Privacy Policy

Last updated 24th May 2018

1. Introduction

This Privacy Policy explains the types of personal data we may collect about you when you interact with us, as well as how we’ll store and handle that data, and keep it safe.

It’s likely that we’ll need to change this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.

2. Who are Tracelocator?

Tracelocator Limited T/as GHT Global (GHT) is a company incorporated in the United Kingdom, registered number 11225015 who’s registered offices are at Kemp House ,City Road, London, England, EC1V 2NX

GHT is a ‘data processor’ for the purposes of the EU General Data Protection Regulation 2016/679 (‘GDPR’).

As a data processor we are provided with personal data from the ‘data controller’ who is our ‘client company’. Our obligations and compliance with GDPR regulations are covered contractually with each individual client company.

3. Why do we use your personal data?

GHT does not offer its services to the public and does not collect personal data other than at the request of the data controller, the client company.

We receive and use personal data supplied by the data controller specifically to undertake our business services:

Location and or tracing of individuals or next of kin
Verification of existence (‘mortality screening’)

We receive personal data in secure format which includes encryption and password protection.

The data we receive may include all or part of the following dependent on the information held by the data controller;

Full Name
Spouse Name
Current Address or last known address
Current Telephone number or last known
Current Email address or last known
Dependents or Next of Kin Names, addresses and contact information
National Insurance Number
Unique identify number used by the data controller to identify you in their database
The name of your Pension fund and or Administrator

We do not hold nor collect any financial information including but not limited to:

Bank account details
The value(s) of your pension fund
Details of any payments you may be in receipt of now or in the future

4. How we share your personal data

We will not share your Personal Data with third parties except with your consent or as otherwise permitted or required by applicable laws including and subject to GDPR.

Any personal data we collect will only be shared with the client company that provided the original data allowing us to perform our service and for the purposes of updating or verifying the correctness of the information held by the client company.

As required by law: We may disclose Personal Data if required by law, for example to law enforcement or other authorities. This includes court orders, subpoenas and orders arising from legal processes, and administrative or criminal investigations. We may also disclose your Personal Data if the disclosure is necessary for the prevention, detection or prosecution of criminal acts or to prevent other damage, or in response to a legal action or to enforce our rights and claims.

5. How we store and protect your Personal Data

Our servers and data centres are located in the European Union (EU).

However, we may need to transfer your Personal Data to staff operating outside the European Economic Area (EEA) who work for us.
These countries may have different and/or less stringent privacy/data protection and data security rules than those of the UK and EU. We will take all steps to ensure that your data is treated securely and in accordance with this Policy.

We have a security program designed to keep the Personal Data stored in our systems protected from unauthorised access and misuse. Personal Data may only be accessed by persons within our organisation to carry out the uses indicated in this Policy.

6. How long we keep your Personal Data

We will only keep your Personal Data for the purposes outlined in this Policy and when these purposes have expired, or are no longer relevant, or you have withdrawn your consent for us to use your Personal Data (and we have no other lawful basis to use such data), we will delete such data.

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 requirements.

7. Cookies, tracking tools and profiling

GHT does not use cookies, profiling or any web or internet tracking tools

8. Third-party websites

Our website and Platforms may contain links to other websites run by other organisations. This Policy applies only to our website and Platforms‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites and platforms even if you access them using links from our Platforms.
In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site.

This notice was last updated on 24/05/2018