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. 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, the data controller is TRL Technology Limited of Sigma Close, 11 Shannon Way, Tewkesbury, Gloucestershire, GL20 8ND.
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, job title and employer by:
- filling in forms on our website,
- participating in discussion boards or other social media functions on our website,
- giving us your business card,
- entering a competition, promotion or survey organised by us, or
- corresponding with us by phone, email, letters or otherwise.
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:
It is also a contractual requirement for you to provide us with certain information. If you do not provide us with that information, then we may not be able to continue to provide goods and services to you, or to the company or organisation you represent.
INFORMATION WE COLLECT ABOUT YOU FROM OTHER SOURCES
When you visit our website, we may collect information about you (such as the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform).
We may also collect information about you by conducting searches of public records (eg. Companies House, electoral roll, DVLA database), or in the process of confirming your identity via our online ID verification provider.
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:
You can change the settings on your internet browser to restrict the amount of information that we can collect when you visit our website. 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 website.
DISCLOSURE OF YOUR INFORMATION
You agree that we have the right to share your personal information with:
- HM Revenue & Customs, the Information Commissioner’s Office and any other regulatory bodies which govern any part of our business;
- our auditors and quality assurance assessors;
- Google Analytics through cookies, SAP and other online cloud providers; and
- selected third parties including 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.
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;
- to any division, sector, segment or company within the L3 Technologies group.
- if TRL Technology Limited 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
IDENTIFYING YOU AS A CUSTOMER
If you are a business client, we may identify you as a client of the firm in our marketing material or in legal directories, although we will never publicly disclose any confidential information about your legal matters without having obtained your prior consent. If you do not agree to us identifying you as a 4
customer of the firm, please notify us by writing to the address at the top of this policy, or by emailing us at Privacy.trl@L3T.com.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on secure internal network folders, SAP secure servers in Germany and secure servers within the UK.
All data is controlled from our retention and destruction policy. We will take all steps reasonably necessary to ensure that your data is treated securely, including taking the following safeguards:
- Entry controls. Our buildings have restricted access with security controls on multiple points throughout each building.
- SAP Access Controls: Access to data within SAP is restricted to user permissions.
- Secure lockable desks and cupboards. Desks and cupboards are kept locked when not in use if they hold confidential information of any kind.
- Overseas transfers. Whenever we transfer your personal information outside the United Kingdom, we ensure a similar degree of protection is afforded to it by ensuring that we apply appropriate safeguards (either by transferring data only to recipients in the European Economic Area, to recipients in countries approved by the European Commission, to recipients that are party to the EU-US Privacy Shield, or by using specific contracts approved by the European Commission).
- 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.
- Personal devices. Personal devices such as mobile phones, laptops and tablets are restricted from our buildings.
- Work devices. Work devices such as L3 TRL Technology issues mobile phones are restricted to certain areas around the business.
- Personnel security controls. Each L3 TRL Technology employee has their own personal and private security code. In addition to key fobs, this code is required to gain entry into them multiple points of security locks in each building.
- Network controls. Approved controls through internal processes, certified to ISO27001.
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. 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.
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:
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 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 us by writing to the address at the top of this policy, or by emailing us at Privacy.TRL@L3T.com
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.
We do not use automated decision-making processes.
CHANGES TO OUR POLICY
Any changes we make to our policy in the future will be posted on our website and, where appropriate, notified to you by post, email or via social media. Please check our website frequently to see any updates or changes to our policy.
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Questions, comments and requests regarding this policy are welcomed. To do so write to the address at the top of this policy, or by emailing us at Privacy.trl@L3T.com