Purpose

This policy describes how we use your personal data when you use our website www.thetracinggroup.co.uk or when we provide services to you. We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe. You have legal rights to access the personal data we hold about you and control how we use it, which are also explained.

Who we are and how you contact us

We are The Tracing Group Limited, a company registered in England with registration number: 10640926. Our registered head office address is Unit 4D, Wymondham Business Centre, Norfolk, NR18 9JL.

You can contact us in writing at Unit 4D, Wymondham Business Centre, Norfolk, NR18 9JL or by email at: info@thetracinggroup.co.uk. If you want to speak to us, please call us on 01603 937800.

Please refer to the sections on your rights to know what personal data we hold and to control how we use it, and how to make a complaint for further information.

What personal data we collect about you

We collect:

1. Personal data that you provide to us. There are lots of ways in which you may share your personal data with us. For example, you may register on our website, post on social media sites that we run, or contact us in connection with the services we provide to others. The personal data you provide us may include your name, address, e-mail address and phone number, date of birth and National Insurance Number.
2. Personal data that we receive from third parties. If we work with other businesses or use sub-contractors, these parties may collect personal data about you, which they will share with us. For example, we may have your name and contact details passed to us by a pension scheme, insurance provider, asset manager or other financial institution so that we can assist them in updating their records or trace you to your current address.
3. Personal data about your use of our website. This is technical information and includes details such as your IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, as well as details of how you navigated to our website and where you went when you left, what pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and any phone number used to call our customer service number.

What we use your personal data for

Personal data that you provide to us is used to:

1. Provide you with the information, products and services you request from us.
2. Provide you with marketing information in accordance with your marketing preferences (see how we use your personal data for marketing)
3. Manage and administer our business.
4. Review and improve our service.
5. Deliver a service to trace customers on behalf of our clients or update our client’s records.
6. Personal data that we receive from third parties is combined with the personal data that you provide and used for the purposes described above.
7. Personal data about your use of our website is used to:
   1. Administer our website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
   2. To improve our website to ensure that content is presented most effectively for you and your computer or mobile device.
   3. To allow you to participate in interactive features of our service when you choose to do so.
   4. As part of our efforts to keep our site safe and secure.
   5. To make suggestions and recommendations to you and other site users about goods or services that may interest you or them.
8. We may utilise credit reference agencies' services when tracing.

The use of cookies

Cookies are small files saved to the user's computer hard drive that track, save and store information about the user's interactions and website usage. This allows the website, through its server, to provide the users with a tailored experience within this website.

The website uses cookies to better the user's experience while visiting the website. Where applicable, this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer/device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user's computer/device.

Users are advised that if they wish to deny the use and saving of cookies from this website onto their computer's hard drive, they should take necessary steps within their web browser's security settings to block all cookies from this website and its external serving vendors.

Our website uses tracking software to monitor its visitors to understand better how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer's hard drive to track and monitor your engagement and usage of the website but will not store, save or collect personal information. You can read Google's privacy policy for further information.

External vendors may store other cookies on your computer's hard drive when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.

When we need your consent to use your personal data

Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it. In the day-to-day running of our business, we may use your personal data without asking for your consent because:

• We are entering into and carrying out our obligations under a contract with you
• We need to use your personal data for our own legitimate purposes (such as the administration and management of our business and the improvement of our services) and our doing so will not interfere with your privacy rights
• In exceptional circumstances, we may wish to use your personal data for a different purpose which does require your consent. In these circumstances, we will contact you to explain how we wish to use your data and to ask for your consent. You are not required to give consent just because we ask for it. If you do give consent you can change your mind and withdraw it at a later date.

Please refer to the section on ‘how we use your personal data for marketing’ to read about marketing consent.

Personal data you are legally obliged to provide

You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data, we may be unable to provide our services to you.

Your rights to know what personal data we hold and to control how we use it

You have a legal right to know what personal data we hold about you - this is called the right of subject access. You can exercise this right by sending us a written request anytime. Please mark your letter “Subject Access Request” and send it to us at Unit 4D, Wymondham Business Centre, Norfolk, NR18 9JL or by email to: info@thetracinggroup.co.uk. Any request for information via a Subject Access Request will be processed within 28 days unless your request is highly complex, in which case we are permitted to extend the service period to 90 days. When any such request is made, The Tracing Group have a legal responsibility to ensure they are communicating with the person who is identified by the requested data, as such, we have a requirement to ascertain your identity and may ask for any reasonable documentation to confirm this. You may be charged a reasonable fee if your request is deemed excessive.

You also have rights to:

• Prevent your personal data from being used for marketing purposes (see ‘How we use your personal data for marketing’ for further details).
• Have inaccurate personal data been corrected, blocked or erased?
• Object to decisions being made about you by automated means or to your personal data being used for profiling purposes.
• Object to our using your personal data in ways likely to cause you damage or distress.

You can find full details of your personal data rights on the Information Commissioner’s Office website at www.ico.org.uk.

Automated decision-making and profiling

We do not make use of automated decision-making or profiling.​

When we will share your personal data with others

We share your data with the following people in the day-to-day running of our business:

1. Any business partners, suppliers and sub-contractors we work with to provide you or our clients with services that you or they have requested from us.
2. Analytics and search engine providers that assist us in the improvement and optimisation of our site.
3. We may also share your personal information with third parties on a one-off basis, for example, if:
   1. We sell or buy any business or assets (including our own), in which case we will disclose your personal data to the prospective seller or buyer of such business or assets
   2. We are obliged to disclose or share your personal data to comply with any legal obligation or to protect the rights, property, or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.​

How we keep your personal data safe

We take every care to ensure that your personal data is kept secure. The security measures we take include:

1. Only storing your personal data on secure servers.
2. Ensuring that our staff receive regular data security awareness training.
3. Keeping paper records to a minimum and ensuring that those we do have are stored in locked filing cabinets on our office premises.
4. Maintaining up-to-date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems.
5. Enforcing a strict policy on the use of mobile devices and out-of-office work.

Please remember that you are responsible for keeping your passwords secure. If we have given you (or you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. Please do not share your passwords with anyone.

Unfortunately, sending information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of personal data sent to our website; you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features (some of which are described above) to prevent unauthorised access.

How we use your personal data for marketing

We will add your details to our marketing database if:

1. You enquire about our services
2. You buy our services
3. You have told a third party that you would like them to pass us your contact details so we can send you updates about our services.
4. You have registered an account on our website and have indicated during the sign-up process that you are happy to receive marketing communications.

We may send you marketing communications by email, telephone, or post. You can ask us to only send you marketing communications by particular methods (for example, you may be happy to receive emails from us but not telephone calls) or ask us not to send you any marketing communications at all. You are also provided with the option to “opt-out”.

We may ask you to indicate your marketing preferences when you first register an account on our website. You can check and update your current marketing preferences at any time by calling or emailing us using the details set out in the Who we are and how you can contact us section above.

When we will send your personal data to other countries

Your personal data will not be transferred to or stored at a destination outside the European Economic Area (“EEA”) by us or our subcontractors.

How long we keep your personal data

We only keep your personal data for as long as we actually need it. In practice, this means that we will keep the details that we have been provided by our client for as long as the contract exists.

Please note that we may anonymise or use your personal data for statistical purposes. We keep anonymised and statistical data indefinitely, but we take care to ensure that such data can no longer identify or be connected to any individual.

How you can make a complaint

If you are unhappy with how we have used your personal data, please get in touch with us to discuss this using the contact details set out in the section above.

You are also entitled to make a complaint to the Information Commissioner’s Office, which you can do by visiting www.ico.org.uk. Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.

External links

Although our website only looks to include quality, safe and relevant external links, users are advised to adopt a policy of caution before clicking any external links mentioned throughout this website.

Despite their best efforts, the Tracing Group Limited cannot guarantee or verify the contents of any externally linked website. Users should therefore note that they click on external links at their own risk. This website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.

Social media platforms

Communication, engagement and actions taken through external social media platforms our website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.

Users are advised to use social media platforms wisely and communicate/engage with them with due care and caution about their privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.

This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.

How we keep this policy up to date

The easiest way to check for updates is by looking for the latest version of this policy on our website or you can contact us (see ‘who we are and how to contact us’) to ask us to send you the latest version of our policy.

Policy last updated/issued: 17/03/2022. V3.0