onboarding, order and reminder emails
[Accountant]Bookkeeping and tax
[Cloud storage and backup]Keeping our files safe

We may also share information where the law requires it, or to protect our rights, for example with our insurers or legal advisers.

Some suppliers process information outside the UK, mainly in the United States. Where they do, the transfer is covered by the UK-US data bridge, the UK International Data Transfer Agreement or another safeguard UK law recognises.

7. How Long We Keep It

InformationKept for
An account that never went on to buy12 months after the last time it was used, then deleted
A customer's profile, answers, documents and evidenceWhile the plan runs, then 12 months in case they come back, then deleted
Passmark app records, after moving to Stay Compliant or leavingRead-only for 90 days, kept 12 months, then deleted
Copies of a customer's people's cardsUntil replaced by a renewed card, the customer asks us to delete them, or 12 months after the plan ends
The register of issued documents and certificates (references, versions and dates, no personal information)Permanently, so a document can always be checked
Invoices and payment recordsSix years after the end of the financial year they relate to, as tax law requires
Server logs[up to 30 days, depending on the host]

8. Your Rights

You can ask us to:

  • give you a copy of the information we hold about you;
  • correct anything that is wrong;
  • delete your information, where we no longer need it or have no other lawful reason to keep it;
  • restrict how we use it, or object to our using it on the basis of legitimate interests;
  • give you your information in a format you can take elsewhere.

Ask by email at hello@mypassmark.co.uk. We reply within one month. There is no charge.

If you are unhappy with how we have handled your information, please tell us first so we can put it right. You can also complain to the Information Commissioner's Office: ico.org.uk, 0303 123 1113.

9. Cookies

Our website uses no advertising or tracking cookies and no analytics that follow you. When you log in, a single essential cookie keeps you logged in; it is deleted when you log out or after [period]. Your browser may also store your onboarding answers as you go, so you can stop and come back. Because none of this is optional to make the site work, we do not show a cookie banner.

If we ever add anything that is not essential, we will ask first and update this notice.

10. Keeping It Safe, and Changes

Information is held in secure, access-controlled systems, sent over encrypted connections, and only seen by people who need it for their job. If something goes wrong we follow our Data Breach Procedure, including telling the ICO within 72 hours where the law requires it.

We review this notice at least once a year. The version and date are at the top and the changes are listed in the revision history.