This is the privacy statement of Trax JH Ltd. At Trax JH Ltd we are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you; that you provide us or that we receive from others about you will be processed by us. It includes data that we hold electronically and in paper files.
1 | How and why we process personal data
We will process data to deliver the services Trax JH Ltd are contracted to provide to you; We confirm, when processing data on your behalf, that we will comply with the provisions of all relevant data protection legislation and regulation.
We do not sell, rent or lease any of the personal information collected from you to third parties. We do not use or disclose sensitive personal information, such as race, religion, or political affiliations (in the event that we become aware of any), without your explicit consent.
What personal information we collect
The personal information that we collect will vary depending on which product or service we deliver. These may include (the list is non-exhaustive):
- Personal Identifiable Information (Names, email address, postal information, DOB)
- IP addresses
Where we collect personal information from
- Through formal engagement to provide professional services
- Via our website (General enquiries; mailing list sign ups; questionnaires or surveys; submission of a job application)
Legal bases for processing data
The legal bases for the processing data is under the following paragraphs of the General Data Protection Regulation (GDPR): Article 6 1.(b), the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, and Article 6 1.(f), it is in the legitimate interests of the data controller or a third party.
Our legitimate interest means the interests of our company in conducting and managing our business to enable us to give you the best service and the best and most secure experience. For example, we have an interest in making sure our marketing is relevant to you, so we may process your information to send you marketing that is tailored to your interests. It can also apply to processing that is in your interests as well. Safeguards have been put in place to ensure we achieve the correct balance between both our interests. Where no formal engagement exists, the legal basis for processing personal information is consent provided via our website; or via formal consent at a marketing event.
How we use your personal data
The purposes for which personal information is processed may include any or all of the following (the list is non-exhaustive):
- Deliver services and meet legal responsibilities
- Verify identity where this is required
- Communication by post, email, or telephone
- Understand needs and how they may be met
- Maintain records
- Process financial transactions
Who has access and why?
Data will be held and processed for the purpose of providing the service that we are contracted under our Terms of Engagement; or where you have provided your information via our website or at a marketing event.
Only those staff who have a legitimate need to access data will be authorised to do so. We may also be required to share your data with some third parties. For example, if we have a problem with some software it may be necessary to provide the software supplier with specific data. However, where this is necessary we only disclose the information that is required to resolve the issue, and we have a contract in place that requires them to keep your information secure and not to use for their own purposes. Examples of third parties could include (this list is non-exhaustive):
- Software providers
- Website hosting provider
- Electronic communication providers
How long we retain your personal data
To meet our legal data protection and privacy obligations, we only hold on to your information for as long as we need it and for the purposes we acquired it for in the first place.
Where we have a formal engagement, we will collect personal data and retain for as long as required under current legislation.
Where you have submitted your data via our website or other marketing channels, we shall keep your personal information on our database, subject to an individual’s right to unsubscribe or be forgotten at any time. Please see the Your Rights section below.
2 | Your Rights
You have a number of rights under GDPR:
Right of Access
You have the right, subject to a number of exceptions, to know what information we hold about you.
Right to Rectification
You have the right to have any information we hold about you corrected if inaccurate or incomplete.
Right to Erasure
You have the right to ask us to delete personal information about you where:
- You consider that we no longer require the information for the purposes for which it was obtained.
- We are using that information with your consent and you have withdrawn your consent – see Withdrawing consent.
- You have validly objected to our use of your personal information – see Right to Object.
- Our use of your personal information is contrary to law or our other legal obligations.
Right to Object
You have the right to object our processing of your personal data on the basis of legitimate interest, for direct marketing.
We will stop processing your data on the basis of legitimate interest unless there are compelling legitimate grounds for us to continue.
We will stop any processing of your data for direct marketing as soon as we receive an objection.
Right to Restrict Processing
You have the right to restrict processing of your data in certain circumstances, such as when there is a question over the way in which we are using it. Right to Data Portability You have the right to obtain and reuse your personal data for your own purposes, subject to our terms and conditions Automatic Processing We will not make any decision regarding you by purely automated means. Withdrawing consent using your information Where we use your personal information with your consent you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given. Please contact us by emailing email@example.com if you wish to exercise any of these rights.
We keep this privacy statement under regular review and will place any updates on this page.
Paper copies of the privacy statement may also be obtained from Donna Smith Trax JH Ltd Unit 66 Mochdre Enterprise Park Newtown Powys SY16 4LE firstname.lastname@example.org
This privacy statement was last updated on 10/05/2018.
Contact information and further advice
We seek to resolve directly all complaints about how we handle personal information, but you also have the right to lodge a complaint with the Information Commissioner’s Office,