We are committed to protecting and respecting your privacy. Everyone has rights with regard to the way in which their personal data is handled. During the course of our activities we will collect, store and process personal data about our customers, suppliers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

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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 UK data protection laws, where we are not a data processor, the data controller is TruPro EA of 145 High Street, Sevenoaks TN13 1XJ.

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Data Protection Principles

When processing your information, we must comply with the six enforceable principles of good practice. These provide that your personal data must be:

• Processed lawfully, fairly and in a transparent manner,

• Processed for specified, explicit and legitimate purposes,

• Adequate, relevant and limited to what is necessary,

• Accurate and kept up-to-date,

• Kept for no longer than is necessary, and

• Processed in a manner than ensures appropriate security.

 

Information You Give To Us

You may give us information such as your

• Name,

• Address,

• Email Address,

• Phone Number,

• Profession.

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We may use the information you give to us for a number of different purposes. For each purpose, we are required to confirm the ‘legal basis’ (that allows us to use your information, as follows:

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• To perform the services that you or your Employer have requested from us.

It will be necessary for our legitimate business interests, namely for the performance of a contract entered into between us and your Employer or any other relevant data controller

• To notify you about changes to the services that we are providing to you.

It will be necessary for our legitimate business interests to ensure you are aware of the latest developments in relation to the services we are providing to you, your Employer or any other relevant data controller.

• To provide with information about our services that you request from us

We will only do this if you give us your consent by some specific, informed and unambiguous method.

Information We Collect About You From Other Sources

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When you visit our portal, we may collect information about you such as the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.

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We may also collect information about you by using customer feedback software.

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We may use the information we collect about you for a number of different purposes. For each purpose, we are required to confirm the ‘legal basis’ that allows us to use your information, as follows:

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• Personalising and tailoring your experience on our website

Because you have consented through our Cookie Policy on our website.

• To improve the delivery of our services.

It will be necessary for our legitimate business interests to improve and evolve our services to you or your Employer.

 

You can change the settings on your internet browser to restrict the amount of information that we can collect when you visit our portal. If you do not allow us to collect this information, then we may be unable to offer you the best experience possible when accessing and using our portal.

 

‘Special Category’ Data

During the course of dealing with you, it is highly unlikely that we will collect information about you relating to your health. This is most likely to occur, for example, if you have an accident in the work place.

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Disclosure Of Your Information

You agree that we have the right to share your personal information with:

• HMRC, Health and Safety Executive and Information Commissioners Office

• Our auditors and quality assurance assessors;

• Selected third parties including:

  • Your Employer, or any other relevant data controller,

  • Business partners, customers, suppliers and sub-contractors to the extent we reasonably consider that it is in your best interests for us to do so, or it is necessary for our legitimate business interests,

  • Dropbox which we may be utilised to collaborate on documents and information,

  • Google Analytics that assist us in the improvement and optimisation of our site.

• We will disclose your personal information to third parties:

  • in the event that we enter into negotiations to sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;

  • If TruPro EA or substantially all of its assets are acquired by a third party, in which case personal data held by it about you will be one of the assets transferred to the third party; or

  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any contract between you or us, or our website terms of use, or to protect the rights, property, or safety of TruPro EA, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 

Where We Store Your Personal Data

All information you provide to us is stored on our secure servers in the United Kingdom. We will take all steps reasonably necessary to ensure that your data is treated securely, including taking the following safeguards:

• Physical security to our premises.

• Secure lockable desks and cupboards. Desks and cupboards are kept locked when not in use if they hold confidential information of any kind.

• Methods of disposal. Paper documents are disposed of by shredding in a manner that ensures confidentiality.

• Equipment. Our internal policies require that individual monitors do not show confidential information to passers-by and that users lock or log-off from their computer when it is unattended.

• Hardware, Software and Databases. We use utilise proprietary cyber security software, including Firewall Protection and Vulnerability Scans.

 

Some of the data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom. It may also be processed by personnel operating outside the United Kingdom who work for us, our group companies or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing.

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If you are concerned about the levels of data security in any of those countries, please let us know and we will endeavour to advise what steps will be taken to protect your data when stored overseas.

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 to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

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How Long We Will Store Your Personal Data

The length of time that we will store your data will depend on the ‘legal basis’ for why we are using that data, as follows:

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• Where we use/store your data because it is necessary for us to comply with a legal obligation to which we are subject.

We will use/store your data for as long as it is necessary for us to comply with our legal obligations.

• Where we use/store your data because it is necessary for our legitimate business interests.

We will use/store your data until you ask us to stop. However, if we can demonstrate the reason why we are using/storing your data overrides your interests, rights and freedoms, then we will continue to use and store your data for as long as it is necessary for the performance of the contract between you and us (or, if earlier, we no longer have a legitimate interest in using/storing your data).

• Where we use/store your data because you have given us your specific, informed and unambiguous consent.

We will use/store your data until you ask us to stop

 

Your Rights

You have various legal rights in relation to the information you give us, or which we collect about you, as follows:

• You have a right to access the information we hold about you free-of-charge, together with various information about why and how we are using your information, to whom we may have disclosed that information, from where we originally obtained the information and for how long we will use your information.

• You have the right to ask us to rectify any information we hold about you that is inaccurate or incomplete.

• You have the right to ask us to erase the information we hold about you (the ‘right to be forgotten’). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain why not.

• You have the right to ask us to stop using your information where: (i) the information we hold about you is inaccurate; (ii) we are unlawfully using your information; (iii) we no longer need to use the information; or (iv) we do not have a legitimate reason to use the information. Please note that we may continue to store your information or use your information for the purpose of legal proceedings or for protecting the rights of any other person.

• You have the right to ask us to transmit the information we hold about you to another person or company in a structured, commonly-used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.

• Where we use/store your information because it is necessary for our legitimate business interests, you have the right to object to us using/storing your information. We will stop using/storing your Walk the Walk Solutions Limited Privacy Policy 6 information unless we can demonstrate why we believe we have a legitimate business interest which overrides your interests, rights and freedoms.

• Where we use/store your data because you have given us your specific, informed and unambiguous consent, you have the right to withdraw your consent at any time.

• You have the right to object to us using/storing your information for direct marketing purposes.

• If you wish to exercise any of your legal rights, please contact Amanda Williams by writing to the address at the top of this policy, or by emailing us at info@truproea.co.uk

• You also have the right, at any time, to lodge a complaint with the Information Commissioner’s Office if you believe we are not complying with the laws and regulations relating to the use/storage of the information you give us, or that we collect about you.

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Automated Decision-Making

We do not use automated decision-making processes.

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Changes To Our Policy

Any changes we make to our policy in the future will be posted on our portal and, where appropriate, notified to you by email or via social media. Please check our portal frequently to see any updates or changes to our policy.

 

Contact

Questions, comments and requests regarding this policy are welcomed and should be addressed to Amanda Williams by writing to the address at the top of this policy or by emailing us at info@truproea.co.uk.