UNIVERSAL PRIVACY, DATA GOVERNANCE & PROPRIETARY RIGHTS FRAMEWORK

Proprietor, Architect & Lead Administrator: Iulian Eduard Vrajitoru

Regulatory Framework: UK GDPR, Data Protection Act 2018, Copyright, Designs and Patents Act 1988, Data (Use and Access) Act 2025

Version: 4.0.1 (Final Release)

Effective Date: 17 February 2026

1. CONSTITUTIONAL STATUS & INDEPENDENT OWNERSHIP

1.1 Private Domain Disclosure This Platform is a specialized digital ecosystem, independently engineered, funded, and operated exclusively by Iulian Eduard Vrajitoru ("the Administrator"). It is a private representation of activities and not an official corporate organ of the national GMB Union.

1.2 Intellectual Property (IP) Sovereignty Under the Copyright, Designs and Patents Act 1988, the Administrator is the "First Owner" of all original works. This includes, but is not limited to:

The underlying source code, CSS, and API integrations.
The UI/UX design, layout hierarchy, and navigational structure.
All original literary content and database architecture.

No Intellectual Property rights have been transferred to the GMB Union or any employer. The Administrator built this Platform outside the scope of any employment contract.

1.3 Revocable Licensing Agreement The GMB Hinkley Point C Branch is granted a temporary, non-exclusive, and fully revocable license to utilize the Platform. The Administrator reserves the absolute right to terminate this license, remove all Union-related branding, and retain the technical engine of the site for private or alternative use at his sole discretion.

2. DATA ROLES & RESPONSIBILITIES

Data Controller: The GMB Branch at Hinkley Point C. They determine the legal purpose for processing union-related data.
Data Processor: Iulian Eduard Vrajitoru. He provides the technical infrastructure and processes data strictly under the Controller's instruction.
Sub-Processor: Wix.com (Enterprise-grade cloud hosting).

3. DATA CLASSIFICATION & TAXONOMY

Personal data is categorized into four distinct tiers:

Tier 1: Identity & Professional Data: Full name, GMB membership number, trade classification, and pay grade.
Tier 2: Contact & Digital Identifiers: Personal email, mobile telephony numbers, and hashed account credentials.
Tier 3: Special Category Data: Trade Union Membership status (processed under Art. 9 UK GDPR).
Tier 4: Automated Telemetry: IP addresses, device hardware identifiers, browser versions, and referral URLs collected to ensure system integrity and security.

4. PURPOSES OF PROCESSING & AUTOMATION

Data is processed for specified, explicit, and legitimate purposes:

Strategic Support: Analyzing membership trends to forecast industrial support needs.
Communication Optimization: Utilizing logic-based routing to direct inquiries to the appropriate workplace representative.
Security & Anti-Fraud: Automated monitoring to prevent unauthorized access via Web Application Firewalls (WAF).

5. SUB-PROCESSOR ECOSYSTEM & SECURITY

Infrastructure: Wix.com (Enterprise hosting with AES-256 encryption at rest).
Transit Security: High-grade SSL/TLS 1.3 encryption for all data in motion.
Analytics: Google Analytics (Anonymized behavioral modeling).
Strict No-Sale Policy: Personal data is never sold, leased, or traded to third-party commercial brokers.

6. INTERNATIONAL TRANSFERS & SAFEGUARDS

Data primarily resides in the UK/EEA. Any international transfers are governed by Standard Contractual Clauses (SCCs) and Binding Corporate Rules (BCRs) to ensure a level of protection equivalent to UK law.

7. USER RIGHTS & SOVEREIGNTY

In accordance with 2026 UK data regulations, users possess the following rights:

Right to Explanation: Users may request the logic behind automated decision-making on the Platform.
Identity Protection: User data will not be utilized to train generative AI models or create synthetic representations of identity without explicit consent.
Data Portability: Request data in a machine-readable format (JSON/CSV).
Erasure: The "Right to be Forgotten" applies to all personal data held within the Platform's database.

8. LIABILITY LIMITATION & INDEMNITY

The Administrator provides the technical framework "as is" and disclaims all liability for the Branch's internal mishandling of data post-extraction from this Platform. By using this Platform, the Controller agrees to indemnify the Administrator against any legal claims arising from the Controller's misuse of the platform.

9. CONTACT & REGULATORY OVERSIGHT

For all matters concerning technical administration, proprietary rights, or data privacy:

Iulian Eduard Vrajitoru (Proprietor & Digital Architect)

Email: iuli675@gmail.com

Direct Line: 07517099518

Lead Data Controller: GMB Hinkley Branch Executive

Email: info@gmb.org.uk.

Regulatory Body: Information Commissioner’s Office (ICO) [www.ico.org.uk]