Privacy Notice — ofp-ecology

Effective: 19 May 2026 | Controller: Owletts Farm Partnership (SBI 200801263), Fleur Cottage, East Grinstead RH19 3SL | Data Protection Lead: Ben Todd

This notice explains what personal information ofp-ecology holds about UK landowners, where we obtained it, how we use it, and the rights you have over it. It is issued under UK GDPR Article 14 because in most cases we did not obtain your information directly from you — we obtained it from UK public registers that already published your information under known legal bases.

If you would like the short version, see our Data Subject Promise. If you want to exercise your rights — see what we hold, correct it, object to it, or have us suppress it — use the Data Subject Rights portal.

What is ofp-ecology?

ofp-ecology is a decision-support platform operated by Owletts Farm Partnership. It overlays UK public-register data about land — scheme participation, ownership, corporate structure — against authenticated user-defined catchment boundaries. Authenticated users (today: a small group of UK farming-cluster CIC directors) use the platform to identify, evaluate and prioritise restoration, stewardship and Biodiversity Net Gain partnership opportunities in their local catchment.

We are not a marketplace, not a credit-reference agency, not a direct-marketing service. We aggregate already-public information into a more useful form for restoration partnership work. Authenticated users may use the platform to inform individualised, human-mediated outreach to identified landowners, using only correspondence addresses that the landowner has affirmatively-published in a relevant public register.

What information we hold about UK landowners

We collect from UK public registers, not from data subjects directly. The fields we hold per landowner depend on which registers they appear in:

From HM Land Registry

• INSPIRE Index Polygons (OGL v3.0): title number, polygon boundary — no proprietor identity at this layer.
• CCOD (Commercial and Corporate Ownership Data) (HMLR bespoke licence): for registered companies and charities that own land in England and Wales — company name, company number, address-on-register, tenure, price paid (if recent), country of incorporation.
• OCOD (Overseas Companies Owning UK Land) (HMLR bespoke licence): for overseas companies that own land — proprietor name, country of incorporation, address-on-register, tenure.
• Price Paid Data (OGL v3.0): for property transactions — sale date, price, address, type (no proprietor identity at this layer).

We do not aggregate the HM Land Registry Index of Proprietors' Names, which is name-search only and requires a paper form (HMLR Form PN1) and £11 fee per search.

From the Rural Payments Agency and Defra

• SBI registered land parcels (OGL v3.0): for farmers registered under their SBI — parcel polygon, SBI, scheme participation indicators.
• Find Farm and Land Payment Data (FFLPD) (OGL v3.0 with embargo): for businesses receiving £1,250+ in agri-environment payments — business name, partial postcode (outward code, e.g. "RH19 1"), post town, scheme name, total payment per scheme year. We do not derive private addresses from the partial postcode. Our internal guardrails (QMS-DOC-040zzc §11.2 / `.claude/rules/landowner-lawfulness-guardrails.md`) prohibit any code-level postcode + Codepoint + electoral-roll fuzzy match.
• CAP Payments (legacy): historical EU-era payment beneficiary data — business name, partial postcode, scheme, total payment. Sunsetted May 2027.

From Natural England + Forestry Commission

• Countryside Stewardship (CS) Agreement Publications: agreement reference, option codes, area, contract dates, organisation name where published.
• Sustainable Farming Incentive (SFI) Actions + Agreement Areas: agreement reference, option codes, area, contract dates. SFI publication is anonymised at source; we resolve landowner identity only by lawful cross-reference to other public sources (CCOD overlap, Companies House by-postcode) — never by FFLPD partial-postcode fuzzy match.
• Environmental Stewardship (ES, legacy): agreement reference, options, area, contract dates.
• EWGS / EWCO Forestry Commission woodland grants: scheme reference, options, area, holder name where published.
• Biodiversity Net Gain Register: reference number, grid reference, responsible body (LPA or conservation body — NOT landowner), habitats. Natural England's published schema deliberately excludes landowner names.

From Companies House + Charity Commission

• Companies House Active Register: for directors of land-holding companies — director name, date-of-birth month and year only, service address, registered office, role.
• Companies House PSC bulk: for natural persons with significant control of land-holding companies — name, date-of-birth month and year only, country of residence, nature of control.
• Charity Commission Register: for trustees of land-holding charities — trustee name, registered charity number, correspondence address.

Sources we deliberately do NOT collect

To minimise risks identified in our Lawfulness Analysis (QMS-DOC-040zzc) and DPIA, ofp-ecology does not ingest:

• HMRC Trust Registration Service (no public extract)
• HM Land Registry Index of Proprietors' Names (postal Form PN1, not bulk-useable)
• Per-LA Section 31(6) Highways Act deposits (no national aggregator)
• Northern Ireland Land Registry (LandWeb Direct integration not in place — NI is carved out)
• Scotland ScotLIS title ownership beyond the OGL polygon layer (Scotland is polygon-only)
• SFI intervention sub-codes that could correlate with sensitive personal characteristics (e.g. Farming in Protected Landscapes Wellbeing component)
• Charity Commission entries for religious or political charities where trustee identity could be sensitive
• WhatDoTheyKnow FOI archives that could surface political opinions
• Environment Agency prosecution records naming individual farmers (criminal-offence data, Art 10)

How we use this information

Our lawful basis for processing your personal data is UK GDPR Article 6(1)(f) — legitimate interests. The interests we have identified, the necessity test, and the balancing-test outcome are documented in our Legitimate Interests Assessment (QMS-DOC-040zze) and in our DPIA (QMS-DOC-040zzd), both available on request from the Data Protection Lead.

We use this information to:

• Display per-landowner profiles to authenticated users, scoped to their catchment boundary.
• Aggregate cross-source for identification and prioritisation of restoration partnership opportunities.
• Inform individualised, human-mediated outreach by authenticated users — using only the landowner's affirmatively-published correspondence address from the relevant register.

We do not, and our authenticated users may not under our Acceptable Use Policy:

• Resolve hidden or redacted addresses by fuzzy matching against Codepoint or the electoral roll.
• Operate mass mail-merge or automated marketing campaigns to identified landowners.
• Sell, license, sub-license or republish raw register data.
• Make automated decisions producing legal or similarly significant effects on a natural person (Article 22).
• Infer religion, political opinion, trade-union membership, health, sexual orientation, racial/ethnic origin, or criminal-offence information.

How long we keep your information

We mirror the source-side retention horizon for each source. If a publisher takes a record down or marks it as removed, we tombstone our copy. If a publisher's stated retention horizon is shorter than indefinite, ours matches.

Who we share your information with

• Hetzner Online GmbH — hosting (Helsinki, eu-central); processor under Art 28 DPA.
• Cloudflare — CDN, DNS, DDoS protection; processor under Art 28 DPA.
• GitHub — source-code repository (no data subject records).
• Authenticated business users of the platform (today: OFP / UMLSC CIC directors; future: ecology consultancy customers) — catchment-scoped profile view, under our Acceptable Use Policy.

We do not sell or share data with brokers, advertisers, or marketing providers. We do not transfer data outside the UK or EEA — Hetzner Helsinki sits within the EEA adequacy zone.

How we secure your information

• Encryption at rest (Postgres TLS, Hetzner encrypted volumes).
• Encryption in transit (TLS 1.3 across all customer-facing endpoints).
• Role-based access control via Keycloak.
• Audit logging of access events for 24 months.
• Daily encrypted backups to Cloudflare R2 (EU jurisdiction).
• Quarterly external security audit + annual external pentest (in roadmap).

Your rights

Under UK GDPR and the Data Protection Act 2018 you have rights to:

You also have the right to complain to the Information Commissioner's Office at ico.org.uk. We would prefer you contact us first so we can resolve it directly, but it is your right to escalate at any time.

How to contact us

• Exercise data subject rights: /privacy/dsr
• Data Protection enquiries: ben.todd.personal@gmail.com
• Postal: Ben Todd, Data Protection Lead, Owletts Farm Partnership, Fleur Cottage, East Grinstead RH19 3SL
• Complain to the regulator: ico.org.uk

Changes to this document

We will publish material changes here with at least 28 days' notice. Cosmetic and clarifying changes may take immediate effect. Historical versions are retained in our QMS register (IMS-REG-001).

Last updated: 19 May 2026.