Privacy

This Privacy Notice is effective from 11/04/2018

Your privacy is critically important to us. At URS, we have a few fundamental principles:

• We limit the collection of data for specific purposes and ensure that we have legitimate and lawful grounds for processing that data.
• We store personal information for only as long as we have a reason to keep it.
• We aim to ensure that the data we hold is accurate and up to date.
• We aim for full transparency on how we gather, use, and share your personal information.
• We implement security controls specifically to protect personal and sensitive data.

Below is URS’s privacy policy, which incorporates and clarifies these principles.

Who We Are and What This Privacy Notice Covers

Companies in the URS Holdings group are is accredited by Accreditation Bodies UKAS, DAkkS, CAI, NABCB, INAB, DAC, SAC, EGAC, providing auditing and inspection services for a range of industry and international standards.

As part of conducting these activities we engage 3^rd party associates and specialist to deliver the best possible service and throughout the audit and inspection activities we gather evidence of compliance that may include minimal personal data specific to the requirements of each particular standard. This may include names of people we have interviewed, relevant training information and identifiers (such as a staff reference number), so that audit verification activities can confirm the auditor has engaged with or audited the individuals concerned.

We also obtain and hold business contact details of our customers and supplier in order to fulfil our contractual and legal obligations.

This policy describes the type of data that we gather, share and processed and the reasons why. It also informs you of your rights and options should you wish to challenge or enquire about any of these activities.

This Privacy Policy applies to information that we collect about you when:

• Using our websites (such as, http://www.urs-holdings.com and http://www.urs-certification.co.uk/ );
• Using other products and services that are available on or through our websites (including our internal portals);
• Having personal interactions via various forms of electronic messaging, voice and video communication or face to face.
• Communication of relevant marketing information that you have either consented to or otherwise expect from us as part of an established relationship.
• Out of contractual necessity such as in the delivery or products or services or the employment of our staff
• From 3^rd parties with whom you have agreed for them to share your data with us.

Throughout this Privacy Policy we’ll refer to our website, mobile applications and other products and services collectively as “Services.”

Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

Please note that this Privacy Policy does not apply to any of our products or services that have a separate privacy policy. These will be presented to you as appropriate should these products or services relate to you.

If you have any questions about this Privacy Policy, please contact us as described in the Contact Section below.

Definitions you should be aware of

Personal data: “personal data” means any information relating to an identified or identifiable natural person (known as the ‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Data Subject: The “Data Subject” is the individual that the personal data relates to and identifies

Data Controller: “Controller” This is the decision maker who decides how, when and where data under their control will be processed.

Data processor: “Processor” refers to the individual or organisation that carries out data processing activities under instruction from the Data Controller. The Data Controller may also be the Data Processor.

Processing: “Processing” processing relates to any activity carried out on personal data and includes manipulating, sharing, copying, viewing and storage of data or simply the activity of making a decision based on that data. Decision making may also include automated decision making.

Filing System: “Filing System” basically means any form of data that can be interrogated or searched and can be digital (like a database or email system) or hard copy (like files in a filing cabinet or contact details in a rolodex).

Consent: “Consent” of the Data Subject relates to the permission to use their personal information following a clear explanation of how that data will be processed and why.

Legitimate Interest: “Legitimate interest” relates to the processing of personal on the basis that the organisation feels that their data processing activities will not infringe upon anyone’s rights or freedoms and that there is a reasonable expectation that these activities will take place.

Special Category: “Special Category” data is personal data which reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, sex life or sexual orientation.

Data Breach: “Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed

Information We Collect

We only collect information about you if we have a reason to do so; for example, to provide our Services, to communicate with you, or to make our Services better.

We collect information in three ways: if and when you provide information to us, automatically through operating our services, and from outside sources. Let’s go over the information that we collect.

Information You Provide to Us

It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples of data you may provide to us

• Business Account Information: If you have a business account with us we will require certain information in order to fulfil our obligations to you. This information will include contact details such as email, phone number and mailing address for individuals associated with your account as well as account preferences and service history in order to provide you with the best service possible.
• Transaction and Billing Information: If you buy something from us, you will provide additional personal and payment information that is required to process the transaction and your payment, such as your name, credit card information, and contact information.
• Communications with Us: You may also provide us information when you respond to surveys or communicate with our Helpdesk about a support question.

Information We Collect Automatically

We also collect some information automatically

Log Information: As part of our online services, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services in order to assess the performance of our systems and to help us improve the security around the data we hold for you.

Usage Information: We collect information about your usage of our Services. For example, we collect information about the actions that administrators and users perform – in other words, who did what, when and to what thing on our system (e.g. that you have read a notice on our CMS portal). We use this information to, for example, provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better.

Information from Cookies & Other Technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and e-mails. URS uses cookies and other technologies like pixel tags to provide better functionality to our website. For more information about our use of cookies and other technologies for tracking, including how you can control the use of cookies, please see here for information.

Information We Collect from Other Sources

We may also get information about you from other sources. For example, we may also obtain information from third party services about individuals who are not yet our users (…but we hope will be!), which we may use, for example, for marketing and advertising purposes.

How We Use Information

We use information about you as mentioned above and as follows:

• To provide our Audit, Inspection and Certification Services
• To further develop our Services - for example by adding new features that we think our users will find of benefit;
• To monitor and analyse trends and better understand how users interact with our Products and Services, which helps us improve our Services and make them easier to use;
• To monitor and protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of URS and others;
• To communicate with you about offers and promotions offered by URS and others we think will be of interest to you, solicit your feedback, or keep you up to date on URS and our products; and
• To personalize your experience using our online Services, provide content recommendations and serve relevant advertisements based on your preferences.

Sharing of Personal Data

How We Share Personal Data

We do not sell our users’ private personal information.

We share your personal data in the limited circumstances spelled out below and with appropriate safeguards on your privacy:

Subsidiaries, Employees, Agents and Independent Contractors: We may disclose information about you to our subsidiaries, our employees, and individuals who are our independent contractors that need to know the information in order to help us provide our Services or to process the information on our behalf. We require our subsidiaries, employees, and independent contractors to follow this Privacy Policy for personal information that we share with them.

With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so. Where we require your consent to share your data with 3^rd parties you will find these listed under Sharing with Third Parties.

We may also request your consent to process limited elements of your data in specific ways. Where we require this consent, it will be presented to you in a way that allows you to have a clear understanding of what you are consenting to and enable you to agree to this in a clear and positive way.

Sharing with Third Parties: We may share information about you with third party vendors who need to know information about you in order to provide their services to us. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information) and those that help us understand and enhance our Services (like analytics providers). We require vendors to agree to privacy commitments in order to share information with them.

With your consent or when considered a legitimate interest that does not negatively affect your rights and freedoms as an individual, we may also share your data with other third parties. These third parties and the reason for sharing your data with them is listed below:

• UKAS     UKAS is our accreditation body and in order to maintain our accreditation we are subject to audits by UKAS in order to verify that we are performing our services in a compliant manner. As part of these audits we make the audits we have conducted available to the UKAS auditors.
• NABCB  NABCB (The National Accreditation Board for Certification Bodies) is an Indian accreditation body. NABCB is our Accreditation body and in order to maintain our accreditation we are subject to audits by NABCB in order to verify that we are performing our services in a compliant manner. As part of these audits we make the audits we have conducted available to the NABCB auditors.
• EIAC     EIAC (Emirates International accreditation Centre) is an accreditation agency for United Arab Emirates. EIAC is our accreditation body and in order to maintain our accreditation we are subject to audits by EIAC in order to verify that we are performing our services in a compliant manner. As part of these audits we make the audits we have conducted available to the EIAC auditors.
• EGAC    EGAC (Egyptian Accreditation Council) is an accreditation body in Egypt. EGAC is our accreditation body and in order to maintain our accreditation we are subject to audits by SAC in order to verify that we are performing our services in a compliant manner. As part of these audits we make the audits we have conducted available to the EGAC auditors.
• SAC      SAC (Singapore Accreditation Council) is an accreditation body in Singapore. SAC is our accreditation body and in order to maintain our accreditation we are subject to audits by SAC in order to verify that we are performing our services in a compliant manner. As part of these audits we make the audits we have conducted available to the SAC auditors.
• DAkkS   DAkkS (Deutsche Akkreditierungsstelle) is an accreditation body in Germany. DAkkS is our accreditation body and in order to maintain our accreditation we are subject to audits by DAkkS in order to verify that we are performing our services in a compliant manner. As part of these audits we make the audits we have conducted available to the DAkkS auditors.
• CAI (Czech Accreditation Institute) is an accreditation body in Czech Republic. CAI is our accreditation body and in order to maintain our accreditation we are subject to audits by CAI in order to verify that we are performing our services in a compliant manner. As part of these audits we make the audits we have conducted available to the CAI auditors.
• INTEC   INTEC are our software development company who have helped us design and develop our Customer Management System and online portal. In order to properly understand our technical requirements INTEC have access to our audit documentation to ensure that it can be correctly integrated into our technical systems.

As Required by Law: We may disclose information about you in response to a subpoena, court order, or other governmental request.

To Protect Rights and Property: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of URS, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.

Business Sale or Transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that URS goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.

Aggregated and De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services.

Published Support Requests: And if you send us a request (for example, via a support email or one of our feedback mechanisms), we reserve the right to publish that request in order to help us clarify or respond to your request or to help us support other users.

Sale or Transfer: If were discussing selling or transferring part or all of a business, we may share information about you to prospective purchasers - but only so they can evaluate that business. If we are reorganised or sold to another organisation, we may transfer information we hold about you to them so they can continue to provide the services to you

Publicly Shared Information

Information that you choose to make public is, you guessed it, disclosed publicly. That means, of course, that information like your public profile, posts, other content that you make public on our system. Public information may also be indexed by search engines or used by third parties. Please keep all of this in mind when deciding what you would like to share.

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. To enhance the security of your account, we encourage you to observe good security best practices with your account information, such as choosing strong passwords when registering with our systems and keeping this information secret.

We employ a range of security controls throughout our organisation to ensure that we look after your personal data and protect it from loss, corruption or unauthorised access.

Retention

We only retain data for as long as is necessary to satisfy the following requirements:

Legal Requirements: We are required to meet legal obligations in terms of retention periods for some data, such as financial records and information.

Contractual: Your data will be retained for the duration of your contract, as required by us to fulfil our contractual obligations. Following the end of the contract term we retain your information for a period of 3 years for marketing and business analysis purposes.

Marketing: Where data is held for marketing purposes then we hold this for 1 year of inactivity prior to destruction.

Business Analysis: Where data is held for business analysis purposes, data is limited to only that necessary to perform the analysis. We retain business analysis data for 4 years.

Data Destruction/Erasure

We always aim to keep the amount of personal data we hold to a minimum and so, unless we have received a specific request from you to erase any of your data before the retention periods expire, we will destroy/erase with an expired retention period as soon as the retention period has expired.

Your Choices

You have several choices available when it comes to information that we hold about you:

Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services may not be accessible (contact us for more information).

Opt-Out of Electronic Communications: You may opt out of receiving promotional messages from us. Just follow the instructions in those messages. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices.

Set Your Browser to Reject Cookies: At this time, URS does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using URS’s websites, with the drawback that certain features of URS’s websites may not function properly without the aid of cookies.

Your Rights

When it comes to personal data you have defined rights regarding how your data is collected, processed and shared. These rights are explained below:

The Right of Access: You have the right to request that we show you what personal data of yours we hold and process.

The Right to Withdraw Consent: Where you have specifically given us consent to process your data then you have the ability to withdraw that consent at any time. Please be aware that where that data is used to provide your with services, then withdrawal of consent to use this data may negatively impact on our ability to provide those services for you.

The Right to Erasure: In specific circumstances, you have the right to request that any data we hold on you be erased. This includes where:

• Your personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
• You withdraw consent.
• You object to the processing and there is no overriding legitimate interest for continuing the processing.

The Right to Object: There are cases where we may process some of your data in order to help us assess and improve our business. This type of processing may not be supported by a contractual requirement or your consent, but would have been carefully assessed to ensure that we have a clear legitimate interest in doing so that does not adversely affect you as an individual.

In these instances, we make you aware of these activities along with your right to object to this kind of processing should you wish.

The Right to rectification: If you become aware that any data we hold is incorrect you have the right to request that this data be corrected

The Right to Data Portability: You have the right to request that we provide you with an electronic copy of any data you have given to us as part of a contractual relationship or following your consent. This also includes any data about you that has been generated automatically as part of these agreements.

The Right to Restrict Processing: In some situation you may require us to restrict processing, such as following an objection or if data accuracy is in question. Where you exercise your right to restrict processing we shall not recommence processing without first notifying you.

Automated Decision Making: As part of our ongoing efforts to improve the speed and quality of our service we use some automated decision-making processes. These processes are designed to provide fast, consistent results based on information contained within your personal data. If you are unhappy with having automated decisions made based on your personal data then you have the right to request that these decisions are conducted by one of our staff instead.

Exercising your rights

If you wish to exercise any of your rights we would be happy to help you. Please use the contact details below to communicate your requirements.

Other Things You Should Know

Transfer of Information outside of the EEA

From time to time we may transfer your personal information to our group companies, suppliers or service providers based outside of the EEA for the purposes described in this privacy policy.  If we do this your personal information will continue to be subject to one or more appropriate safeguards set out in the law.  These might be the use of model contracts in a form approved by regulators, or having our suppliers sign up to an independent privacy scheme approved by regulators (like the US ‘Privacy Shield’ scheme).

Ads and Analytics Services Provided by Others

Ads appearing on any of our Services may be delivered by advertising networks. Other parties may also provide analytics services via our Services. These ad networks and analytics providers may set tracking technologies (like cookies) to collect information about your use of our Services and across other websites and online services. These technologies allow these third parties to recognize your device to compile information about you or others who use your device. This information allows us and other companies to, among other things, analyse and track usage, determine the popularity of certain content, and deliver advertisements that may be more targeted to your interests. Please note this Privacy Policy only covers the collection of information by URS and does not cover the collection of information by any third-party advertisers or analytics providers.

Registering a Complaint

If you have any complaints about the way in which your personal data is being handled, then please contact us using the contact details below. Alternatively, you may also contact the national supervisory authority to register a complaint, their details can be found at https://ico.org.uk or http:www.bfdi.bund.de.

Contact Details

To contact us about your personal data or with any data requests, you may contact our data controller at:

United Registrar of Systems (Holdings) Ltd.
United House
28 Poole Hill 
Bournemouth
BH2 5PS
T: +00 44 1202 552 153
E: info@urs-holdings.com
W: urs-holdings.com