Privacy Notice

Introduction

The Copper Mark is the leading assurance framework to promote responsible practices across the copper, molybdenum, nickel and zinc value chains. For more information about how we operate, see the relevant sections on our website.

This notice provides information about the personal information we collect about you, including when you interact with our website (coppermark.org). This notice also provides information about how we will use your personal information and your rights over your personal information.

We may update this notice. We will post any revised notice on our website and will make reasonable efforts to provide you with a revised notice if we make any substantial updates.

Who we are and how to get in touch

We are the Copper Mark, a company limited by guarantee based in the UK. Our company number is 12370476. Our registered office address is at 10 North Place, Cheltenham, GL50 4DW, United Kingdom.

If you would like to know more, please contact us at info@coppermark.org.

What is personal information?

When we use the term “personal information” we mean any information that could be used to identify you. At its simplest, this includes your name and your email address. Personal information will also include any information provided by you (for example, in your correspondence with us or in response to a consultation).

Whose personal information we use

We collect and use personal information about the following types of people:
Individuals who receive our marketing communications
Individuals who are contacts for applications to become a Copper Mark producer, partner or supporter
Individual assessors and individuals who are contacts at company assessors (and/ or applicants)
Individuals who apply to work for the Copper Mark
Individuals who interact with us as, or on behalf of, participants in the Copper Mark
Individuals who participate in our Copper Mark working groups
Individuals who submit or are referenced in a grievance using the Copper Mark Grievance Mechanism (note this does not apply to those who submit anonymously)
Individuals who have contacted us using the contact form or via email, or who we are otherwise in contact with
Visitors to our website
Our suppliers and partners who we engage with as part of our normal business operations

What personal information we collect

The personal information we collect and use includes (but is not restricted to):

Name
Contact details (email address, postal address, telephone number)
Education, certifications and other experience/ qualifications
Employer or associated organisation(s) and role
Your communication preferences
Technical information about your interaction with the website
Any other information that you may give us (for example, if you contact us with a query, comment or a grievance, or apply to become an assessor)

Special category data

Certain types of personal information are sensitive and need more protection. For example, information about your race or ethnic origins, political opinions, sex life or sexual orientation, religious beliefs, health information, biometric and genetic data. There are also special rules about the use of criminal information (information about criminal convictions or allegations about criminal convictions).

We will not usually collect these types of personal information about you. We will only process these types of personal information about you if we have a valid reason for doing so and only if the law allows us to do so.

Sources of personal information

We will collect your personal information directly from you and your interaction with us, including through our website.

You are not under any statutory or contractual requirement to provide us with your personal information. But if you don’t do so, there are certain circumstances where we will not be able to work with you, for example – we won’t be able to consider your application to be an assessor if you do not complete our application form in full.

We will collect information indirectly, for example if you are listed in your company’s application as an assessor, if you submit or are referenced in a grievance or if you are listed in a company’s self-assessment.

We also collect certain technical information from you when you interact with our website. For example, we may keep track of the amount of time you spend on pages, or the pages you visit. For more information about this, please see our Cookies Notice.

How we use your personal information (and the lawful bases for our use)

Purposes of processing

We process personal information to:

Provide you with information about the Copper Mark and to communicate with you in general, including for example if you contact us on behalf of a participant
Provide you with our services or receive services from you
Work with you as an assessor, including publishing your contact details on our website or in other public forums
Communicate with you in your role as a contact for a partner or producer, or participant
Analyse, evaluate and improve our operations (including our overall strategy)
Investigate, respond to and resolve grievances
Satisfy legal obligations which are binding on us (for example, reporting to the UK’s Companies House)
Establish, defend or enforce legal claims
There may be more than one purpose for which we wish to use your personal information depending on the situation.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose and that purpose is compatible with the original purposes. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Lawful bases

We will only use personal information when the law allows us to (i.e., where we have a ‘lawful basis’). Most commonly, we will use your personal information 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. For example, we have a
Where it is necessary for the performance of a contract (either with you or for your benefit). For example, if you are a sole trader, we may have a contract with you and we need your bank details to receive or make payments.
Where it is necessary to comply with a legal obligation on us (for example, reporting to HM Revenue and Customs or the UK’s Companies House).
Less commonly, we may ask for your consent to use your personal information for a specific purpose. You always have the right to withdraw your consent. Just send us an email.

Who we share your personal information with

We may use suppliers/ contractors to help us operate the Copper Mark. We have written agreements with our suppliers that require them to keep your personal information safe, and only use any personal information in line with our instructions.

We may also share your information with partners we work with – for example, to deliver training or events. If we share your information with any other third party, we will let you know in advance where reasonably possible.

There are other circumstances where we may need to share your personal information, for example:

if we transfer the running of the Copper Mark (or any part of it) to another organisation;
with our professional advisors e.g., lawyers, where necessary to protect our or a third party’s interests;
if we are under any legal or regulatory obligation to do so; and
in connection with any legal proceedings or prospective legal proceedings, or to establish, exercise or defend our or a third party’s legal rights.

Where we transfer your personal information internationally

The Copper Mark is based in the UK. However, we may use suppliers/ contractors that operate around the world. This means that it is possible that personal information we collect from you may be transferred to and stored in a location outside of the UK or the EU.

Certain countries outside of the UK or the EU have a lower standard of protection for personal information, including lower security protections. Where your personal information is transferred outside the UK or EU to a country which does not offer a similar level of protection to the UK or EU, we will take all reasonable steps necessary to ensure that the recipient appropriately protects your personal information by, for instance, entering into contracts that have been approved by UK or EU authorities. If you have any questions about data transfers, please do get in touch using our contact details at section 1.

How we keep your personal information safe

The Copper Mark takes reasonable technical and organisational measures to safeguard your personal information against loss, theft and unauthorised use, access or modification.

Sometimes we include links to other websites. This notice only covers how the Copper Mark uses personal information and does not cover these other websites. We encourage you to read the privacy notices on other websites you visit.

How long we keep your personal information for

We will keep your personal information only for as long as required in connection with the purposes for which it was collected and/or is used. Generally, we keep personal information for 6 years following the end of your relationship with us.

We may also retain information for longer periods where we are required to do so in accordance with legal or regulatory requirements, such as tax and accounting. In specific circumstances we may also retain your personal information for longer so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

If you would like further information about this, please contact us using the details in section 1.

Your rights

When we use your personal information, you have the right to:

Ask us for confirmation of what personal information we hold about you, and to request access to a copy of that personal information. If we are satisfied that you have a right to see this personal information, and we can confirm your identity, we will, except where an exemption applies, provide you with this personal information.
Request that we erase the personal information we hold about you, as far as we are legally required to do so.
Ask that we correct any personal information that we hold about you which you believe to be inaccurate.
To change your mind and withdraw your consent when we rely on consent as a legal basis.
Object to our use of your personal information where we:
rely on legitimate interests as grounds for processing;
use the personal information for direct marketing; or
use the personal information for research purposes.
Ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate use.
There are other rights which are unlikely to apply to our use of your personal information. For example, the right to port (or transfer) your personal information (the data portability right) in certain circumstances. Additionally, if we use automated decision making which produces legal effects or similarly significantly affects you, we must tell you.

You also have the right to make a complaint to the relevant data protection supervisory authority. In the UK this is the Information Commissioner’s Office at www.ico.org.uk/concerns.

Version history

Version Number	Purpose/Change	Author	Date
2	Revised	Martin Howitt	8^th January 2024
3	Draft for review	Martin Howitt	8^th January 2024