MANAGED IDENTITIES LIMITED
TRUSTD PRIVACY NOTICE
Managed Identities Limited (Company No. 12044881) of Newstead House, Pelham Road, Nottingham, United Kingdom NG5 1AP (“We”, “Us”) is committed to protecting and respecting your privacy. This Privacy Notice (together with any other documents referred to herein) sets out the basis on which the personal data collected from you, or that you provide to Us through the use of the Trustd Platform, will be processed by Us in connection with the verification of you or an organisation with which you are associated (the “Organisation”). Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it.
For the purpose of the General Data Protection Regulation (“GDPR”) the Data Controller is Managed Identities Limited.
YOUR PERSONAL INFORMATION
Information We collect from You
We collect and process some or all of the following types of information from you:
- Information required to verify your identity and any licenses, qualifications or registrations relevant to your position in the Organisation. This includes information provided by you or by another member of the Organisation.
- In particular, We process personal details such as name, email address, address, date of birth qualifications, experience, information relating to your employment history, skills and experience.
- If you contact Us, We may keep a record of that correspondence.
- A record of your progress through any verification that we may conduct.
- A record of any information received by Us in connection with You as a result of our verification checks.
- Details of your visits to Trustd including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to Trustd and the resources that you access.
Information We Collect From Other Sources
The Trustd Platform searches various databases – some publicly available and others not, which may include your personal data, to conduct verification checks. A list of the databases that we may check your personal data against are available on request.
We may receive your personal data from the Organisation or from a third party that requests verification of You or the Organisation.
USES MADE OF YOUR INFORMATION
Lawful basis for processing
Where you have requested the verification on your own behalf, we process your personal data in order to perform a contract with you.
Where the Organisation has requested verification in respect of Your personal data, We rely on legitimate interest as the lawful basis on which We collect and use your personal data. Our legitimate interests are the performance of a contract with the Organisation with which you are associated.
Where a third party (known as a “Verification Requester”) has requested verification in respect of Your personal data, We rely on consent as the lawful basis on which We collect and use your personal data. We may have obtained Your consent directly, or the Organisation may have confirmed that they have obtained Your consent to Us providing your personal data to the Verification Requester.
Purposes of processing
We use information held about you in the following ways:
- To verify your details.
- To communicate with you in respect of the verification process.
- To enhance any information that we receive from you with information obtained from third party data providers.
- To provide your verification to the Organisation and Verification Requesters.
- To help our service providers (such as our data providers) improve their services.
Automated decision making/profiling
We use technology to capture and compile information you have provided to us and to check this against third party databases to verify your identity and other credentials. The process of finding likely matches for your information is automatic, however, any decision as to whether or not your data can be validated is carried out by individuals engaged by us or by third parties on our behalf.
DISCLOSURE OF YOUR INFORMATION
We pass your information to our third party service providers, including our data providers and other service providers, who use it only in accordance with our instructions and as otherwise required by law.
We share certain verification information, which may include your personal information, with Verification Requesters to the extent that you (or the Organisation) have authorised such Verification Requesters to conduct verification on you or the Organisation using the Trustd Platform.
HOW WE STORE YOUR PERSONAL DATA
We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
Unfortunately, the transmission of 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 your data transmitted through any online means, therefore any transmission remains at your own risk.
Where We store your personal data
Where we store your personal data in our own systems, it is stored in the United Kingdom or within the European Economic Area ("EEA").
The data that We collect from you and process using the Trustd Platform may be transferred to, and stored at, a destination outside the United Kingdom or the European Economic Area ("EEA"). In such event We ensure that appropriate protection of your personal data is in place prior to such transfer, which may include data processor agreements designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.
If you would like further information please contact Us (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom or EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
How long we keep your personal data
We will hold all the data for so long as you or the Organisation that you’re associated with are registered to use Our services and for a period of 7 years after such registration is deleted or expires.
Your personal information will be deleted on one of the following occurrences:
- deletion of your personal information by you (or by the Organisation); or
- receipt of a written request by you (or another person engaged by the Customer) to us.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal data and to certain other supplementary information that this Privacy Notice is already designed to address
- require Us to correct any mistakes in your information which We hold
- require the erasure of personal data concerning you in certain situations
- receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal data concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal data
- otherwise restrict our processing of your personal data in certain circumstances
- claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- contact us using our Contact details below
- let Us have enough information to identify you,
- let Us have proof of your identity and address, and
- let Us know the information to which your request relates.
HOW TO COMPLAIN
We hope that We can resolve any query or concern you raise about Our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
All questions, comments and requests regarding this Privacy Notice should be addressed to firstname.lastname@example.org.