Privacy Policy

1. Who we are

Mustr (mustr.co.uk) is run by BAM Digital Solutions, a sole trader business owned by Benjamin Maddison. We are registered with the Information Commissioner’s Office (ICO), registration number ZC251987.

For anything about your data, email ben@bam-digitalsolutions.com.

2. Our two roles

Under the UK GDPR we act in two different roles, depending on the data.

• Processor for our customers’ records. When a construction business (our customer) uses Mustr, the incident reports, site records, crew details, photos and documents it collects belong to that business. It is the controller and decides why that data is collected. We process it only to run Mustr for them, under our Data Processing Agreement. If you are a worker, an injured person or a witness named in a report, the business you work with is responsible for that data, and we will pass your requests to them.
• Controller for our own data. We are the controller for customer account details, billing, support emails, website use, and the free RIDDOR checker we plan to offer.

3. Data we handle as a processor

On behalf of our customers, Mustr stores:

• incident and near-miss reports sent on WhatsApp: what happened, where, when, who was involved, injury details and any photos sent with the report;
• names, roles and WhatsApp numbers of crew members (operatives) the customer adds;
• toolbox talk attendance, RAMS and policy sign-offs, accreditations and site details;
• the WhatsApp conversation needed to complete a report, and an audit log of changes to records.

Injury details are health data, which is special category data under the UK GDPR. Customers usually rely on their legal duties under RIDDOR 2013 and health and safety law to record it. We protect it as described in section 8.

4. Data we handle as a controller, and why

• Account details (your name, email, company name and number, WhatsApp number you verify): to create and run your account. Lawful basis: contract.
• Billing (plan, payment status; card details are held by Stripe, never by us): to take payment and keep tax records. Lawful basis: contract and legal obligation.
• Support emails: to answer you. Lawful basis: legitimate interests in helping customers.
• Security and service logs: to keep Mustr secure and working. We do not write message text, photos or numbers into our logs. Lawful basis: legitimate interests.
• Free RIDDOR checker (coming soon): this is not live yet. When it is, the description you send will be passed to our AI provider to give you an answer and will not be stored. To limit use, we will keep a scrambled (hashed) form of your number and a daily count for 30 days. We will keep your number as a lead only if you reply YES to being contacted. Lawful basis: legitimate interests for answering and rate limiting; consent for the lead, which you can withdraw at any time.

We do not sell personal data, and we do not use it for advertising.

5. AI

Mustr uses Claude, an AI model from Anthropic, to read reports and suggest whether they may be reportable under RIDDOR 2013 or relevant to CDM 2015, and to draft toolbox talks. The AI does not make decisions with legal effect about anyone: a person at the customer business checks every draft and decides what to submit. Under its commercial terms, Anthropic does not use this data to train its models.

6. Who we share data with

We use the providers below to run Mustr. Each acts on our instructions under a contract with data protection terms. We may also share data where the law requires it, or with a buyer of the business, who would be bound by this policy.

7. International transfers

Some providers are based in, or can access data from, the United States or other countries outside the UK. Where that happens we rely on UK adequacy regulations (including the UK Extension to the EU-US Data Privacy Framework where the provider is certified), or on the ICO’s International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.

8. How we protect data

• Each customer can only see its own records. The database enforces this for every request.
• Data is encrypted in transit and at rest.
• Photos and documents are kept in private storage and shown through links that expire.
• Changes to records are written to an audit log.
• Access to systems is limited to the people who run Mustr.

9. How long we keep data

• Customer records: while the customer’s account is open, so they can meet their own record-keeping duties (for example, RIDDOR requires records of reportable incidents to be kept for at least three years). After an account closes, we keep them for 90 days so the customer can export them, then delete them.
• Unfinished WhatsApp report conversations: the conversation expires after 4 hours of no reply.
• RIDDOR checker usage counts (once the checker is live): 30 days. Leads: until you ask us to stop.
• Billing and tax records: as long as tax law requires, usually six years.
• Backups: our database provider takes automatic daily backups that are kept for 7 days. Deleted data can remain in those backups for up to 7 days after deletion, and then it is gone.

10. Your rights

You have the right to access your data, to have it corrected or erased, to restrict or object to how it is used, to data portability, and to withdraw consent at any time. To use these rights, email ben@bam-digitalsolutions.com. We reply within one month. If the data is held for a customer business, we will pass your request to them and help them answer it.

You can reply STOP to Mustr on WhatsApp to stop messages to your number.

11. Complaints

Please contact us first so we can try to put things right. You can also complain to the Information Commissioner’s Office at ico.org.uk/make-a-complaint or on 0303 123 1113.

12. Children

Mustr is a business service and is not meant for anyone under 18.

13. Changes

We will update this page when what we do with data changes, and tell customers by email about any significant change.