We are Trident Assurance Services (TAS), consultants offering the complete assurance package. We are committed to being transparent about how we collect and use data and to meeting our data protection obligations. This policy sets out how we use and protect any personal information we hold and process about you.

Data protection principles All personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
• processing is fair, lawful and transparent;
• data is collected for specific, explicit, and legitimate purposes;
• data collected is adequate, relevant and limited to what is necessary for the purposes of processing;
• data is kept accurate and up-to-date. Data which is found to be inaccurate will be rectified or erased without delay;
• data is not kept for longer than is necessary for its given purpose;
• data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures;
• we comply with the relevant data protection legislation procedures for international transferring of personal data.

Personal data In providing you with our services, we may process your personal data. Personal data is information about you from which you can be identified, such as your name, date of birth and contact details.

Confidentiality

The confidentiality of your personal data is of paramount concern to TAS and we comply with UK data protection legislation.

How do we protect and safeguard your data? We take the security of your data seriously. Our internal policies and controls are designed by default to ensure that your personal data is not accidentally destroyed, misused, disclosed or lost and is not accessed except by our employees in the performance of their job role duties.

Where we engage third parties to process personal data on our behalf, they do so underwritten instructions, a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

How long do we keep your data? We only keep your data for as long as is necessary and in accordance with UK legislation and industry guidelines.

Your rights and how to exercise them As a data subject, you have a number of rights and freedoms. You can:
• obtain confirmation as to whether your personal data is being processed and where that is the case, gain access to the personal data;
• require TAS to rectify incorrect or incomplete data;
• require TAS to erase or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
• object to the processing of your data where TAS is relying on its legitimate interests as the legal ground for processing.
• move, copy or transfer your personal data from one IT environment to another, securely and without affecting its usability.

If you would like to exercise any of these rights, please contact our Data Protection Officer (DPO) at: dpo@trident-ms.co.uk. We will ask you to provide documentation to confirm your identity or, if you are acting on behalf of another individual, we will ask you for proof of their consent or your legal right to receive their personal information.

If you believe that TAS has not complied with your rights and freedoms you can make a complaint. Please see the contact details in this document.

Changes to our processing arrangements

Should we need to change the way we collect, store or process your data we will contact you to let you know.

Law relating to this document General Data Protection Regulation (2016/679 EU) Data Protection Bill Privacy and Electronic Communications Regulations (PECR)

Contact information Should you need to, you can contact us via the following routes:
In person or by post: Trident Assurance Services 3B Olympus House Calleva Park Aldermaston RG7 8SA
By telephone: 0118 324 9444
By email: enquiries@trident-as.co.uk

Our Data Protection Officer can be contacted via the following routes:
By post: Trident Assurance Services 3B Olympus House Calleva Park Aldermaston RG7 8SA
By telephone: 0118 324 9444
By email: dpo@trident-ms.co.uk

Trident Assurance Services is a company registered in England and Wales with 09357729.
The TAS registered office is Aquis House, 49-51 Blagrave Street, Reading, Berkshire RG1 1PL.
Trident Assurance Services is registered with the Information Commissioners Office, registration number Z4946055.

Complaints If you think we have not complied with our data protection obligations and you wish to complain to the Information Commissioner, you can use the contact details below:
Information Commissioner’s Office Helpline: 0303 123 1113 www.ico.org.uk/concerns

Website users
What personal data do we collect? When you use our website we may collect the following personal data:
• your name, company, email address and telephone number;
• the internet protocol (IP) address of the device you are using, the browser software you use, your operating system, the date and time of access and information on how you use our website;
• details of contact we have had with you including records of telephone conversations and emails;
• information you give us when responding to online surveys for research purposes.

We also collect technical data via Google Analytics, however these reports do not contain any personal data.
How do we collect your data? We may collect this information in a variety of ways. For example, we might collect data when:
• you complete our ‘contact us’ form;
• you fill in your details to book an event or webinar;
• you subscribe to email notifications and/or newsletters;
• you complete an online survey.

Why do we process your personal data? We may process your personal data for any of the following reasons:
• to enable us to contact you in response to a query or request for information;
• to register you for email notifications and/or newsletters that you have subscribed to;
• to book you onto an event and/or webinar;
• to collect your opinions as part of any research we may carry out.

What is the lawful basis for processing? We may process your data on the grounds of contractual or legitimate interests – if we need to respond to your enquiry or enter into a ‘contract’ of services with you, or book onto an event we are hosting. If you have subscribed to our email notifications or newsletter we are relying on your consent to process your personal data. You can withdraw this consent at any time.

Who do we share your data with? Your data may be shared internally within TAS whose employees may view your data as part of their job role.

If you subscribe to our email notifications and/or newsletter your name, company and email address may be stored on the email platform Mailchimp. Mailchimp’s server is in the USA so your name and email address may be stored outside of the EEA.

We do not share your personal information with anyone outside of TAS or its partner organisations to use for their own purposes, except:
• when we have your permission;
• to comply with a legal obligation or to perform a public task;
• if we are under a duty to disclose or share personal data in order to enforce or apply our terms of use (of our website or any part of it) or terms and conditions of supply of any relevant products or services and other agreements;
• to protect the rights, property, or safety of TAS, our customers, or others;
• in order to detect, prevent and help with the prosecution of financial crime;
• if there are other exceptional circumstances, and we are unable, or it is not appropriate to seek your permission;
• to archive for statistical or research purposes or in the public interest;
• in the reason of public interest.

Third party websites Our website includes hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

We cannot ensure the security of your data when it is being transmitted to our website or other digital sites from other pages. All transmission of personal information and other data is done at your own risk.

Cookies
What is a cookie? A cookie, also known as a browser cookie, is a text file containing small amounts of information which a server may download to your computer hard drive, tablet or mobile device when you visit a website or use an app.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies may be either ‘persistent’ cookies or ‘session’ cookies. A persistent cookie will be stored on the web browser and will remain valid until its set expiry date unless detected by the user before the expiry date. A session cookie, on the other hand, will expire at the end of the user session when the web browser is closed.

First-party and third-party cookies Cookies can be set and controlled by the operator of the website which the user is browsing (known as a ‘first-party cookie’) or a third party such as Facebook, for example, to display advertisements and social sharing features (known as a ‘third-party cookie’).

Cookies used by TAS The only cookies in use on the TAS website are for Google Analytics. Google Analytics is a web analytics tool that helps website owners understand how visitors engage with their website. Google Analytics customers can view a variety of reports about how visitors interact with their website so that they can improve it.

Like many services, Google Analytics uses first-party cookies to track visitor interactions as in our case, where they are used to collect information about how visitors use our website. We then use the information to compile reports to help us improve our website.

Cookies contain information that is transferred to your computer’s hard drive. These cookies are used to store information, such as the time that the current visit occurred, whether the visitor has been to the website before and what site referred the visitor to the web page.

Google Analytics collects information anonymously. It reports website trends without identifying individual visitors.
How can you control the use of cookies? You can opt out of Google Analytics without affecting how you visit our website – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page.

Sharing of data from cookies TAS may disclose data collected from third-party cookies, such as visitor trends, to third parties, in an anonymous form, for research and statistical purposes, and to help us optimise our websites.
Learn more about cookies To find out more about cookies in general either search in Google or visit aboutcookies.org or allaboutcookies.org.

A guide to behavioural advertising and online privacy has been produced by the internet advertising industry which can be found at www.youronlinechoices.eu. The guide contains
an explanation of the Internet Advertising Bureau’s self-regulatory scheme to allow you greater control of the advertising you see.

Who do we share your data with? Your data will be shared internally with our recruitment and HR team, the interviewing staff and, where necessary, support staff.

We do not share your personal information with anyone outside of TMS and its partner organisations to use for their own purposes, except:
• when we have your permission;
• to comply with a legal obligation or to perform a public task
• if we are under a duty to disclose or share personal data in order to enforce or apply our terms of use (of our website or any part of it) or terms and conditions of supply of any relevant products or services and other agreements;
• to protect the rights, property, or safety of TMS, our customers, or others;
• in order to detect, prevent and help with the prosecution of financial crime;
• if there are other exceptional circumstances, and we are unable, or it is not appropriate to seek your permission;
• to archive for statistical or research purposes or in the public interest;
• in the reason of public interest.

How long we keep your data If your application is not successful and you if you have provided your consent for us to keep your data on file for future job vacancies, we will keep your data for 12 months once the recruitment process ends. At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data and there will be no consequences of withdrawing consent.

If your application is not successful and you have not provided your consent for us to keep your data for the purpose of future suitable job vacancies, we will keep your data for three months once the recruitment exercise ends, after which it will be deleted.

If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.

Customers/potential customers
What personal data do we collect? We may collect and process a range of information about you. This includes:
• basic details such as name, company, address and contact details;
• details of contact we have had with you such as referrals and quotes;
• details of services you have received;
• information about complaints and incidents;
• information from customer surveys, competitions and marketing activities;
• written summaries of calls we receive or make;
• email communications we receive or make;
• written minutes of meetings and service reviews;
• other information we receive from other sources, including from your use of websites and other digital platforms we operate or the other services we provide, information from business partners, advertising networks, analytics providers, or information provided by other companies who have obtained your permission to share information about you.

How do we collect your data? We may collect this information in a variety of ways. For example, we might collect data when:
• you apply for a quote or enquire about our services;
• you enter into a contract with TAS for the provision of services, and when you use those services;
• you submit a query to us, for example by email, telephone, social media or the TAS website;
• you participate in any marketing activity;
• you complete our customer feedback surveys or research surveys;
• you leave us your contact details at a promotional event;
• you subscribe to email notifications and/or newsletters.

Why do we process your personal data? We use your personal information to provide you with our services, and to improve and extend our services. This may include:
• responding to your queries, including providing quotes;
• internal record keeping and administration;
• responding to requests where we have a legal or regulatory obligation to do so;
• assessing the type and quality of service you have received and any concerns or complaints you raise, so that these can be properly investigated;
• using your contact information to send you service-related information;
• using your contact information to send promotional material about new services, special offers or other information we think you may find interesting (we will only do this with your consent);
• using your contact information to give you an opportunity to complete a customer satisfaction survey;
• using your contact information to conduct and analyse market research;
• sending statements, invoices and payment reminders to you, and collecting payments from you;
• sending you non-marketing commercial communications;
• sending you our email newsletter or notifications if you have requested them.

What is the lawful basis for processing? We process your information in order to;
• perform the contract which we have entered into with you or take steps to enter into a contract with you;
• carry out our legitimate interests (to provide a quality service and to maintain transparent and accurate records).

Who do we share your data with? Your data will be shared internally with TAS staff in order for them to complete their job role and to carry out our obligations under our contract with you and/or in line with the purposes set out above. Your financial data may also be shared with our bank as necessary where you are making payments to us.

Your contact details may also be shared with our marketing team to ensure you are invited to events or provided with important updates. You can opt out of marketing communications at any time.

We may share your personal information with third parties where required by law (for example to comply with anti-money laundering legislation) and where it is necessary to administer the working relationship with you (as stated above).

We do not share your personal information with anyone outside of TAS and its partner organisations to use for their own purposes, except:
• when we have your permission;
• to comply with a legal obligation or to perform a public task
• if we are under a duty to disclose or share personal data in order to enforce or apply our terms of use (of our website or any part of it) or terms and conditions of supply of any relevant products or services and other agreements;
• to protect the rights, property, or safety of TAS, our customers, or others;
• in order to detect, prevent and help with the prosecution of financial crime;
• if there are other exceptional circumstances, and we are unable, or it is not appropriate to seek your permission;
• to archive for statistical or research purposes or in the public interest;
• in the reason of public interest.