Privacy notice — planning agents
Privacy notice — planning agents, architects and consultants (APPROVED 2026-08-27; amendment approved 2026-09-10)
APPROVED BY DAN, 27 August 2026 (869eqx27v): "I have read the complete GDPR pack, I approve all of it." The draft banner is lifted on every document in this pack at once, which is what he asked for. What his approval is not: it is not legal advice, no solicitor has read any of it (his decision of 2026-08-19, 869ef85a2), and it did not create the DPIA that §12.6 of the LIA says is needed before the first bulk-file sale — that DPIA was written on 2026-08-29 at his instruction (869eqy933 Q2), is at docs/gdpr/DPIA-BULK-DATA-FILE.md, and he signed it off separately on 2026-08-30 (869erd3f6 §3.1, "sign it off as written") — a different act from the pack approval above, and one that cleared a single condition (C8) rather than opening a sale: no bulk data file has ever been sold, offered for sale, or produced. The history below is kept as written.
History — status was: DRAFT, 2026-08-25. Written by Claude for ticket 869enkace, as condition C4 of docs/gdpr/LIA-AGENT-ACQUISITION.md. Not legal advice, and no solicitor review is coming (Dan's decision of 2026-08-19, ticket 869ef85a2). Dan reviews, amends and approves before any letter is posted to an agent.
No letter has ever been posted to an agent, and none may be until Dan approves both the assessment and the batch. This notice is published ahead of the mailing rather than alongside it, so that the URL printed on the paper leads somewhere on the day the paper exists.
AMENDED 9 September 2026 (869ez9e55), and READ AND APPROVED BY DAN on 10 September 2026 (869eznx22 §2.2: "approved — flip C6, and I have read the notice"). The amendment banner that stood here for a day is lifted; what it said is kept below because the point of it was that the two versions could be read against each other. Condition C4 of docs/gdpr/LIA-SUBSCRIBER-TO-AGENT.md. When he approved this pack on 27 August it described one purpose: a marketing letter about Just Granted, sent by Blueworkz Ltd. On 9 September he decided that a subscriber's letter about a planning application may be addressed to the named agent, and that decision makes two of this notice's sentences incomplete rather than wrong. What changed, so that it can be read against the approved version rather than looked for: "What we do with it" now describes two purposes with two different controllers instead of one; "we do not pass your details to our subscribers" now says what a subscriber does and does not see; "Who we are" names the subscriber as the controller of their own letter; and a new paragraph publishes the frequency cap. No such letter has ever been sent. kestrel.agentletters.may_address_agents() was False when this was written and is True since 10 September 2026, so the notice is no longer ahead of a purpose that cannot happen — it is ahead of one that has not happened, which is the position it was published in before the acquisition mailing too. 869efx9xk, Dan's end-to-end send gate, still stands in front of every letter and production holds no Stannp key.
The contact address and the website now agree: both read justgranted.co.uk (869ee2apd, 2026-08-27). hello@planandpost.co.uk is an alias on the same mailbox and still receives, so anything sent to the address this notice used to print still reaches us.
Who we are, and who this notice is for
Just Granted is a trading name of Blueworkz Ltd (company number 13258077), registered at 39 Crispin Field, Pitstone, Leighton Buzzard, LU7 9BG, United Kingdom, and registered with the Information Commissioner's Office, registration reference ZB220579.
This notice is for you if you are a planning agent, architect, designer, surveyor or consultant whose name and business address appear on planning applications published by local planning authorities, and we have written to you, or may write to you — either to tell you about Just Granted, or on behalf of one of our subscribers about an application you were named on.
Those two letters have different senders, and it matters which one you are holding. The letter itself says so, on every page.
- A letter about Just Granted is ours. Blueworkz Ltd is the data controller and the sender, and nobody else is behind it.
- A letter about a planning application is a subscriber's — a builder, architect or surveyor who pays us for planning data. They are the sender and they are the controller of that letter; we produce and post it for them, and we are their processor for it. We never write to you about somebody else's application in our own name.
That distinction is the difference between this notice and our other two, and it is why this one exists separately:
- Planning applicants — people who submitted an application, written to by one of our subscribers, where the subscriber is the sender. That notice is at /legal/privacy/.
- Customers — people who subscribe to Just Granted or leave us their email address. That notice is at /legal/privacy/customers/.
Contact us at hello@justgranted.co.uk, or by post at the registered address above.
What we hold about you, and where it came from
Every local planning authority in the UK is required to keep a public planning register and to publish the applications made to it. Where an application is made through an agent, the register usually names that agent and gives their business address, because the authority corresponds with them about the application.
We collect planning applications from those registers. From the same records we hold, about you:
- your name, or your firm's name, as the authority published it;
- your business address, as the authority published it;
- which applications you were named on, and at which authorities.
We did not get any of it from you, and we have no relationship with you. That is why you are reading this: Article 14 of the UK GDPR requires us to tell you when we hold data about you that we obtained from somewhere other than you.
We hold no email address, no telephone number and no financial information about you, because the registers do not publish them and we do not look for them elsewhere.
What we do with it
Two things, both of them a letter through the post.
1. We may post you a letter about Just Granted, our service for building-trade businesses. That is direct marketing, by post, from us, and Blueworkz Ltd is the controller of it.
2. One of our subscribers may post you a letter about an application you were named on, where the authority published no applicant to write to. Our subscribers are builders, architects and surveyors who offer services to people carrying out the work a planning application describes. Where the register names you as the agent and names nobody else, you are the correspondence address the authority itself uses for that application, and the letter goes to your office rather than through the letterbox of the property. The subscriber is the sender and the controller of that letter. We produce and post it for them.
No letter of the second kind has ever been sent. It is described here before it exists, not after, so that the address printed on the paper leads somewhere true on the day the paper exists.
How often. For our own letters about Just Granted: once, and not again — one letter per office per campaign, and not more than one campaign per office in twelve months. For a subscriber's letter about an application: one letter per office from any one subscriber in any twelve months, whatever the size of the council they buy or how many applications you are named on. Those limits are enforced by our software and not by a policy somebody has to remember.
What we never do. We do not email you, telephone you or text you. We do not build a profile of you, we do not score you, and we do not make any automated decision about you. We do not sell, rent or share a list of agents with anyone.
What our subscribers see, and what they do not. No subscriber can browse, search, filter or download planning agents. There is no list of you to buy and we do not offer one. What a subscriber does see is the addressee of a letter they have personally chosen to send and paid to post: your name and office address appear on their own letter, their own proof of it, and their own record of having sent it — as they must, because a letter has an addressee and its sender knows it. That is one application at a time and one letter at a time, and it is the only route by which a subscriber ever learns an agent's details from us.
Our lawful basis
Legitimate interests — Article 6(1)(f) of the UK GDPR, for both kinds of letter, and there is a written assessment of each.
For our own letter about Just Granted, our interest is in reaching the businesses most likely to want the service, at a cost a company of our size can bear. For a subscriber's letter about an application, the interest is theirs: offering their services to the project the application describes, at the address the authority itself corresponds with about it.
We have written an assessment of each balance, weighing the interest against your rights, and we have recorded in each the places where the argument is weak as well as the places where it holds.
We rely on legitimate interests rather than consent because we have no way of asking you first: we hold no email address for you, and the only thing we could do to ask would be to post you the letter we are trying to justify.
Direct marketing by post is not covered by the Privacy and Electronic Communications Regulations, which apply to electronic messages. It is governed by the UK GDPR, and by your absolute right to object below.
You can ask us for either assessment. Email hello@justgranted.co.uk and we will send it to you.
How to stop letters (your right to object)
You have an absolute right to object to direct marketing — Article 21(2). There is no balancing exercise, you do not have to give a reason, and we do not ask you to prove who you are beyond enough to find your entry.
Email hello@justgranted.co.uk, or write to us at the registered address. Tell us the name and address the letter was sent to. We will:
- add that office to our suppression list within 10 working days, marked as an objection about professional post to that office, so that it stops our letters to you and does not affect any householder who happens to share your postcode;
- stop both kinds of letter, from us and from every subscriber. There is one list, it is checked before every letter of either kind goes to the printer, and no subscriber can override it or see that you are on it. You object once, to us, and you do not have to find out who any of our subscribers are;
- keep that suppression entry indefinitely, because deleting it would restart the post you asked us to stop;
- confirm to you that we have done it.
One thing we want to be plain about, because it would be easy to imply otherwise: objecting stops the letters, it does not erase the planning record. Your name and business address remain in our copy of the public register, unused for marketing, on the retention timetable below — the same as they remain on the authority's own published register, which we do not control.
If you would rather we deleted the data entirely, ask, and we will treat it as an erasure request under Article 17 and answer it on its merits.
How long we keep it
Our published timetable is at /legal/retention/. The period for agent data is 24 months from the last time you appeared on an application we collected, matching the period for applicants — approved on 29 August 2026 and now in that timetable rather than proposed alongside it. Suppression entries are kept indefinitely, for the reason above.
We also do not keep a marketing list of you. The list of firms to write to is worked out fresh each time from the applications we hold and thrown away when the batch is composed, so an agent who drops out of the register drops out of the channel without anybody having to remember to remove them.
Your other rights
You have the right to ask us for a copy of the data we hold about you, to have it corrected if it is wrong, to have it erased, to restrict what we do with it, and — as above — to object. Email hello@justgranted.co.uk and we will answer within one month.
If you are not satisfied with our answer, you can complain to the Information Commissioner's Office: ico.org.uk, or 0303 123 1113.
Sharing, processors and transfers
You are not in the data file we license. From 2026-08-27 we intend to license a bulk file of planning-application data to organisations who want it for market research. What is in that file is the applicant's details and the application — never an agent's name, firm or office address. Those fields are held in a different system from the one the file is cut from, they are not among the columns it contains, and adding them would be a different decision with its own assessment. Nothing has been sold.
You are not in any list we hand a subscriber either. The paragraph above is about a bulk file sold to third parties; this is about the people who pay us for planning data, and the answer is the same. A subscriber sees an agent's name and office address in exactly one circumstance — on a letter they have themselves chosen, paid for and sent — and never in the browse screen, the search, the filters, the map or any file they can export. Adding agents to any of those would be a different decision with its own assessment, and it has not been taken.
If we post you a letter, the printing and posting are done by Stannp Ltd, a UK print-and-post provider acting as our processor under an Article 28 contract. They receive your name and address for the purpose of producing and posting that one letter. That is true of both kinds of letter; on a subscriber's letter, Stannp is the subscriber's sub-processor and we are theirs.
We use hosting and email providers in the United Kingdom and the European Economic Area to run the service. We do not transfer your data outside the UK or the EEA for this purpose.