*Update to privacy policy 28.03.24*

Berw Ltd is ceasing trading this summer, and becoming dormant as a company, with the hope of resuming trading and relaunching Planet magazine in the future. As a consequence, any financial data gathered from our customers has now been destroyed. Personal data is being retained securely for the legitimate interests of enabling subscribers to resume their subscriptions and our contributors to be published again by ourselves should we start trading again. We will review whether this can be justified periodically. Personal data such as correspondence is also being securely retained to fulfil certain ongoing legal and contractual obligations, and for archival and research-based legitimate interests. This update is an amendment to the rest of the privacy policy below.

***

About us

Berw Ltd is the company limited-by-guarantee (with no share capital) which publishes Planet: the Welsh Internationalist magazine in print and digital formats, free online features on Planet Extra and book titles as Planet Books.

Berw Ltd is the data controller and responsible for your personal data (collectively referred to as ‘we’, ‘us’ or ‘our’ in this privacy policy). Personal data means any information about an individual from which that person can be identified.

This privacy policy aims to give you information on how Berw Ltd collects and processes your personal data, including any data you may provide when you (e.g.) become a subscriber, contact us, purchase a publication or other product, take part in a competition, login to manage your digital subscription, submit an advertisement, write an article for us or give us feedback. This website and the products and services provided by Berw Ltd are not intended for children and we do not knowingly collect data relating to children.

Third party links

This 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 policy of every website you visit.

How personal data is collected, and the purposes of processing personal data

Direct interactions: You may give us your personal data by filling in forms or by corresponding with us by post, phone, email, Facebook or Twitter direct message or otherwise.

Publicly available information: we may use publicly available contact details for individuals for the purposes of commissioning an article, or organisations for soliciting advertisements, for example.

Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, for example. Please see below for more information about cookies.

We also receive Contact, Financial and Transaction Data from providers of technical, payment and delivery services, for example Paypal, Amazon or BACS.

Cookies

For information about our Cookies policy and how to opt out of certain cookies please see https://www.planetmagazine.org.uk/cookiepolicy

Our legal bases for processing personal data

Processing and delivering magazine or book orders: contract and legitimate interest

Managing magazine subscriptions in print and digital formats: contract and legitimate interest

Marketing the magazine or books: contract, legitimate interest

Commissioning features and book titles: contract, legitimate interest

Sourcing advertisements: contract, legitimate interest

Distributing the magazine to shops and at events: contract, legitimate interest

Distributing an e-newsletter: consent

Considering magazine and book manuscript submissions: legitimate interest

The process of editing written, visual or multimedia material: contract, legitimate interest

Correspondence with supporters, patrons & funders: contract, legitimate interest

Correspondence regarding feedback about our activities and related debate in the public interest: legitimate interest

Processing job or student placement applications: contract, legitimate interest

Using data collected through cookies: consent, use of essential cookies that enable core functionality for the website.

If we are not able to receive and process the required personal data from you, we may not be able to fulfil our contractual obligations to you. For example, it is essential that we have your email address for us to be able to give you access to Planet in digital format.

Our legal bases for processing information are determined also by the Data Protection Act 2018. This gives exemptions from certain GDPR provisions if the personal data is being processed for the special purposes with a view to publication by a person of journalistic, academic, artistic and literary material in the public interest. It also gives exemptions from certain GDPR provisions if the personal data is being processed for archiving, research and statistical purposes. More information can be found here: https://www.gov.uk/government/collections/data-protection-act-2018

Our legitimate interests

Sustaining new magazine and book sales, magazine subscriptions and our renewal rate which is essential for our business model and in the public interest as a company which receives public funds to publish for the public good.

Marketing and distributing the magazine and books, and sustaining enough income and contributions in kind in ways which are both essential for our commercial interests and in the public interest as a company which receives public funds to publish for the public good.

Developing an awareness of the demographic of our readership in order to publish work which is relevant to our readers.

The ability to swiftly contact potential contributors for forthcoming publication.

Correspondence to enable the editing of material to the highest standards, and maintaining professional relationships with our contributors.

Retaining correspondence and other documentation of cultural value and/or in the public interest as a long-standing publicly funded publisher for archival purposes.

Correspondence with our authors and supporters to enable us to fulfil our role as a vital contributor to cultural and political debate and the wider public sphere in Wales.

Encouraging and retaining correspondence from readers giving feedback on the material we publish to ensure we continue to produce work of the highest quality, and which is popular with our readers.

Recruiting employees, freelancers and students on placement in the best interests of Berw Ltd, and in line with the principles of fairness, transparency and equality of opportunity.

Sourcing and retaining correspondence and other documents which include endorsements from readers, authors, patrons, supporters to (e.g.) make a strong case for the continuation of our funding, or to pursue new forms of support, to encourage authors to contribute or organisations to advertise. Consent would be sought to share any endorsement communicated in correspondence with third parties.

Beyond legal obligations, enabling and retaining correspondence and other documents to effectively fulfil our general obligations to and maintain professional relationships with those who submit work for potential publication, to our funders (public and private), advertisers, Board members, Advisory Board members, complainants, etc.

Contacting individuals to pass on a message from a third party or ask if their contact details can be passed on to the third party if in the significant interests of the individual or significant cultural/journalistic/public interest.

Initiating and retaining correspondence and other documentation as evidence to protect Berw Ltd and the magazine from potential defamatory claims, copyright infringement claims or other legal claims, as a long-standing business and publisher which receives public funds.

Access and control of your personal information

Updating your information

Please ensure you update your personal information or tell us if it changes or is inaccurate. The best contact for this is [email protected].

Withdrawing consent for processing

Where we may rely on your consent to process personal information, you have the right to withdraw that consent at any time. With regard to our e-newsletter, this can be managed through MailChimp settings. Otherwise, please contact us with details of your request. In some instances we may still have an alternative legal basis to continue to process that personal information and we will inform you of that. If you do withdraw consent we may not be able to provide the product or service you have requested.

Other rights

You may request a copy of your personal information from us. You can also ask us to correct any inaccuracies in your personal information. In some circumstances you may be able to ask us to transfer information you have provided to us to another organisation.

You may also have the right to object, erase, or restrict our processing of your information – for example, where we process personal data because this is in our legitimate interests, you may object to this. We will need to carefully consider your request, as there may be circumstances which require us, or allow us, to continue processing your data.

To exercise any of these rights, please contact us. These rights may be restricted by law, for example we may not be able to provide a copy of your data where the data we hold is also the data of a third party and it is not reasonable to disclose this information.

Complaints

If you have a comment, concern, suggestion or complaint, please contact us at [email protected]. If you have a complaint and we cannot resolve the matter, you have the right to complain to the Information Commissioner’s Office in the UK https://ico.org.uk/ . Alternatively you may contact the data protection regulator responsible for your country or region.

Data security and third parties

We have put in place security measures to prevent a data breach, i.e. your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Also, we limit access to your personal data to those employees, agents, contractors, volunteers and other trusted third parties (such as our accountant and website developer and host) who have a legitimate need to know for commercial or legal reasons. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We would not under any circumstances sell your personal data.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Retention of personal information

We will retain your information for as long as necessary for the uses set out in this Policy, or while there is another legitimate reason for doing so. If you ask us to delete your information before that time, we may not be able to do so due to technical, legal, regulatory or contractual constraints. For example, we would need to retain your name and contact details for suppression purposes if you do not want to receive direct marketing from us.

Changes to this policy

From time to time, we make changes to our Privacy Policy and Cookie Policy. This may be in relation to changes in the law, best practice, changes in our services or treatment of your personal information. Where necessary, we will seek your consent to these changes. We will always display clearly when the privacy policy was last amended on this webpage.

***

Our complaints policy

1. Berw Ltd (Planet) (‘We’ or ‘Us’) view complaints as an opportunity to learn and improve the quality of our journalism and the contents of our publication(s) for the future, as well as a chance to put things right for the person (or organisation) that has made the complaint.

2. Our policy is:

To provide a fair complaints procedure that is clear, convenient and easy to use for anyone wishing to make a complaint (in particular those who have disabilities)

To uphold and adhere to the Standards Code (“Code”) https://impress.press/standards/ set out in the IMPRESS Regulatory Scheme in our assessment of all complaints

To publicise the existence of our complaints procedure so that readers know how to contact us to make a complaint

To make sure everyone working for us knows what to do if a complaint is received

To make sure all complaints are dealt with promptly and fairly, with decisions based on sufficient investigation of the circumstances and (where appropriate) offer a suitable remedy

To make sure that complaints are, wherever possible, resolved and that trust in our journalism and our publication(s) remains strong

To gather information about all the complaints we receive to help continually improve the quality of our journalism and our publication(s)

To submit an annual report to IMPRESS of all complaints received and their outcomes

To submit any complaint that is not resolved by us in a timely or satisfactory way to IMPRESS and to comply with directions issued by IMPRESS relating to its Regulatory Scheme

To make available to all our employees a confidential whistleblowing hotline which is independently operated by IMPRESS and not to take any action to the detriment of anyone who uses the hotline or declines to breach the Code

Definition of a Complaint

3. A complaint is any expression of dissatisfaction, whether justified or not, about the editorial content, standards of journalism or conduct of employees or contributors involved in production of our publication(s) that engages the standards set out in the Code: https://impress.press/standards/

Who Can Complain and How?

4. Complaints may come from any person or organisation who is:

personally and directly affected by an alleged breach of the Code

a representative group affected by an alleged breach of the Code, where there is public interest in the complaint

a third party seeking to ensure accuracy of published information

5. A complaint should be received by email or in writing although complaints are accepted by other reasonable means where it is not convenient or practical for the individual complainant to complain in writing.

6. A complaint should be clearly marked as such. General enquiries and requests for corrections will not normally be dealt with as a complaint under this policy unless the complainant makes it clear that they wish to make a complaint.

Whistleblowing Rights of Employees and Contributors

7. Employees or contributors are encouraged to contact the IMPRESS confidential whistleblowing hotline (“the Hotline”) if they are being pressurised to breach the standards set out in the Code or if they have concerns that the standards set out in the Code are not being adhered to more generally by Us.

8. We will publicise the contact details of the Hotline to all our employees and contributors.

9. Any employee or contributor of who uses the Hotline does so with Our full support and in the knowledge that they will not be sanctioned as a result of doing so,

10. We guarantee to protect all whistle-blowers from possible reprisals, victimisation or sanction if a disclosure has been made in good faith even if a subsequent independent investigation carried out by IMPRESS into our journalism finds there to be no breach of the Code or of the IMPRESS Regulatory Scheme. For the avoidance of doubt, We will not take any action to the detriment of anyone who uses the IMPRESS whistleblowing hotline or declines to breach the Standards Code adopted by Us as part of our compliance with the IMPRESS Regulatory Scheme.

Confidentiality

11. All complaint information will be handled sensitively, telling only those who need to know and following any relevant data protection requirements.

Compliance Records

12. In respect of each title We will maintain a written record of all complaints, to include the name and contact details of the complainant, the material or conduct in respect of which the complaint is made and the alleged Code breach.

13. For each complaint record, We will include any steps taken by Us to address the complaint, and the outcome of the complaint. This record will be made available to IMPRESS and to the public (in a redacted form, where necessary), for publication by IMPRESS in its annual report.

14. We will report to IMPRESS all compliance failures of which We become aware (whether complained about or not)

15. Monitoring and learning from complaints are reviewed quarterly by Us to identify any trends which may indicate a need to take further action.

Responsibility

16. Overall responsibility for this policy and its implementation lies with our Board of Directors

17. Responsibility for ensuring that complaints are managed in accordance with this policy lies with a nominated senior legal and compliance standards individual for each title.

18. Each title shall include a statement of arrangements which includes details of the internal authority structure, where responsibilities for Code compliance lie, to whom notice of failure in compliance would be reported (whether complained about or not), together with steps to deal with any failures in compliance.

Procedure

Stage One: Making a Complaint

1. Information on how to make a complaint is clearly publicised on page 96 of our publication and the ‘Privacy and Complaints Policies’ page of our online publication.

2. Complaints may be sent in writing to Us at [email protected] or other reasonable means where this is more convenient and practical for the complainant.

3. Complainants should provide the following information before their complaint will be considered:

The complainant's name, address, e-mail address and telephone number

If the complaint is about a news article it must include:

the name and date of the publication and page reference of the specific article being complained about plus the URL.

URL/Link to any visual or audio element of the complaint.

a written account of what is being complained about with clear reference made to (i) any specific words or phrases in the article that are relevant to the complaint; and (ii) any clauses of the Standards Code adopted by IMPRESS (“Code”) that the complainant believes to have been breached

The desired outcome or remedy sought by the complainant

If the complaint is about the conduct or behaviour of an employee or contributor it must include:

the name(s) of the individual(s) being complained about (if known) or any other information which may identify the individual (s)

a written account of what is being complained about with clear reference made to (i) the nature of the behaviour or conduct being complained about including any relevant times, dates, correspondence or other evidence to support the complaint; and (ii) any clauses of the Code that the complainant believes to have been breached

The desired outcome or remedy sought by the complainant

4. We will make reasonable efforts to contact a complainant by telephone, e-mail or in writing to ensure that sufficient information is provided to respond to the complaint.

Stage Two – Recording, Investigating and Resolving the Complaint

5. The complaint information should be passed to the person we have nominated as being responsible for legal standards and compliance. They will record it in the complaints log and will acknowledge receipt of the complaint by e-mail or in writing within 7 calendar days of receipt of the complaint.

6. The acknowledgement of receipt of a complaint should say who is dealing with the complaint and when the person complaining can expect a reply. Any conflicts of interest should also be declared at this point. A copy of this complaints policy should be attached.

7. The legal standards and compliance contact is responsible for ensuring that the circumstances of the complaint are investigated fairly and that any conflicts of interest are managed. This may require the complainant to provide additional information, documents or other evidence to support their complaint.

8. Complainants should receive a final decision letter within 21 calendar days from the date of the receipt of the complaint.

9. The final decision letter will inform complainants that they have the right to refer their complaint to IMPRESS, stating the applicable time limits, set out in clause 4.4 of the IMPRESS Regulatory Scheme, and how to contact IMPRESS.

10. Whether the complaint is justified or not, the reply to the complainant should describe the action taken to investigate the complaint, the conclusions from the investigation, and any action taken as a result of the complaint.

Stage Three – Escalating the Complaint to IMPRESS

11. If the complainant feels that the problem has not been satisfactorily resolved by Us at Stage Two or if the complainant feels that there are justifiable reasons why the complaint is so urgent that they cannot wait for Us to respond, they can request that the complaint is reviewed by IMPRESS in accordance with its Regulatory Scheme, by contacting IMPRESS using the following details.

Review

19. This policy is reviewed regularly and updated as required.

Adopted on:……………………………22.05.18

Last reviewed:…………………………22.05.18

Privacy and Complaints Policies

Our privacy policy

***

***

Our complaints policy

Procedure