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GDPR & Safeguarding Policies

GDPR

The lawful bases for processing are set out in Article 6 of the GDPR. At least one of these must apply whenever you process personal data:

 

 

  • Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
  • Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
  • Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).
  • Vital interests: the processing is necessary to protect someone’s life.
  • Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
  • Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)

How our Services Can be Used

In line with the requirements of GDPR – shown above, we offer the following services.
Address Tracing for the purposes of.

  • Serving of Legal Documents typically related to: Debt, Family Matters, Leasehold Extensions, Fraudulent Trading, Matters in the Family Court, Divorce, Child Maintenance.
  • Business Continuity, contacting your customers where there is a contractual agreement in place.
  • Informal debt Collection – to include LBA (letter before action), prior to Court Proceedings.
  • Tracing long lost Friends and Family members where the subject consents to the supply of their personal data.
  • Estate Distribution / Asset Reunification

In the main such services would be used by Legal Organisations, Local Government, Letting Agents & Landlords, Registered Companies, Financial Institutions.

Services to Members of the Public

The services that we offer many be used by members of the General Public, however, all such trace requests will be rigorously vetted for authenticity and plausibility and may be declined without the need for explanation.

Safeguarding & Purpose Validation

We are mindful of our Safeguarding and Purpose Validation responsibilities (Primarily applicable to Women and Children), as such the following exemptions will apply.

The following rules apply to trace requests from members of the public.

  • We will never perform traces upon anyone under the age of 18.
  •  When requested to locate a lost family member or friend, it will be necessary to obtain their permission to release the address information to the enquirer? 
  • In the case of previously cohabiting couples, we will not trace any subject unless the parties have been living apart for more than six years. 
  • If an enquirer describes themselves as a landlord.- We will check the ownership details of the tenanted property will decline the requests unless the title documents reflect the enquirers name.
  • Where a landlord and tenant have cohabited during the previous six years, then the trace request will be declined.
  • Where a trace request is described as Debt related or Required for Solicitor / Court and the subject is a female living outside of a family group, such requests will always be declined unless the requestor agrees that the information shall be passed directly to their appointed solicitor.
  • In the case of Asset Reunification or Estate Distribution trace requests, the requestor may be required to show some evidence to support their request.
  •  Company director home address traces – A company director’s home address is personal information, and many directors have chosen to keep it off the public register. Where a member of the public asks us to trace a director’s home address. – The result will be sent directly to the requester’s appointed solicitor; or. – If the requester does not wish to use a solicitor, they must provide evidence of the debt or dispute showing why the director’s home address is needed rather than the company’s registered office — for example, a personal guarantee, or a claim or court order against the director personally
  • Reverse telephone number lookups – identifying a person from a telephone number alone carries a higher risk of misuse. Reverse telephone number lookups are therefore available only to business clients and professional organisations, and are not offered to members of the public. 

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