Privacy and Fair Processing policy v1.0
TraceGenie and Locate GB are websites wholly owned by 1st Locate (UK) Limited
Registered Office: Town Centre House, 1st Floor West Wing, The Merrion Centre, Leeds, West Yorkshire, LS2 8LY
Data protection Registration no. Z6791585
The Websites in scope
Our websites are all hosted within the European Union and all Personal Identifiable Information is hosted on servers held within the United Kingdom.
Our information security management system (ISMS) is certified to ISO/IEC 27001. Our UK business is also Cyber Essentials certified and all our payment card processing is in compliance with PCI DSS.
What information we collect and how
The information we collect via the Website may include.
Any personal details you knowingly provide us with through forms and our email, such as name, address, telephone number etc.
Definitions used in this policy
References to ‘we’, ‘us’ and ‘our’ are to 1st Locate UK Limited.
References to ‘our Website/s’ or ‘the Website/s’ or ‘the service’ are to any website owned and operated by 1st Locate UK Limited.
References to ‘you/your/yours’ are to you as a user of the service.
References to ‘personal information’ relates to information which can be used to identify a living individual
Our commitment to data security and data protection
1st Locate is committed to protecting the rights and privacy of data subjects and ensuring all data is processed in line with the requirements of The General Data Protection Regulation 2016/679 (also known as ‘GDPR’).
What information do we collect and how do we collect it?
The information we collect via the Website may include.
• Any personal details you knowingly provide us with through forms and our email. These are,
o telephone number
o email address
• In order to effectively process credit or debit card transactions it may be necessary for ourselves, our bank or card processing agency to verify your personal details for authorisation outside the European Economic Area (EEA). Such information will not be transferred out of the EEA for any other purpose.
• Your preferences and use of email updates, recorded by emails we send you (if you select to receive email updates on products and offers).
Your IP Address, this is a string of numbers unique to your computer that is recorded by our web server when you request any page or component on the Website. This information is used to monitor your usage of the Website.
What we do with your information
Any personal information we collect from this website will be used in accordance with the General Data Protection Regulation 2016/679 and other applicable laws. The details we collect will be used:
• To process your order, to provide after sales service (we may pass your details to another organisation to supply/deliver products or services you have purchased and/or to provide after-sales service); this is for the purposes of directly servicing your order and account relationship with us. Your details will not be passed to other organisations for marketing or email purposes.
• We may need to pass the information we collect to other companies for administrative purposes. We may use third parties to carry out certain activities, such as processing and sorting data, monitoring how customers use the Website and issuing our e-mails for us. Third parties will not be allowed to use your personal information for their own purposes.
What is the Legal Basis for processing the information?
We are required to advise you of the legal basis for processing your data.
Information held on our Websites
The legal basis is Explicit Consent. This means that the individual whom the personal data is about has consented to the processing. Please see the information below regarding the Electoral Register for further details about this.
Consumers who access our websites and use our services
The legal basis is Performance of Obligations. The processing is necessary:
• in relation to a contract which the individual has entered into; or
• because the individual has asked for something to be done so they can enter into a contract.
To process your order, to provide after sales service (we may pass your details to another organisation to supply/deliver products or services you have purchased and/or to provide after-sales service); this is for the purposes of directly servicing your order and account relationship with us. Your details will not be passed to other organisations for marketing or email purposes.
In order to use our service, you must accept the legal process for processing and by making a purchase, you consent to this.
The types of Personal Information displayed on our websites
Electoral roll data
The electoral roll consists of approximately 45 million persons registered to vote in the UK. The roll is collated through August to October each year and published in December. We purchase a copy of the register each year but only for those persons who have given consent to appear via their electoral roll registration card
The open edited register is an extract of the electoral register and is publicly available for examination.
The roll is split into 2 registers:
• 1/ The Full Electoral Roll. This is for use by organisations such as Credit Reference Agencies to validate credit applications and for identity verification. We do not have access to the Full Electoral Register from 2002 onwards.
• 2/. Edited electoral roll. This is a version of the electoral roll that is available for sale to commercial organisations. The persons recorded on this register have decided not to exercise their right to opt out of publication on this register. This is the version of the electoral roll that is used by 1st Locate. We do not have access to the full version. The edited electoral roll contains around 70% of the persons recorded on the full unedited roll. These persons have consented to their details appearing on the edited electoral roll.. Like many other organisations, we purchase the edited consented version of the electoral roll each year. Electronic versions of the edited roll are usually available around April/May each year.
• It can be bought by any person, company or organisation.
The personal data in the register must always be processed in line with the obligations of current data protection legislation.
A person's name and address will be included in the open edited register if the option to be included is selected on the voter registration card, thereby giving consent to be included on the edited register.
Opting out of the open edited register does not affect your right to vote but may prevent some organisations being able to confirm your details.
Legitimate uses of the edited register: -
To prevent yourself from being published on future edited electoral rolls you should contact the Electoral Registration department of your local council or follow the guidance at AboutMyVote
• You have the right to request a copy of any information that we currently hold about you.
• In order to receive such information please write to us and include your contact details including address. We do not charge for any Subject Access Requests
• Subject Access Request.
Data Protection and Privacy Manager
1st Locate UK Limited
Town Centre House, Leeds LS2 8LY
• We will aim to respond within 30 days of receiving the request. If we need more time to process the request [for more complex requests for example], we will inform you.
Requests to remove data from our public search engine results.
• The records we hold relate to information available in the public domain and arise from consented records registered on the edited electoral roll, births, deaths, marriages and company directorships.
• Although not obliged to do so, as by definition of appearing on the edited register, a person's consent has been given for processing of such data, we will remove a persons details from our public search engine results upon completion of this search engine data removal request
• Other requests for removal of entries to our private subscription databases must be made under Section 10 of the Data Protection Act and will be processed and considered in accordance with guidance received from the Information Commissioners Office.
• We will only accept a written request for data removal made under section 10 of the Data Protection Act and we may take steps to verify the identity of the person making the request.
• We will not accept an email request for removal of entries. Requests should be made in writing and detail the reasons why removal is required.
• All parties wishing to be included and considered within a Section 10 notice should sign the request and we may take steps to verify all identities in this process.
• We will consider each case individually within the timelines prescribed by the Information Commissioners Office and inform you of the outcome - either our agreement or refusal for removal.
• Please do not assume we will hold records on you. Unless you have opted in - i.e. you have provided your consent to appear on the edited electoral roll by selecting this option on your voter registration card issued by your local council electoral registration department, then, we will not hold a record of your electoral entry.
• In order to prevent yourself appearing on the edited electoral roll in future years, please contact your local council electoral registration department.
There has been some criticism of the open edited register being made available to direct marketing firms relating to junk direct mail.
Remember, there is additional legislation in place to protect you from this and registration at the Mailing Preference Service will prevent organisations from being able to send you unsolicited mailings.
There is a similar scheme in place to prevent unsolicited telephone calls - Telephone preference service
Withdrawing access to the open edited electoral register will cause difficulties for many organisations and companies and ultimately the consumer.
We believe there is sufficient legislation in place to ensure appropriate usage of the edited register.
Yours rights under GDPR
• The right to rectification
When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.
• The right to erasure (the ‘right to be forgotten’)
Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
• The right to restrict processing
You may ask us to stop processing your personal data. We will still hold the data, but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:
a) The accuracy of the personal data is contested
b) Processing of the personal data is unlawful
c) We no longer need the personal data for processing but the personal data is required for part of a legal process
d) The right to object has been exercised and processing is restricted pending a decision on the status of the processing
• The right to data portability
You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.
• The right to object
You have the right to object to our processing of your data where
o Processing is based on legitimate interest;
o Processing is for the purpose of direct marketing;
o Processing is for the purposes of scientific or historic research;
o Processing involves automated decision-making and profiling.
All of our people search and tracing activities are undertaken in full compliance with the relevant legislation and we are full members of the Credit Services Association. Additionally, we hold a comprehensive Data Protection registration and are Authorised and regulated by the Financial Conduct Authority for accounts formed under the Consumer Credit Act 1974 (amended 2006)
Requests to remove data from our public search engine results.
The records we hold relate to information available in the public domain and arise from consented records registered on the edited electoral roll, births, deaths, marriages and company directorships.
Although not obliged to do so, as by definition of appearing on the edited register, a person's consent has been given for processing of such data, we will remove a persons details from our public search engine results upon completion of this search engine data removal request
The Data Protection Co-ordinator
Town Centre House, 1st Floor West Wing, The Merrion Centre, Leeds, West Yorkshire, LS2 8LY
Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.
Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority within the European Union. For the United Kingdom, this is the Information Commissioner’s Office (ICO), who is also our lead supervisory authority. Its contact information can be found at https://ico.org.uk/global/contact-us/.
All of our
people search and tracing activities are undertaken in
full compliance with the relevant legislation and we are
full members of the Credit Services Association.
Additionally, we hold a comprehensive Data Protection
Authorised and regulated by the Financial Conduct Authority
We are currently holding around 400
million records across our various databases. You are
provided access to all of this data within your
subscription package. We also provide supplemental
information (where available) providing an indication of
time at address, year of birth and comparable house