Here at Trusted Data Solutions UK Limited (“Trusted Data Solutions UK Ltd, TDS or “we”, “us”) we pride ourselves on our customer service. This includes how we handle or use your personal information, and always provide options that ensure your personal information is secure.
1. POLICY OVERVIEW
1.1 Scope of this policy
1.2 Policy updates
2. ABOUT US
2.1 Who are we?
We are Trusted Data Solutions Limited, a company incorporated in England and Wales under company number 08332095. You’ll find our registered address below.
2.2 Who’s the Data Controller?
2.3 How to contact us
FAO: The Data Protection Officer: Kathryn Richards
Address: Trusted Data Solutions UK Ltd, 7 Charnwood Court, Heol Billingsley, Nantgarw, Cardiff CF15 7QZ
3. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
3.1 What types of information do we collect about you?
The type of information we collect about you depends on the nature of your interactions with us. Depending on the circumstances, we collect any of the following:
- Details about you as a Customer: Your name, email address, address, telephone number
- Details about you as a Supplier; Name, address, email address and telephone number
- Details about you as a Subscriber; Name, address, email address and telephone number
- Your interactions with us. Information about your interactions or conversations with us and our people, including when you make enquiries, comments, complaints or submit feedback to us (whether formally via email or simply verbally to our people);
- Job applications. If you apply for a job with us, your CV, work history, educational details and the role you’re applying for; and
- Your use of our systems and services. Details of the way in which you use our site, directly with our office and/or social media pages (please see the cookies section below for further details).
4. HOW WE COLLECT INFORMATION ABOUT YOU
- How we collect information about you will depend on how you interact with us and what services you arrange with us. Depending on the circumstances, we collect information in any of the following ways:
- When you browse our site;
- When you contact us as a customer to engage/employ us;
- When you fill in part of the booking information on our site but do not complete the booking;
- When you apply for a job with us by email or via the site;
- When you contact us via our office, social media, post, email or instant messenger;
- When you request a brochure, sign up to receive email updates, participate in any of our competitions, promotions (for example via any social media channels, email or our site), surveys or market research;
- When you make a complaint via a third party; and/or
- When you attend any events we host or participate in
5. IN WHAT CIRCUMSTANCES DO WE NEED TO COLLECT YOUR SENSITIVE INFORMATION?
In certain circumstances, we will collect information that is deemed sensitive. This is most likely to include:
We seek to limit any sensitive personal data that we collect and, unless we have other specific lawful reasons to use this information (such as in an emergency situation), we will ask for your consent to collect it.
6. HOW WE USE YOUR INFORMATION
6.1 For what purposes do we use your information?
We’ll use your information for a variety of different purposes, some of which will depend on the services that you engage us for. This includes:
- To manage your requirements. We will use your information to provide you with any services that you request or purchase from us. This includes delivering your goods (on the basis of performing our contract with you), and providing you with any special assistance (where you provide your consent);
- To send you service communications and support services. We will use your information to send you any communications relevant to the services you’ve requested or purchased from us. This includes sending you an email to notify you of changes to your requests or providing you with a resolution. We will also provide you with customer service and support, deal with your enquiries, scheduling changes, complaints, comments or observations shared with us (on the basis of performing our contract with you or on the basis of our legitimate interests to provide you with customer service);
- To send you marketing communications. We will use your information to keep you up to date with the latest news, events, offers, sales, brochures, promotions and competitions that we think might be of interest or relevant to you (either on the basis of your consent where we have requested it, or our legitimate interests to provide you with marketing communications where we may lawfully do so) (please see the “MARKETING” section below for more information);
- To personalise your customer experience. We use your information to provide you with a more personalised service. For example tailoring the communications that we send to you with your preferred products and services);
- To improve our customer service. We may record calls to our office and/or monitor calls for the purposes of improving our customer service, ensure quality assurance, training, security and for general business purposes (on the basis of our legitimate interest in improving our customer service);
- To process your job applications. We will use your information to process any job applications that you submit to us, whether directly or via an agent or recruiter (speculatively or in response to any ad) (on the basis of our legitimate interest to recruit new employees or contractors);
- To optimise our website. If you use our website, we will use your information to ensure that the content from our website are presented in an effective manner for you and your device, to provide you with access to our website in a manner that is effective, convenient and optimal, and to provide you with content that is relevant to you, using site analytics and research and in certain circumstances combining that with other information we know about you (on the basis of our legitimate interests to operate and present an effective and convenient website to our website users);
- To ensure security and protect our business interests. In certain circumstances, we use your information to ensure the security of our services, buildings, and people, including to protect against, investigate and deter fraud, unauthorised or illegal activities, systems testing, maintenance and development (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so);
- To conduct research. We use your information to carry out aggregated and anonymised research about general engagement with our services and systems, or if you choose to participate in customer surveys, (on the basis of our legitimate interests to improve our products, services and customer service); and
- To comply with our legal obligations. In certain circumstances, we will need to use your information to comply with our legal obligations, for example to comply with any court orders or subpoenas (on the basis of our legitimate interests to comply with a legal obligation).
6.2 On what grounds will we process your information?
We will use your information for the purposes listed above, either:
- For the performance of your contract with us and the provision of our services to you;
- To comply with a legal obligation we have;
- For our legitimate interests (we explain what we mean by this below);
- To protect your vital interests;
- With your consent (please click here to see your rights in relation to consent that you provide to us);
- For establishing, exercising or defending legal claims; and
- For reasons of substantial public interest.
6.3 What do we mean by “legitimate interests”?
As outlined above, in certain circumstances we may use your personal information to pursue legitimate interests of our own or those of third parties, but this is provided your interests and fundamental rights do not override those interests. By “legitimate interests” we mean our interests in conducting and managing our business activities and to ensure that we are guaranteeing the best service and experience for you and our customers. This involves:
- Using your information to protect you against fraud when you transact on our site, and to ensure that our systems and sites are secure;
- Determining the effectiveness of our site / tools / services and improving the security and optimisation of our network, sites and services;
- Confirming information that you provide to us in a CV or application, by reference to past employers and/or publicly available employment or business profiles;
- Personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you, such as sending you marketing and serving you with advertising that is relevant and likely to be of interest to you; and/or
- Detecting, monitoring and preventing fraud or other unlawful acts, and operating a safe and lawful business. Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours, and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as when we have your consent, or we have a legal obligation to use your information in that way). If you have any concerns about our processing please refer to details of “YOUR RIGHTS” section below.
As we outline in “YOUR RIGHTS” section below, from 25 May 2018 you will have the right to object to us using your information for our legitimate interests. However, please keep in mind that your objection to this sort of processing may affect our ability to carry out the tasks that we have set out above.
7. WHO WE SHARE YOUR INFORMATION WITH
7.1 In connection with the purposes and on the lawful grounds described above, we share your personal information with the following third parties:
- Third party suppliers that we work with to provide your booking and our other services to you. We may share your information with third party suppliers that provide us with services in connection the provision of our services to you. This includes for example: Our Parent Company;
- Courts or advisors. We share your information with other third parties (including legal, accountants or other advisors, regulatory authorities, courts and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law; and
Where we do share your information with third parties, we will require them to maintain appropriate security to protect your information from unauthorised access or processing, unless we have no ability to do so (for example, where we are sharing information with border agencies or enforcement authorities).
8.1 When you’ll hear from us
We will keep you up to date with our latest offers, partnerships, sales, promotions that we think might be of interest / relevant to you if you have indicated that you are happy to receive marketing communications from us – that is, if you have:
- Purchased services l from us and have not told us that you don’t want to hear from us; or
- Signed up to receive marketing communications from us and have not later told us that you don’t want to hear from us.
8.2 Opting out of or withdrawing your consent in relation to marketing
If you no longer want to hear from us, you can opt out or unsubscribe by:
- Following the “unsubscribe” link contained in any marketing communications that you receive from us;
- By email to: firstname.lastname@example.org
- By phone on: +44 20 3794 7600
8.3 Third parties and marketing
We might rely on third parties to help us manage our marketing communications, but we won’t share your information with any third parties for their marketing purposes unless you agree to our doing so.
9. OUR WEBSITE AND COOKIES
9.1 What we collect when you interact with our website.
Trusted Data Solutions collects personally identifiable information, such as your e-mail address, name, home or work address or telephone number. Trusted Data Solutions also collects anonymous demographic information, which is not unique to you, such as your postcode, age, gender, preferences, interests and favourites. There is also information about your computer hardware and software that is automatically collected by Trusted Data Solutions. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used by Trusted Data Solutions for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Trusted Data Solutions website. Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through Trusted Data Solutions public message boards, this information may be collected and used by others. Note: Trusted Data Solutions does not read any of your private online communications. Trusted Data Solutions encourages you to review the privacy statements of Web sites you choose to link to from Trusted Data Solutions so that you can understand how those Web sites collect, use and share your information. Trusted Data Solutions is not responsible for the privacy statements or other content on websites outside of the Trusted Data Solutions and Trusted Data Solutions family of website
9.2 What do we mean by “cookies”?
The Trusted Data Solutions website use "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalise Trusted Data Solutions pages, or register with Trusted Data Solutions site or services, a cookie helps Trusted Data Solutions to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Trusted Data Solutions website, the information you previously provided can be retrieved, so you can easily use the Trusted Data Solutions features that you customised. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Trusted Data Solutions services or websites you visit.
To learn more about cookies and how they are used, visit http://www.allaboutcookies.org/
10. YOUR RIGHTS
10.1 Overview of your rights
You have certain rights in respect of the personal information that we hold about you, including:
- The right to ask us not to process your information for marketing purposes;
- The right to request access to the information that we hold about you;
- The right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
- In certain circumstances, the right to ask us to stop using information about you; and the right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/) or the relevant authority in your country of work or residence.
Please note that we reserve the right to retain certain information for our own record-keeping (for example, to ensure that you do not receive marketing communications that you have opted-out of receiving) and to defend ourselves against any claims. We may also need to send you service-related communications relating to the services that we provide to you even when you have requested not to receive marketing communications.
10.2 Some upcoming new rights…
From 25 May 2018, you will have certain additional rights in respect of the information that we hold about you, including:
- The right to withdraw consent that you have provided to us to use your personal information (refer to paragraph 6 to see when we are relying on your consent and for further information on your rights connected with consent please click here);
- The right to object to our using your information on the basis of our legitimate interests (see paragraph 6 above to see when we are relying on our legitimate interests) (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground; and
- The right to receive a copy of any information we hold about you (or request that we transfer this information to another service provider) in a structured, commonly-used, machine-readable format, in certain circumstances; and
- The right to ask us to limit or cease processing or erase information we hold about you in certain circumstances.
10.3 How to exercise your rights
- Contacting us. You can exercise your rights by contacting us using the details in the ‘GET IN TOUCH’ section above, or by checking the applicable boxes on forms that we use to collect your information, or to tell us that you don’t want to participate in marketing.
- If you wish to remove your information from our marketing circulation lists, which include receiving marketing emails, you can unsubscribe by scrolling to the bottom of the email and clicking the ‘unsubscribe’ link.
- We will comply with your requests unless we have a lawful reason not to do so.
10.4 What we need from you to process your requests
Please be aware that we may need you to provide additional information (such as to confirm your identity and/or to confirm what information you wish to access) in order to process your request.
11. WHERE IS YOUR INFORMATION?
11.1 Our service providers and suppliers
We are based within the European Economic Area (EEA). However, in certain circumstances information that we collect about you will be sent to and held by us in countries outside of the EEA where we work with suppliers and service providers that are either based outside of the EEA or have servers based outside of the EEA.
Trusted Data Solutions secures your personal information from unauthorised access, use or disclosure. Trusted Data Solutions secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use or disclosure. When personal information (such as a credit card number) is transmitted to other Web sites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.
11.2 Destination territories
As we outline above, in certain circumstances, we are required to share information about you with immigration or other government authorities before we can deliver you to your destination.
12. HOW WE LOOK AFTER YOUR INFORMATION
12.1 Our security measures
We strive to constantly keep our security practices under review to make sure that we’re keeping your information as safe as possible. We use a variety of different technical and operational security measures to protect your information against unauthorised access or unlawful use. For example we:
- Ensure the physical security of our offices, warehouses and other sites;
- Ensure the physical and digital security of our equipment, devices and systems by mandating appropriate password protection, encryption and access restrictions;
- Are abiding by ISO27001, meaning that we apply certain high standards of.
- Ensure appropriate access controls so that access to your information is only granted to those of our people that need to use it in the course of their work;
- Carry out regular penetration testing of our systems and reviews of our software; and
- Maintain internal policies and deliver data protection and confidentiality training to make sure our people also understand their responsibilities in looking after your information and commit to taking appropriate measures to enforce these responsibilities.
12.2 How you can help ensure the security of your information
You can also play a part in helping to keep your information safe. Here are a few useful starting points:
- Choose strong passwords and change them regularly;
- Keep your passwords confidential, and avoid sharing them with anyone else or using your password for multiple accounts;
- Inform us immediately if you know or suspect that your password/encryption key has been compromised or if someone may have accessed it;
- Keep your devices protected by ensuring that you’re using the latest version of your operating system and have suitable anti-virus software, if applicable; and
- Be alert to any fraudulent emails that may appear to be from us, but aren’t. Any emails that we send will come from [*]@tdsllc.co.uk or tdsllc.com.
12.3 Links to other sites and resources
13. HOW LONG WE KEEP YOUR INFORMATION FOR
We keep your information for as long as is reasonably necessary to enable us to provide you with the services that you have requested from us, to comply with any legal obligations that require us to keep information, or for as long as we reasonably require for our legitimate interests, including for example for the purposes of exercising our legal rights or defending ourselves against claims. We operate a data retention policy and look to find ways to reduce the amount of information we hold and the length of time that we need to keep it. For example:
- We try to adopt a paperless approach wherever possible and securely destroy any paper correspondence we receive on a regular basis unless we are required to retain it for evidential or legal purposes;
- We retain a suppression list of individuals who no longer wish to be contacted by us indefinitely. We need to keep this information to comply with their wishes not to contact them;
- We retain any unsuccessful CV’s or job applications that we receive for a period of up to 2 years in case we think you might be suited to another opportunity that becomes available in the near future
14. NOT HAPPY?
However, if you’d still like to make a formal complaint or have concerns regarding the ways in which we use your information, you can contact the Information Commissioner’s Office (also known as the “ICO”). The ICO is an independent authority and the UK’s supervisory authority for information rights.
You can register your concerns on the ICO site by clicking here.