Trustd Privacy Notice

MANAGED IDENTITIES LIMITED

TRUSTD PRIVACY NOTICE

Managed Identities Limited (Company No. 12044881) of Newstead House, Pelham Road, Nottingham, United Kingdom NG5 1AP (“We”, “Us”, “Our”) 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 Our Trustd Platform, will be processed by Us in connection with theverification of you including on behalf of an organisation with which you are associated (the “Organisation”) or a third party who requests to verify your documents (a “Verification Requester”). 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 isManaged Identities Limited.

If you are an individual (data subject) regarding whom verification is requested by an Organisation or Verification Requestor, this privacy notice is addressed to you.

YOUR PERSONAL INFORMATION

Information We collect from you, your Organisation or a Verification Requester

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. 
• Personal details such as name, email address, address, date of birth, visa and immigration status, qualifications, experience, information relating to your employment history, skills and experience, driving licence details, driver’s insurance and vehicle details.

• 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:

Database	Data Collected
FullCircl	Company description and directors details
GBG – IDScan API	Live facial recognition checks
GBG – ID3 Global API	Driver’s date of birth, driving licence details, entitlement to drive
DVLA – MOT History API	MOT history of driver’s vehicle
DVLA ADD	Driver’s driving licence points
DBS	Criminal record checks

We may also receive your personal data from the Organisation or from a Verification Requester.

USES MADE OF YOUR INFORMATION

Lawful basis for processing

Where you have requested the verification on your own behalf, which also indicates your explicit consent, We additionally 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 do so to perform a contract with the Organisation.They will have provided you with their own basis for processing your data within their relevant policy document which will have indicated for instance that it is in the public interest for the prevention of dishonesty for them to request Us to provide verification.

Where a Verification Requester has requested verification in respect of your personal data, We rely on performance of a contractas the lawful basis on which We collect and use your personal data. The Verification Requester will have provided you with their own basis for processing your data within their relevant policy document which will have indicated for instance that it is in the public interest for the prevention of dishonesty for them to request verification. 

Where We search for your personal data on various databases, We rely on performance of a contract as the lawful basis on which We collect and use your personal data. 

Where We collect details of your criminal records via DBS checks, We rely on legitimate interest as the lawful basis on which We collect and use your personal data in order to protect the public against dishonesty.

We rely on performance of a contract to share with our affiliate Transport Exchange Group any data and verification reports based on information provided by you, your Organisation or a Verification Requester as part of an application for membership with Transport Exchange Group. The information we provide to them enables them to provide you and / or the Organisation or the Verification Requestor with their services. Transport Exchange Group will process such information in accordance with their privacy policy which is available here [insert link to TEG privacy policy].

We may send you newsletters and promotional materials from time to time with regard to similar services because you are our customer or service user. You can opt out of these at any time via the “unsubscribe” link or contact address provided in each promotional email or newsletter.

Should We ever share your information with third party advertisers, We will ask for your consent beforehand, which would be the lawful basis. You do not have to agree and if you do, you may change your mind and opt out at a later date by means set out in such third party’s privacy policy.

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.

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, and results will be passed to [our external / the Organisation’s/ the Verification Requestor’s compliance officers to decide whether your application can be validated.

DISCLOSURE OF YOUR INFORMATION

We share certain verification information, which includes your personal information with Verification Requesters, who use it to engage your services via Transport Exchange Group.

We share certain verification information, which includes your personal information with your Organisation to determine whether they want to engage your services.

We may also disclose your personal data to third parties:

• in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets;
• if We or substantially all of Our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets;
• 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 Our Terms and Conditions and other agreements;
• to protect Our rights, property, or safety or that of our affiliated entities and Our users and any third party We interact with the to provide the Platforms;
• in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be of interest to you.

HOW WE STORE YOUR PERSONAL DATA

Security

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

We store your personal data in AWS servers located in Ireland (EU-west-1).

Where the data that We collect from you and process using the TrustdPlatform 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 includes data processor agreements approved by the European Commission or the (UK) Information Commissioner’s Office (as appropriate) 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.

KEEPING YOUR PERSONAL DATA UP TO DATE

It is important that the personal data we hold about you is accurate and current. 

If your personal details change you should update them by accessing the relevant page on Trustd,  If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.

HOW LONG WE KEEP YOUR PERSONAL DATA

We will hold all the data for so long as you or the Organisationthat you’re associated with, or a Verification Requester is registered to use Our services and for a period of 7 years after such registration is deleted or expires.

We may store your personal data provided to Us for an additional period as long as it is reasonably necessary taking into consideration Our need to resolve any disputes, enforce our rights and/or respond to queries.

If you have any questions about our data retention policy, please contact us.

YOUR RIGHTS

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, including where you no longer wish to be verified by TEG. 
• 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.

Cookies and IP addresses

We may collect information about your mobile phone, computer or other device from which you access the Platforms including where available your IP address, operating system, screen size and resolution, and browser type, for systems administration and to report aggregate information to third parties affiliates. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.

A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

The cookies We use include:

• Analytical cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around the Trustd Platform when they are using it. This helps Us to improve the way our Trustd Platform works, for example, by ensuring that users are finding what they are looking for easily.

• Strictly necessary cookies. These are cookies that are required for the operation of our Trustd Platform. They include, for example, cookies that enable you to log into secure areas of our Trustd Platform, or cookies that let us know you have accepted this privacy policy.
• Functionality cookies. These are used to recognise you when you return to our Trustd Platform. This enables Us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our Trustd Platform, the pages you have visited and the links you have followed to our affiliates websites. We will use this information to make our Trustd Platform, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. Please note that third party affiliates may also use cookies, over which We have no control.

More information about the cookies we include and how to manage them can be found here:

• Marketing websites.

• The Trustd platform.

Cookies which are strictly necessary for the core functionality of the Trustd Platform are enabled by default, and set automatically at the point you access the Trustd Platform.

Any cookies which are not strictly necessary for the functioning of the Trustd Platform will not be set unless you expressly consent to them through the cookie banner by clicking “accept”.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Trustd Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Trustd Platform.

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/make-a-complaint/or telephone: [phone].

CONTACT

All questions, comments and requests regarding this Privacy Notice should be addressed to [e-mail].

20 Northdown St, London N1 9BG

This Privacy Notice was last updated on 19th December, 2022