We respect your privacy and are committed to protecting your personal data. This privacy policy tells you how we use and look after your personal data when you visit our website www.thetracinggroup.co.uk or when we provide services to you. It also tells you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below.
If we are the Data Controller
The Tracing Group Limited is the controller and responsible for your personal data (collectively referred to as "The Tracing Group", "we", "us" or "our" in this privacy policy).
If we are the Data Processor
If we are processing your personal data in the course of providing tracing services to an organisation such as a pension provider, that organisation is the controller of the personal data we are processing. You should refer to the relevant controller’s privacy policy for information about how your personal data is being used and protected.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
If you write to or email us, please mark your correspondence for the attention of the Data Protection Manager
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please do contact us in the first instance.
Purpose of this privacy policy
This privacy policy aims to give you information on how we collect and process your personal data, including any data you may provide via our website, when you browse for information or enquire about or purchase services from us.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Our website is not intended for children and we do not knowingly collect data relating to children.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated in February 2025.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Social media platforms
If you communicate or engage with us via social media, your engagement and personal data will also be subject to the terms and conditions and privacy policy of the relevant social media platform.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you do not provide personal data
You are not legally obliged to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to provide, or may have to cancel, our services to your organisation. We will let you know this at the relevant time.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data. In exceptional circumstances we may wish to use your personal data for a different purpose which does require your consent. In these circumstances we will contact you to explain how we wish to use your personal data and to ask for your consent. You are not required to give consent just because we ask for it. If you do give consent you can change your mind and withdraw it at any time.
Purposes for which we will use your personal data
We have set out below a description of all possible ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
We may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data.
| Purpose | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new contact, provide you with information about our services which you request from us and notify you of any changes to our terms of business | Identity Contact |
Necessary for our legitimate interests (to manage our relationship with our clients and to generate and grow business) |
| To process and deliver our services to your organisation including the management and collection of fees, payments and charges | Identity Contact Transaction |
Necessary for our legitimate interests (to recover money due to us) |
| To notify you about changes to our terms of business or privacy policy | Identity Contact |
Necessary to comply with a legal obligation |
| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity Contact Technical |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | Technical Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). We will add your details to our marketing database if:
You can check and update your current marketing preferences at any time by calling or emailing us using the details set out in the Contact Details section. Please see the Opting Out section for more details about managing your preferences.
Opting out
You can ask us to stop sending you marketing communications by particular methods (for example, you may be happy to receive emails from us but not telephone calls) or you may ask us not to send you any marketing communications at all. You may opt out of receiving some or all marketing communications at any time by following the opt-out links on any marketing message sent to you or by contacting us.
Where you opt out of receiving these marketing communications, this will not apply to personal data provided to us as a result of a service purchase or service experience. Where you choose to opt out, it may take 7 days to fulfil this request.
Cookies
Cookies are small files saved to the user’s device which track, save and store information about the user’s interactions with and usage of a website. This allows the website controller to provide users with a tailored experience within the website. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the Purposes for which we will use your personal data section above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside the UK. If this changes we will update this privacy policy and take steps to ensure that your personal data continues to be adequately protected.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Please remember that you are responsible for keeping your passwords secure. If we have given you, or you have chosen, a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. Please do not share your passwords with anyone.
Unfortunately, sending information via the internet is not completely secure. We cannot guarantee the security of your personal data in transit to our website; however, once we have received your personal data we will use strict procedures and security features to try to prevent unauthorised access.
How long will you use my personal data for?
We will only keep your personal data for as long as we need it to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may keep your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We keep anonymised data indefinitely.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to a copy of your personal data.
Request correction of the personal data that we hold about you.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party in a structured, commonly-used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We may, to keep your personal datasecure, need to request specific information from you to help us confirm your identity.
Policy last updated/issued: 24/02/2025. V3.1