Privacy Notice

This Privacy Notice explains how Plumia Ltd collects and uses personal data.

Plumia Ltd is a nonprofit company limited by guarantee incorporated in England and Wales. In this Privacy Notice, “Plumia”, “we”, “us” and “our” mean Plumia Ltd.

Plumia is the data controller for the activities covered by this Privacy Notice. This means that Plumia determines why and how personal data is used.

Contact details

Email: member@plumia.org
Address: 65 Dereham Road, Scarning, England NR19 2PT
Company number: 16157782

1. When this Privacy Notice applies

This Privacy Notice applies when you:

apply or opt in to become a Plumia member;
are admitted as a Plumia member;
subscribe to or interact with Borderless or another Plumia publication;
apply for or take part in a Plumia event, programme, residency, fellowship or other activity;
contribute writing, research, artwork, feedback or other material to Plumia;
contact Plumia, complete a form or respond to a survey;
use a Plumia website, publication page or digital tool; or
join Plumia or access a benefit through a partner-supported, sponsored, fee-waived or other approved route.

A partner-specific joining page or notice may provide additional information where another organisation is involved.

2. Personal data we collect

The information we collect depends on how you interact with Plumia.

2.1 Identity and contact information

This may include:

your name;
email address;
Service address;
country, city, time zone or general location;
organisation, role, biography or professional information; and
Social media handles, website links or public profile links that you provide.

2.2 Membership information

If you join Plumia as a member, we may collect:

your membership application or opt-in;
admission date and, where applicable, cessation date;
membership status and membership route;
fee, fee-waiver or sponsor-funded status;
records showing your acceptance of Plumia’s Articles of Association, Membership Terms and £1 guarantee liability;
records showing that this Privacy Notice was provided to you;
timestamps and other evidence relating to your application or acceptance;
a member or partner reference, where one is used;
communication preferences; and
resignation, suspension, termination or status-change records.

Plumia has one legal class of members, known as Individual Members. Information about the route through which you joined helps us administer fees, funding and member benefits. It does not alter your legal status as a Plumia member.

2.3 Governance information

We may collect information needed to administer Plumia as a membership organisation, including:

eligibility to attend and vote at general meetings;
meeting attendance;
proxy appointments;
Written resolution records;
votes cast where recording them is required to administer or evidence a decision;
questions and submissions made in connection with a meeting; and
information included in minutes, resolutions, reports or statutory filings.

2.4 Publication and communication information

If you subscribe to or interact with Borderless or another Plumia publication, we may collect:

subscription and payment status;
communication preferences;
newsletter delivery, opening and link engagement information, where enabled;
comments, replies, likes and survey responses; and
information shared through community or discussion spaces.

Material posted in a public or member-visible space may be visible to other users.

2.5 Event, programme and contributor information

If you apply for, attend or contribute to a Plumia activity, we may collect:

application, registration and attendance information;
travel, accommodation or logistical information;
your biography, role or speaker information;
dietary, accessibility or support information that you provide;
photographs, video, audio, screenshots or transcripts;
feedback and evaluation responses;
your contribution and related editorial correspondence; and
rights, licence, payment or publication information.

Dietary, accessibility and support information can reveal health, disability, religion or other specially protected information. We collect this only where it is needed to provide the requested support.

2.6 Payment information

Where you make or receive a payment connected with Plumia, we may collect:

payment amount, date and status;
invoice and receipt information;
fee or subscription information;
bank details where Plumia pays you; and
limited transaction references.

Payment card information is normally collected directly by the relevant payment processor and is not stored by Plumia.

2.7 Communications and technical information

We may collect:

messages and correspondence sent to Plumia;
records of responses, calls, meetings, requests or complaints;
IP address, browser, operating system and device information;
pages viewed and referral source;
approximate location derived from an IP address; and
cookie, security and usage information.

3. Where we obtain personal data

We obtain personal data:

directly from you;
through the platforms and service providers that Plumia uses;
from membership partners, sponsors and benefit providers involved in a route you have chosen;
from Plumia’s directors, contractors, contributors and advisers;
from public sources where relevant to editorial, research, governance or due diligence work; and
from another person where they nominate, invite or refer you for an activity.

Where another organisation provides your information to Plumia, the relevant joining flow or first communication will identify that organisation and explain the information received.

4. How we use personal data

We use personal data to:

Administer Plumia membership, including processing applications, admitting members, maintaining membership status, managing fees or fee waivers, and handling resignations, suspensions or terminations. Our lawful basis is contract, including steps taken at your request before you become a member.
Meet our company law and governance obligations, including maintaining the statutory register of members, preparing company records and administering formal member decisions. Our lawful basis is legal obligation.
Manage general meetings and member decisions, including notices, attendance, voting, proxies, written resolutions, annual reports and accounts. Our lawful bases are legal obligation and contract.
Send essential membership communications, including admission confirmations, membership status notices, governance information and changes to Plumia’s governing documents. Our lawful bases are contract and legal obligation.
Administer partner-supported membership routes and benefits, including receiving applications, confirming membership status, providing access and coordinating status changes. Our lawful bases are contract and legitimate interests.
Provide publications and subscriptions, including Borderless and other content requested by subscribers or members. Our lawful basis is contract for paid or membership services and consent for optional email subscriptions.
Send optional communications, including newsletters, event announcements, fundraising messages, community updates and information about partner-supported benefits. Our lawful basis is consent.
Run events, programmes, residencies and fellowships, including applications, selection, registration, logistics, participation and feedback. Our lawful bases are contract or legitimate interests, depending on the activity.
Arrange dietary, accessibility or other requested support. Our lawful basis is consent. Where the information reveals health, disability, religion or other special category information, we also rely on explicit consent under Article 9 of the UK GDPR or EU GDPR.
Process payments and maintain financial records, including membership fees, contributor payments, invoices, receipts and accounting records. Our lawful bases are contract and legal obligation.
Carry out editorial, research and publication work, including commissioning, editing, publishing, crediting and archiving contributions. Our lawful basis may be contract, legitimate interests or consent, depending on the activity.
Protect Plumia, its systems and its community, including preventing misuse, maintaining security, handling complaints and resolving disputes. Our lawful bases are legitimate interests and legal obligation.
Operate and improve Plumia’s digital services, including maintaining websites, understanding participation and improving publications and activities. Our lawful basis is legitimate interests for essential operation and consent for non-essential cookies and analytics.

Where we rely on legitimate interests, those interests include operating Plumia as a membership and publication organisation, maintaining accurate records, administering benefits, protecting Plumia and its users, understanding participation and improving Plumia’s work.

Where we rely on consent, you can withdraw it at any time. Withdrawal applies from that point onwards.

5. Information required for membership

To become and remain a Plumia member, you need to provide:

your name;
an email address or other usable contact information;
the information needed to enter you in Plumia’s register of members; and
confirmation that you accept Plumia’s Articles of Association, Membership Terms and £1 guarantee liability.

Plumia cannot admit or retain a person as a legal member without the information needed to administer membership and comply with company law.

Information requested for optional publications, surveys, profile fields, events and community activities is voluntary unless the relevant form explains that it is needed to provide the requested service.

6. Essential and optional communications

Essential membership communications

Members receive communications needed to administer membership and Plumia’s governance. These may include:

admission and membership status notices;
notices of annual and other general meetings;
annual reports and accounts;
voting, proxy and written resolution information;
changes to Plumia’s Articles, Membership Terms or Privacy Notice; and
suspension, termination or other legal and administrative notices.

These communications continue while you remain a Plumia member.

Optional communications

Optional communications may include:

Borderless and other newsletters;
editorial and community updates;
event and programme announcements;
fundraising messages; and
information about partner-supported benefits.

You can withdraw consent or unsubscribe at any time through the relevant email or by contacting member@plumia.org.

Unsubscribing from optional communications leaves your Plumia membership active. We may retain a minimal suppression record so that your opt-out continues to be respected.

We may share personal data with:

Plumia directors and authorised contractors, contributors and team members;
email, publication, CRM, form, hosting, cloud storage, productivity, event, survey, voting and analytics providers;
payment processors, banks, accountants, bookkeepers and auditors;
lawyers, insurers and other professional advisers;
venues, programme partners and logistics providers;
membership partners, sponsors and benefit providers;
regulators, courts, law enforcement bodies and public authorities;
Companies House and other statutory bodies; and
an organisation involved in a lawful restructuring, merger, transfer or winding-up of Plumia.

Plumia does not sell personal data.

Service providers receive access only to information needed to provide their services and are subject to appropriate data protection and confidentiality requirements.

Partner-supported memberships and benefits

Where a membership route or benefit involves another organisation, Plumia may receive or share limited information such as:

name and email address;
membership status and relevant dates;
paid, fee-waived or sponsor-supported status;
an acceptance or registration timestamp;
communication preferences; and
a membership or partner reference, where one is used.

The relevant joining flow will identify the organisation, the information exchanged and the purpose of the exchange.

A sponsor or partner does not receive special category information, private correspondence, payment card information or individual voting choices solely because it supports a membership route, activity or benefit.

Another organisation may act as an independent controller for its own products or activities. Its own privacy notice governs that processing.

8. Statutory register of members

Company law requires Plumia to maintain a register of members.

The register contains information required by law, including a member’s name, service address and membership dates. Entries relating to former members may remain in the register for up to ten years after membership ends.

The register is subject to statutory inspection and copy rights. Requests have to follow the process established by company law, including the rules concerning the purpose for which the information is requested.

9. International data transfers

Plumia is incorporated in the United Kingdom and works with people and service providers in different countries.

The United Kingdom currently benefits from an EU adequacy decision, which permits personal data to be transferred from the European Economic Area to the United Kingdom under that decision.

Where personal data is transferred to another country without an applicable adequacy decision, we use an appropriate legal safeguard. This may include:

the UK International Data Transfer Agreement;
the UK Addendum to the EU Standard Contractual Clauses;
EU Standard Contractual Clauses; or
another transfer mechanism permitted by applicable law.

You can contact member@plumia.org for further information about the safeguards used for a particular transfer.

10. How long we keep personal data

We keep personal data only for as long as needed for the purpose for which it was collected and for any applicable legal, accounting, governance or dispute resolution period.

Our usual retention periods are:

Statutory register of members: throughout membership and for ten years after membership ends.
Membership applications, acceptance records, membership-route information and status history: throughout membership and normally for six years after membership ends.
General meeting, voting, proxy, resolution and governance records: for at least ten years. Foundational minutes, resolutions and governance records may form part of Plumia’s long-term company archive.
Payment, accounting, invoice and tax records: normally for six years after the end of the relevant financial year.
Newsletter and publication subscription records: until you unsubscribe, close the relevant account or the publication ends.
Unsubscribe and suppression records: for as long as needed to ensure that your communication preference continues to be respected.
Event and programme records: normally for two years after the activity ends.
Dietary, accessibility and support information: normally for no longer than three months after the relevant activity, unless an incident, complaint or legal requirement requires longer retention.
Ordinary enquiries and correspondence: normally for two years after the matter closes.
Complaints, disputes and investigations: until the matter has concluded and any relevant legal claim period has expired.
Contributor, editorial and publication records: for the duration of the editorial relationship and for as long as the relevant material remains published or forms part of Plumia’s editorial archive.
Website, cookie and analytics information: for the period stated in the relevant cookie settings or Cookie Notice.

We may retain information for longer where required by law or where it is needed to establish, exercise or defend legal claims.

We may retain anonymised or aggregated information for longer where it can no longer identify an individual.

11. Security

Plumia uses organisational and technical safeguards appropriate to the information and risks involved. These include access controls, secure accounts, limited permissions, confidentiality requirements, provider contracts and procedures for responding to security incidents.

Where a personal data breach creates a legally reportable risk, Plumia will notify the relevant regulator and affected individuals as required.

12. Your rights

Depending on the applicable law and the circumstances, you may have the right to:

receive a copy of your personal data;
correct inaccurate or incomplete information;
request deletion;
restrict how information is used;
receive certain information in a portable format;
withdraw consent;
object to certain processing; and
complain about how your information is handled.

These rights are subject to legal conditions and exemptions. Plumia may retain information required for statutory records, governance, accounting, legal claims or other lawful purposes.

Requests can be sent to member@plumia.org. We may request information needed to confirm your identity.

You have a right to object to the use of your personal data for direct marketing. You may also object to processing based on Plumia’s legitimate interests.

We will assess the objection and stop the processing unless applicable law permits it to continue.

13. Data protection complaints

You can make a data protection complaint by emailing member@plumia.org and identifying the concern as a data protection complaint.

Plumia will:

acknowledge the complaint within 30 days;
investigate it appropriately;
keep you informed where a response takes time; and
communicate the outcome without undue delay.

14. Cookies and analytics

Plumia websites and digital services may use cookies or similar technologies.

Strictly necessary technologies support functions such as security, page delivery and preference management. We will request consent before using non-essential analytics, advertising or similar technologies where consent is required.

15. Photographs, recordings and public contributions

Plumia activities may involve photographs, video, audio, screenshots, transcripts or written summaries.

Where an activity is being recorded, Plumia will provide appropriate notice. Consent will be requested where required, particularly for identifiable promotional material, interviews or testimonials.

Where you contribute to a public event, publication or discussion, your name, biography, image, voice or contribution may be published and retained as part of Plumia’s editorial or organisational archive.

16. Automated decision making

Plumia does not currently make decisions producing legal or similarly significant effects based solely on automated processing.

Digital tools may support membership records, communications, forms, analytics and voting administration. Material membership and governance decisions are made by authorised people through Plumia’s governance processes.

17. Changes to this Privacy Notice

We may update this Privacy Notice when Plumia’s activities, partnerships, systems or legal obligations change.

The current version will be published through Plumia’s website or publication platform. Where a change materially affects how personal data is used, Plumia will take reasonable steps to bring it to the attention of affected people.

Last updated: 14 July 2025