Privacy Notice

Palma Awards Ltd is the data controller responsible for the personal data processed through PALMA.

Data protection enquiries, objections and requests: concerns@palmaawards.com. A person reads that inbox; there is no automated address at PALMA.

The registered office and ICO registration number will be published here once the company is registered. They are absent because they do not yet exist, not because they are being withheld.

PALMA never collects information about an unclaimed creator merely because it might be useful later.

That is a rule, not an aspiration. It is why an unclaimed record holds four things and not fourteen, why a nominator’s description of someone is never published, and why PALMA holds no identity documents at all.

The architecture that follows from it:

1. IAn unclaimed record is kept to the minimum an awards archive needs to name a candidate.
2. IIA claimed record is controlled by the creator. They decide how they are described.
3. IIISensitive information is never public, whatever its source.
4. IVVerification lives in a separate restricted system and never surfaces on a record.
5. VAward history is an institutional record and is permanent.
6. VIAn external link is published only where PALMA has a lawful and reasonable basis to publish it.

PALMA writes a creator record when someone is nominated, or when the editorial desk establishes that a creator belongs in the archive. That happens before the creator has agreed to anything, and often before they have heard of PALMA.

The lawful basis is legitimate interests (UK GDPR Article 6(1)(f)): the legitimate interest of maintaining an accurate public record of achievement in an industry, balanced against the interests of the person named. PALMA is not relying on your consent, and does not pretend to have it.

Because PALMA did not get the information from you, Article 14 applies. PALMA tells you how it got it, and what it holds, at how PALMA got your information, which is linked from every unclaimed record.

An unclaimed record may contain only:

An unclaimed record will never contain:

1. (a)a legal name, where the creator works under a different one;
2. (b)a city, address, or any location more precise than a country;
3. (c)a date of birth, age, or anything from which one could be inferred;
4. (d)a biography, characterisation or description written by anyone other than the creator;
5. (e)anything a nominator wrote about them. Nomination text is never published, and is not shown on the record;
6. (f)contact details of any kind;
7. (g)anything that reveals or implies health, sexuality, sex life, religion, politics, ethnicity, trade-union membership or biometric identity;
8. (h)anything inferred, guessed, scraped in bulk, or collected because it might be useful later.

You can object, and PALMA will act on it. Under Article 21 you may object to processing based on legitimate interests. For an unclaimed record PALMA treats an objection from the person named as decisive: the record comes down, and PALMA keeps only a minimal note that it was removed and must not be recreated. You do not need an account, and you do not need to give a reason. Use the link on the record itself or write to concerns@palmaawards.com.

The one exception is an honour already conferred. If PALMA has publicly recognised somebody, the record of that recognition is an institutional and archival record and is treated under section Historical and archival records below. Even then, the record is reduced to the achievement itself on request.

Account information. Name, professional name, email address, a hashed password, account status, role and security information. PALMA cannot read your password; it is stored as a scrypt hash with a per-account salt.

Claimed creator record. Professional name, pronouns, country, city, headline, biography, portrait, website and links. All supplied and controlled by the creator, plus the PALMA achievement history, which is not.

Nomination information. The email address used to verify a nomination, the category, the creator nominated, the nomination text, the date and associated technical records.

Verification information. A status, a provider reference, a timestamp and an integrity hash. Nothing else. See below.

Judging and operational information. What is needed to run an award: conflicts of interest, assignments, scores, rationales, eligibility decisions, cases, appeals, audit events and enforcement decisions.

Technical information. Device and browser information, security logs, authentication events and cookie information reasonably necessary for security, fraud prevention and operating the service. PALMA stores a keyed hash of an IP address rather than the address itself, and an address alone is never the basis for rejecting a nomination.

PALMA processes personal data to:

1. (a)operate and secure the PALMA service;
2. (b)create and administer accounts;
3. (c)process and validate nominations;
4. (d)verify email addresses;
5. (e)establish eligibility;
6. (f)administer creator claims and disputes;
7. (g)administer judging and conflicts of interest;
8. (h)publish legitimate PALMA award and creator records;
9. (i)maintain the PALMA Roll of Honour;
10. (j)investigate fraud, manipulation, impersonation and abuse;
11. (k)respond to reports and appeals;
12. (l)communicate operational information;
13. (m)maintain audit and institutional records;
14. (n)comply with legal obligations;
15. (o)establish, exercise or defend legal claims; and
16. (p)improve the security, reliability and functionality of the service.

Where consent is relied upon it is asked for separately and is not bundled into acceptance of the Terms. Accepting the Terms is not consent to anything, and withdrawing a consent never costs you an account or a record.

PALMA records a legitimate interests assessment for each activity relying on that basis, and will provide the relevant assessment on request.

PALMA recognises that information associated with creator participation may be sensitive and may, depending on the circumstances, reveal information falling within special-category data rules under Article 9, in particular data concerning sex life or sexual orientation.

PALMA does not collect special-category data to build records. An unclaimed record is limited to the fields listed above precisely so that PALMA is not in the position of characterising somebody’s work in a way that reveals protected information about them. A category a creator has been nominated in is a description of the work, and PALMA writes it as such.

Where a creator chooses to describe themselves in their own claimed record, that is their decision and their words, and PALMA relies on their explicit consent (Article 9(2)(a)) for publishing it. They can change or remove it at any time.

PALMA will not collect or retain sensitive information merely because it is interesting or commercially useful. Where special-category data is processed, PALMA identifies the applicable Article 9 condition and applies additional safeguards. Where processing is likely to result in a high risk, PALMA carries out a data protection impact assessment before starting.

PALMA creators must be 18 or over. Assurance is performed either by a specialist third-party provider, or, where no provider is contracted, by a PALMA moderator in a restricted workspace.

The permanent record consists of exactly:

1. (a)a status. Verified, or not;
2. (b)a provider reference;
3. (c)the date the check was completed; and
4. (d)an integrity hash binding the outcome to the case.

Never a document, a facial image, a date of birth, an identity number or an address. A test in PALMA’s codebase rejects an outcome carrying any of those, so this is enforced rather than promised.

Where a manual exception requires PALMA to receive material temporarily, access is restricted to authorised personnel, processing is limited to the verification purpose, and the case cannot be closed while the material is still held. Closing is what triggers deletion, and the operator confirms the deletion on the same screen that records the outcome.

Verification information is never published and never appears on a public record.

A claimed creator record may publish: professional name, pronouns, country, city, headline, biography, portrait, website, links. Together with the PALMA achievement history.

Information used internally for verification, judging, fraud prevention, security or case management is never published merely because it exists in PALMA’s systems. That list includes: judging scores and rationales, panel deliberations, conflict declarations, internal notes about a creator, claim evidence, verification data, reports, nomination counts, nominator addresses and the audit log.

Internal notes are a separate table with a separate permission and are never shown to the creator they concern or to the public.

Nominators do not need a PALMA account.

A nominator’s email address is used to verify and administer the nomination, and for security, fraud prevention and audit. PALMA will not publicly identify a nominator, and will not disclose to a creator who nominated them.

PALMA does not publish nomination counts and does not rank creators or nominators by volume. A public tally would turn recognition into a popularity contest and invite exactly the manipulation the rest of this system exists to prevent.

Nomination text is never published. It is written about a third party by somebody else, and publishing it would make PALMA the publisher of one person’s characterisation of another. It goes to the panel and no further.

PALMA processes confidential information relating to judges, conflicts, deliberations, scoring, rationales and internal award decisions.

Such information is restricted to authorised personnel and is not disclosed to creators, nominators, sponsors or the public unless PALMA determines that disclosure is appropriate or disclosure is legally required. Sponsors have no route to it under any arrangement.

PALMA analyses technical and behavioural signals to detect duplicate nominations, automated abuse, impersonation, account compromise and manipulation of the awards process.

Automated signals are used as indicators for human review rather than as the sole basis for an adverse decision. An IP address alone is never the basis for rejecting a nomination: a household, a campus and a workplace share one, and so does a creator’s audience arriving together.

PALMA retains security and audit records for as long as reasonably necessary for security, fraud prevention, dispute resolution, legal compliance and institutional accountability.

PALMA may share personal data with:

1. (a)age and identity assurance providers;
2. (b)hosting, database and infrastructure providers;
3. (c)email and communications providers;
4. (d)security, fraud-prevention and technical service providers;
5. (e)professional advisers;
6. (f)event, ticketing or payment providers where relevant;
7. (g)authorities or law-enforcement bodies where legally required or reasonably necessary; and
8. (h)a successor where PALMA is reorganised, sold, merged or transferred, subject to applicable law.

PALMA does not sell personal data, and does not share it with advertisers or data brokers. Sponsorship buys visibility in the ceremony and on the site; it never buys access to creators, nominators or nomination data.

Some service providers process personal data outside the United Kingdom. Where personal data is transferred internationally, PALMA relies on a lawful transfer mechanism, an adequacy decision, or the International Data Transfer Agreement or Addendum, and applies the safeguards required by applicable data protection law. Details of material categories of international processing are available on request.

PALMA applies retention periods according to the purpose for which information is processed. These are applied by a scheduled sweep rather than by hand, a period nobody enforces is a sentence, not a policy.

Beyond that schedule, PALMA retains account and security records for the life of an account and a reasonable period after; nomination records for as long as reasonably necessary to administer the process, investigate abuse and defend disputes; award and PaROH records for archival purposes; and audit records for as long as necessary to demonstrate the integrity of PALMA’s decisions.

Temporary verification material is kept only for as long as reasonably necessary to complete the check, and is deleted when the case closes.

PALMA retains public historical achievement records for archival and institutional purposes. Where legally permissible and reasonably necessary, that retention continues after an account is closed or a person ceases participating.

Where a record has been corrected or revoked, PALMA retains the underlying audit trail so the historical integrity of the record can be demonstrated. Nothing is silently removed; a revoked honour reads revoked rather than disappearing.

This is a genuine limit on erasure, and PALMA states it plainly rather than burying it. It applies to the fact of an honour, not to everything else: a person who wants their record reduced to the achievement itself, name, category, year, can have that.

PALMA uses strictly necessary cookies for security, authentication and core functionality. They are listed in the cookie notice.

PALMA keeps an aggregate count of how often each of its pages is opened, and of the terms typed into its search boxes. These counts hold no personal data: no IP address, no cookie, no device identifier, no user-agent and no session. None of them stored, and none of them derived and discarded. Because nothing identifies a reader, no part of this is personal data about you and there is no record of your visit to request, correct or erase. The mechanics are set out in the cookie notice.

PALMA runs no advertising, no third-party analytics and no tracking technologies. If that ever changes, they will be used only with the required consent, a preference mechanism will be provided, and continuing to browse will not be treated as consent.

Operational messages, a decision on your record, a security notice, a verification outcome, are sent because PALMA owes them to you. An account that could mute the news that its honour was revoked would not be being kept informed.

Announcements you can switch off are switched off in your Dossier. The Gazette is separate again: consented, double opt-in, and one click to leave from any issue.

Every address PALMA writes from accepts replies. There is no noreply@.

Subject to the conditions and exemptions in law, you have the right to:

1. (a)ask what PALMA holds about you, and get a copy;
2. (b)have inaccurate information corrected;
3. (c)ask for erasure;
4. (d)ask PALMA to restrict processing while a dispute is resolved;
5. (e)object to processing based on legitimate interests, including, decisively, an unclaimed record about you;
6. (f)receive data you gave PALMA in a portable form;
7. (g)withdraw consent where consent is the basis; and
8. (h)complain to the Information Commissioner’s Office.

PALMA responds within one month. Write to concerns@palmaawards.com. You do not need an account to exercise any of these, and PALMA will not make you create one.

You can complain to the ICO at ico.org.uk at any time, including without contacting PALMA first.

You can close your account from your account page. Your sign-in, sessions, Dossier and preferences are deleted, and you are signed out everywhere.

Closing an account does not necessarily require deletion of:

1. (a)historical PALMA award records;
2. (b)legal or regulatory records;
3. (c)security and fraud-prevention records;
4. (d)audit records;
5. (e)records required to establish or defend legal claims; or
6. (f)information PALMA is otherwise lawfully permitted or required to retain.

Where information does not need to remain identifiable, it is deleted or anonymised. The creator record itself returns to the unclaimed state described at the top of this notice . Minimal, and removable on request.

PALMA takes reasonable steps to keep personal data accurate and provides a route for creators to correct their public information. Correcting a factual detail does not alter a historical award decision or a judging record.

Access to sensitive operational information is restricted by role-based access control, every privileged administrative action is written to an audit log, and the most consequential actions require two administrators to agree.

Where required by law, PALMA assesses personal-data incidents, documents relevant breaches, notifies the ICO within 72 hours where the threshold is met, and notifies affected individuals where the risk to them is high.

PALMA is not intended for participation by people under 18. PALMA does not knowingly process children’s personal data for participation in its awards. Where PALMA becomes aware that somebody under the applicable age has participated, it removes or restricts the relevant account, nomination or data, subject to applicable law. If you believe a person under 18 appears anywhere on PALMA, write to concerns@palmaawards.com and it will be treated as urgent.

PALMA updates this notice to reflect changes in law, technology, services, providers or processing activities. This is version 1.1, effective 2026-09-14.

Where required by law, PALMA gives additional notice of material changes. A change that narrows what PALMA holds takes effect immediately; one that widens it is notified before it applies.