Introduction

The Advocate Group privacy policy applicable to our COVID 19 Track and Trace system. This policy applies when you submit your details via the Track and Trace system (“The System”) because the venue or location you are attending (“Venue”) is required by law to keep your details on record and disclose them if the Venue is affected by a COVID-19 outbreak. Advocate Group respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use The System and tell you about your privacy rights and how the law protects you. The System is not intended for children under 13 and we do not knowingly collect data relating to children under 13.

IMPORTANT INFORMATION AND WHO WE ARE

CONTROLLER

Advocate Group is the controller and responsible for your personal data (referred to as “Advocate Group”, “we”, “us” or “our” in this privacy policy). 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:

• Full name of legal entity: Advocate Group
• Email address: support@advocategroup.org.uk
• Postal address: 17 Old Courts Road, Brigg, Lincolnshire, DN20 8JD
• Telephone number: 01652 651830
• You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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 contact us in the first instance.

 

CHANGES TO THE PRIVACY POLICY

We keep our privacy policy under regular review. If we make changes to our privacy policy, our updated privacy policy will be made available to you on our website.

THIRD-PARTY LINKS

Our registration page may contain a link to the Venue’s online ordering system. Clicking on that link may allow third parties to collect or share data about you. We do not control these third-party services and are not responsible for their privacy statements. When you leave our registration page, we encourage you to read the privacy policy of every website you visit.

THE DATA WE COLLECT

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 the following kinds of personal information:

• Identity Data includes title, first name and last name.
• Contact Data includes email address and telephone number.
• Attendance Data includes the date and time you attended the Venue.
• Technical Data includes internet protocol (IP) address, time zone setting and location.
• Usage Data includes information about how you use The System.

 

SPECIAL CATEGORY DATA

Special Categories of Personal Data 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.
We do not collect Special Category Data from you.
We do not collect any information about criminal convictions and offences.

HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you when you access The System, either through scanning our QR code or be visiting trackandtrace.advocategroup.org.uk

• Direct interactions. You give us your Identity, and Contact Data by using The System.
• Automated technologies or interactions. As you interact with The System, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using server logs and other similar technologies.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. We use your personal data for the following lawful bases:

• Where it is necessary for the legitimate interests of the Venue to comply with its legal obligations and your interests and fundamental rights do not override those interests.
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Our legitimate interests include:

• Running our business, provision of administration and IT services, network security, to prevent fraud and in connection with a business reorganisation or group restructuring exercise. Where we ask for and you provide us with your consent, you have the right to withdraw consent at any time by contacting us.

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, a description of all the ways we plan to use your personal data.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

• For our internal records and references.
• To provide and facilitate access to The System and to provide The System service to the Venue.
• To manage our relationship with you, including notifying you about changes to our privacy policy.
• To administer and protect our business, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.
• To use data analytics to improve The System.
• To contact you in response to your query sent through the enquiry form on our Website.

MARKETING

We will never use your personal data for marketing purposes.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in section 4 (Purposes for which we will use your personal data) above.

• In the event there is a COVID-19 infection at the Venue at the time you attended the Venue we will share your information with:
• the UK Government “Track and Trace” systems; or
• where required by law, the Venue for the purposes of the Venue complying with its legal obligations; and if the UK Government Track and Trace agency or the Venue receives this information then the receiving party becomes a separate data controller and is responsible for telling you how it will use your information from that point onwards. The data that we would disclose in these circumstances is: [Your name, contact details and the date and time you attended the Venue.]
• External Third Parties.
• Service providers acting as processors, who provide IT, hosting, network support, system administration, back-up;

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.

INTERNATIONAL TRANSFERS

All personal data collected by us in connection with The System is either processed in the UK or by third parties within the European Economic Area. Where there is a transfer of your data between the UK and the EEA we will comply with the applicable data protection legislation.

DATA SECURITY

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.

DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for 21 days from the date you supply it to us. We consider this is the period reasonably necessary to fulfil the purposes we collected it for. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation or audit in respect to our relationship with you.
If you are involved in a COVID-19 outbreak we may be required by law to retain your data for longer periods, we will notify you at the time to tell you how this data is to be retained.
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), in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• 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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that 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:
• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that 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 wish to exercise any of the rights set out above, please contact us.

 

NO FEE USUALLY REQUIRED

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.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.