Commercial data handling statement

1              Introduction

1.1          Title Research Limited (TR) is a limited company whose registered office and primary place of business is Spectrum House, Bond Street, Bristol, BS1 3LG. 

1.2          The company registration number for TR is 01115250, and the Information Commissioners Office (ICO) Public Register Registration number is Z6214613. The VAT number for TR is 207410645.

1.3          This Statement is intended to provide parties who have commercial dealings with TR with further details as to how TR will manage data. 

1.4          Should you believe that your data is being processed by TR, and you have any questions regarding this or any element of this data processing statement, please write to us at the address above, or e-mail us at info@titleresearch.com. Please mark any correspondence for the attention of the Head of Risk & Compliance who is our nominated point of contact for data queries. 

 

2              The information we hold

2.1          There are a number of reasons we may hold your data.

2.1.1      You may be in contract to provide goods or services to TR (referred to in this Statement as “Supplier”). We will process your data to meet our obligations and achieve the benefits of our contract with you. 

2.1.2      You may have entered into a contract for TR to provide professional services (referred to in this Statement as “Client”). We will process your data in accordance with the contract for services we are providing, and to make you aware of other information relevant to your instructions.

2.1.3      You may have been contacted by TR in connection with our instructions to locate individuals with an interest in an estate (“Consumers”). We will process your data to carry out our obligations to our client under our contract with them.

2.1.4      You may have made enquiries with TR regarding our services, attended a Webinar or other event, or provided us with your details to hear more about our services (referred to in this Statement as “Enquirer”). 

2.2          If you believe your data is being processed by TR, but that this is not addressed in any of the above categories, please contact us using the contact details shown above. We will process your data in accordance with your informed consent. 

 

3              Your rights

3.1          You have a number of rights in respect of how your data is handled.

3.1.1      The right to be informed that your data is being used.  The information in this statement should help you in this regard.

3.1.2      A right of access to your data.  Information on how you can access your data is provided below. 

3.1.3      A right of to have incorrect data we hold about you rectified.  Information on how to ask for your data to be rectified is provided below.

3.1.4      A right to request that your data is deleted. 

 

4              How we will hold data

4.1          We will hold your electronic data (including e-mails, call recordings or digital documents) within our secured hosted network.  This network is not accessible by the public, and the data is stored only within the UK. 

4.2          We will hold any hard copy data you provide us within our primary place of business referred to above.  Please note, it is our practice wherever appropriate to scan or otherwise convert hard copy documents to digital documents, and then to destroy the original hard copy document through a secure confidential waste service.  At the conclusion of our service, we will store any remaining hard copy documents with our nominated third party archiving provider. 

 

5              How long we will hold data

5.1          The length of time we will hold your data will vary depending on our relationship with you.

5.1.1      For Suppliers, we will continue to hold your data whilst we are in active contract.  Once the contract period has come to an end, we will continue to hold your data for a period of seven years from the last day of the contract.  This is to allow adequate time us to respond to any queries on the contract brought within the contractual limitation period.

5.1.2      For Clients, we will continue to hold your data whilst we are in active contract.  Once the contract period has come to an end, we will continue to hold your data for a further period from the last day of the contract.  As the majority of services provided by TR concern probate and estate administration, we will retain data on cases where we are instructed for a period of 13 years after the contact has come to an end.  Parties with an interest in an estate may bring a claim a number of years after an estate has been administered to, and after 13 years it is likely that any claim brought would be out of time. 

5.1.3      For Consumers, we will retain your information for the same amount of time as we keep other documents relating to our service as set out at clause 5.1.2

5.1.4      For Enquirers, we will continue to hold your data until such time as you advise that you no longer wish to be contacted by us.  Unless you expressly request that we delete your data, we will hold this for a period of six months after you advise that you do not wish to be contacted.  We will hold data for this period to ensure that you receive no unrequested contact from us during this period.  Please note, once we have deleted your data, we are unable to guarantee that we will not contact you again in the future if your details are provided to us via a legitimate means. 

5.2          It is our practice to continuously back up data as a means of protection against data loss.  This is done through a series of data backups, which can themselves be kept for a period of up to 7 years from the point of backup.  Therefore, whilst we will delete data after the time period stated above, backups of this data may continue to exist for a further 7 years, but access to these will be heavily restricted.  Please note, not all data is backed up for the full seven years, and we may be unable to recover all data after the initial period referred to above. 

 

6              Right of access to data

6.1          You have the right to request information about the data we hold about you, and this request is sometimes called a Subject Access Request. 

6.2          If you wish to request information on what data we hold about you, please contact us using the details provided above.

6.3          Unless bound by a duty not to disclose such information we will provide you with further information about the data we hold.  Where you request a copy of any relevant documents, we will provide these once suitably redacted to protect the rights of any other affected parties. 

6.4          We will not normally charge you to provide you with copies of your data, unless there are unusual circumstances (such as a request for copy data that has already been provided).  In the event it is necessary for us to charge you, we will limit our charges to a reasonable fee in the circumstances

 

7              Right of correction

7.1          You have the right to request that we correct any information we hold about you that you believe to be incorrect. 

7.2          If you would like to request that we amend any information we hold about you, please write to us or e-mail us at e-mail with further details of what data you believe is incorrect.  We will then respond within a reasonable period of time to confirm whether we are able to act on your request and if not, we will provide you with an explanation. 

 

8              Right of deletion

8.1          You have the right to request that we delete any information we hold about you that you believe to be incorrect. 

8.2          If you would like to request that we delete any information we hold about you, please write to us or e-mail us at e-mail with further details of what data you believe is incorrect.  We will then respond within a reasonable period of time to confirm whether we are able to act on your request and if not, we will provide you with an explanation. 

8.3          Please note, where your details are connected to our professional services, we are unlikely to be able to delete your full details until the expiry of our retention period (see section 5 above) as we may require these to evidence that we have fully discharged any obligation to our client. 

 

9              Who will process your data on our behalf

9.1          We will utilise a number of third parties to assist us in process our data.  If you require any further information about our use of third party data processors, please contact us. Such third parties will include:

9.1.1      An IT service provider to provide our secure hosted network.

9.1.2      An IT support provider to provide our internal IT support.

9.1.3      A data entry service provider.

9.1.4      A scanning and indexing provider for the handling of post and other documents.

9.1.5      A Customer Relationship Management (CRM) software provider.

9.1.6      A third party secure archiving provider.

9.2          TR may be instructed in relation to a jurisdiction other than the UK, either in respect of acting as an agent for processing instructions on assets held outside of the UK, or in respect of genealogical research where family members reside outside of the UK. 

9.2.1      Where we have been instructed to provide a service relating to people or assets outside of the UK, we are likely to instruct a local agent within that jurisdiction to assist us.  Such local agents may include agents in jurisdictions outside of the European Economic Community (EEC). 

9.2.2      It is not possible to identify in advance all the potential non-UK agents we may need to instruct, as this will be dependent on the nature of the instructions we receive. 

9.2.3      Where it is necessary to instruct a non-UK agent as referred to above, the following mitigations will be in place:

(a)          Sharing of data will be limited to that necessary for us to effectively deliver our service.

(b)          Local agents will be provided with standard terms of business setting out how the service should be delivered

 

10           What data will be processed

10.1        For Suppliers

10.1.1    We will process all data you provide us in connection with the contractual agreement.  This will include processing the personal information of any employees or other colleagues linked to the contact (such as names and e-mail addresses). 

10.2        For Clients

10.2.1    We will process all data you provide us in connection with the contractual agreement.  This will include processing the personal information of any employees or other colleagues linked to the contact (such as names and e-mail addresses). 

10.3        For Consumers

10.3.1    We will process your name and contact details to carry out the service that our Client has instructed us to provide.  Where we have been instructed to conduct genealogical research, we may search for your details within areas of public record to locate your contact details and relationship with a particular estate. 

10.4        For Enquirers 

10.4.1    We will utilise the contact details provided (including names, e-mail addresses, telephone numbers and other details linked to contact details) with your consent in order to communicate with you about our products or services.

 

11           Special categories of personal data

11.1        Special categories of personal data are data about the following for an individual:

11.1.1    Racial or ethnic origin

11.1.2    Political opinions

11.1.3    Religious or philosophical beliefs

11.1.4    Trade union membership

11.1.5    Biometric data for identification purposes

11.1.6    Health or medical care

11.1.7    Sex life or sexual orientation

11.2        Within the normal course of our service, we will not process any special categories of personal data.  However, if you believe that in your case you will need to provide us with data relating to one of the above categories, then please contact us to discuss further. 

 

12           Use of data

12.1        The way we use data will vary depending on our relationship with you.

12.2        For Suppliers

12.2.1    We will process data in order to utilise the benefits we have and meet the obligations we owe you under the terms of the contract. 

12.3        For Clients

12.3.1    We will process data in order to carry out our duties and obligations under the specific contract for which you have instructed us.  We will provide further details of what steps we will take on a case by case basis. 

12.4        For Consumers

12.4.1    We will process data to advise our client on the outcome of our research in accordance with our contract for professional services.    

12.5        For Enquirers 

12.5.1    We will utilise the contact details provided (including names, e-mail addresses, telephone numbers and other details linked to contact details) in order to communicate with you about our products or services.

 

13           Automated decision making

13.1        We will not make any decisions regarding the processing of your data based on an automated decision making process. 

 

14           Further information

14.1        This Statement is intended to provide all practical information regarding how we will use your data.  Please contact us if you have any questions that fall outside of the information provided here.