Data Protection Compliance Statement
This is a statement of Data Protection Compliance adopted by HCE Group for undertaking trace or trace and collect/enforce enquiries for clients.
HCE Group will, during such enquiries, collect and use personal information which must be dealt with properly however it is collected, recorded and used; whether on paper, in a computer, or recorded on other material.
We regard the lawful and correct treatment of personal information by the company as critical in maintaining the confidence of our clients; we therefore treat personal information lawfully and correctly.
To this end we fully endorse and adhere to the Principles of Data Protection, as set out in the Data Protection Act 1998.
Specifically, the Principles require that personal information:
- Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met
- Shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes
- Shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed
- Shall be accurate and, where necessary, kept up to date
- Shall not be kept for longer than is necessary for that purpose or those purposes
- Shall be processed in accordance with the rights of data subjects under the Act
- Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
- Shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
HCE Group will, through appropriate management, strict application of criteria and controls:
- Observe fully the conditions regarding fair collection and use of information
- Meet its legal obligations to specify the purposes for which information is used
- Collect and process appropriate information and only to the extent that it is needed to fulfil operational needs or to comply with any legal requirements
- Ensure the quality of information used
- Apply strict checks to determine the length of time information is held
- Ensure that the rights of people about whom information is held are able to be fully exercised under the Act.
- (These include: the right to be informed that processing is being undertaken, the right of access to one’s personal information, the right to prevent processing in certain circumstances and the right to correct, rectify, block or erase information which is regarded as wrong information.)
- Take appropriate technical and organisational security measures to safeguard personal information
- Ensure that personal information is not transferred abroad without suitable safeguards
HCE Group is accredited through the British Standards Institute (BSI) under ISO 27001: 2013 for Information Security Management and will ensure that:
- There is an individual with specific responsibility for data protection within the organisation
- Everyone managing and handling personal information understands that they are contractually and legally responsible for following good data protection practice
- Everyone managing and handling personal information is appropriately trained to do so
- Everyone managing and handling personal information is appropriately supervised
- Anyone wanting to make enquiries about handling personal information knows how to do so
- Queries about handling personal information are promptly and courteously dealt with
- Methods of handling personal information are clearly described
- A regular review and audit is made of the way personal information is managed
- Methods of handling personal information are regularly assessed and evaluated
- Performance of handling personal information is regularly assessed and evaluated
Data Protection Policy for Tracing
In cases where it is appropriate and reasonable, we will profile subjects’ names through various databases to which we have access. In some circumstances, depending on the nature of the enquiry, this may leave a "footprint" under the search purpose that clients have provided to us on the subject's credit file.
Depending on the information we obtain from these databases, we may then determine further enquiries such as obtaining telephone numbers for addresses at which we believe the subject may be located. We may also utilise other public databases and/or Registries that we feel would be of value in this enquiry (e.g. Insolvency Register, Land Registry, London Gazette etc.).
Once this research has been completed, we may then conduct enquiries by telephone at and around the locations identified. At no stage will we divulge to a third party any personal data relating to the data subject.
Whatever the instruction, we confirm that no part of our enquiry will be sub-contracted to any other agent without prior client approval. We also confirm that no information concerning the data subject given to us by our clients or obtained during the course of a trace enquiry will be used for any other purpose.
At all stages of enquiries we recognise that we are acting as our clients’ data processor and as such we will fully comply with the Data Protection Act and its guiding principles.