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.
Third party links
How personal data is collected, and the purposes of processing personal data
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
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
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] or you can ring 01970 611255 or get in touch via Planet, PO Box 44, Aberystwyth, Ceredigion, SY23 3ZZ.
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.
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.
If you have a comment, concern, suggestion or complaint, please contact us at [email protected] or ring 01970 611255, or get in touch via Planet, PO Box 44, Aberystwyth, Ceredigion, SY23 3ZZ. 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
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:
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:
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.
11. All complaint information will be handled sensitively, telling only those who need to know and following any relevant data protection requirements.
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.
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.
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 Planet, PO Box 44, Aberystwyth, Ceredigion, SY23 3ZZ, by e-mail at [email protected] or telephone on 01970 611255 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:
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.
19. This policy is reviewed regularly and updated as required.