Origo respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data, tell you about your privacy rights and how the law protects you when:
- you visit our websites on the domains origo.com, unipassmailock.com and unipass.co.uk and all associated sub-domains (regardless of where you visit them from) (“Sites”); and
- when you use any of the following services which we provide via our Sites: Standards, Origo Transfer Service, Integration Hub, Mortality Screening, Agency Services, Unipass Identity, Unipass Mailock, Unipass Letter of Authority and Origo Communities (“Services”) provide.
The following definitions are used in this privacy notice:
The following definitions are used in this privacy notice:
- Client: means a financial services business which has entered into contract with Origo for any of our Services;
- Registered User: means an individual employee, director, officer, contractor or agent of a Client who is authorised by that Client and is registered to use a Service; and
- User: means any person accessing our Sites.
Important information and who we are
The data we collect about you
How your personal data is collected
How we use your personal data
Disclosures of your personal data
Your legal right
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data through your use of the Sites and Services.
The Sites are not intended for children and we do not knowingly collect data relating to children.
For some of the Services we provide we will be the processor and Clients will be the controllers. However for all Services we will be the controller in relation to the personal data which we request from Registered Users in order to set up and manage their access to the Service.
We are also the controller in relation to personal data we obtain from Users accessing our Sites. Origo is collectively referred to as “Origo”, "we", "us" or "our" in this privacy notice.
The Origo Information Security Manager is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights set out below, you can contact the Information Security Manager by using the contact details set out below.
Our full details are:
Origo Services Limited (UK Company Number: SC115061)
Name or title: Information Security Manager
Email addresses: email@example.com
Postal address: 7 Lochside View, Edinburgh, Scotland, EH12 9DH
Telephone number: 0131 451 5181
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 26th August 2021
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Sites, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may check the details you provide with fraud prevention agencies and share your information with them if we suspect fraud. It is important that you don’t provide false, inaccurate information or impersonate another individual.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Profile Data is the information provided about you when forms on our Sites are completed, including information provided to create an account and log-in details for our Services including name, last name, username, employer (Client) name, email address, telephone numbers and IRN.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Sites.
- Usage Data includes information about how you use our Sites and Services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific site's feature or the number of Service types that are purchased. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Services). In this case, we may have to cancel delivery of the Service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Profile and Financial Data by filling in forms, providing documentation or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- purchase or use our Services;
- create an account on our Sites or otherwise;
- request marketing to be sent to you; or
- give us some feedback.
- Clients. Our Clients may provide Profile Data when registering you to be able to use the Services.
- Automated technologies or interactions. As you interact with our Sites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers and search information providers.
- Transaction Data from providers of technical, payment and delivery services.
- Profile Data from publicly available sources, such as the electoral roll and the FCA Register.
- Financial Data from private institutions who make such information available to us, such as credit reference agencies.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with a Client and/or Registered User for the Services and which involves your accessing the Services.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by writing to The Marketing Team at the address notified above.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type Of Data
Lawful Basis For Processing Including Basis Of Legitimate Interest
To register you as a new Client or Registered User
Performance of a contract with you
To provide the Services to you including:
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(c) Necessary for the legitimate interests of others (preventing fraud)
To manage our relationship with you which will include:
(b) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated, study how Clients and Registered Users use our Services and to improve our Services into the future)
To administer and protect our business, Sites and Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with our legal obligations
To deliver relevant Sites content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(c) Marketing and Communications
Necessary for our legitimate interests (to study how Client and Registered Users use our Services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Sites, Services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of Clients and Registered Users for our Services, to keep our Sites updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about Services that may be of interest to you
(d) Marketing and Communications
Necessary for our legitimate interests (to develop our Services and grow our business
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Profile, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services and offers may be relevant for you and send to you through our marketing messages.
You will receive marketing messages from us if you have requested information from us or purchased Services from us and you have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us or unsubscribing from our marketing list.
We use analytics cookies to collect information on website activity (such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site and, when entering our website from another website, the address of that web site). This information on its own does not identify an individual but it does provide us with statistics that can be used to improve our website.
The browsers of most computers, smartphones and other web-enabled devices are usually set up to accept cookies. If your browser preferences allow it, you can configure your browser to accept all cookies, reject all cookies, or notify you when cookies are set. Each browser is different, so check the "Help" menu of your browser to learn about how to change your cookie preferences. However, please remember that cookies are often used to enable and improve certain functions on our website. If you choose to switch certain cookies off, it may affect how our websites work and certain functionality may not work. More information about cookies can be found on allaboutcookies.org.
- Understanding how you use the Sites and Service: we use a range of services to understand how you use our Sites and Service including Google Analytics and/or Clicky Web Analytics. This helps us continually improve our Services and deliver more relevant and useful content to you.
- Behavioural and retargeting: Origo collects data about your activities that does not personally or directly identify you when you visit our Sites. This information may include the content you view, the date and time that you view this content, the Services your use or purchase, or your location information associated with your IP address. We may use the information we collect to occasionally provide you more relevant advertisements (referred to as “retargeting”). We collect information about where you saw the ads we serve you and what ads you clicked on.
In order to accept cookies when browsing our Sites, simply accept cookies in the message that appears on your screen. You can disable cookies by adjusting your browser settings. Each browser is different, so check the “Help” menu of your particular browser (or your mobile phone's handset manual) to learn how to change your cookie preferences. The “Help” menu on the toolbar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Where Origo is the processor and shares personal data in performance of a contract.
- Public databases and credit reference agencies who assist in providing the Services.
- Service providers who provide payment, marketing, IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers based within the EU who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances, especially in the prevention of money laundering and fraud.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Third Parties where we act as an introducer
Where we are acting as an introducer to a third party, the use of any of your data provided to that third party will be as stated in their terms and conditions of business.
6. International transfers
Some of our external third party suppliers are based outside the European Economic Area (EEA). Their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EEA and the US. For further details, see European Commission: EU-US Privacy Shield.
7. Data security
The security of your personal information is important to us. We follow best practice industry standards to protect the personal information submitted to us, both during transmission and once we receive it. Commonly referred to as “bank-level” security, this means we use the same encryption standards that you would have with your own bank. We also routinely run security audits to ensure we meet these standards at all times.
When you enter sensitive information (such as bank credentials or a credit card number) you should always be encrypted using secure Transport Layer Security (TLS). We will always use such encryption.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In some cases we may retain your personal data for at least 7 years to meet our regulatory compliance requirements or as needed to provide to you the Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. If your account is deleted, all personal information will be removed from our systems except for any Transaction Data, Technical Data and records required to comply with our legal obligations, resolve disputes and enforce our agreements.
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.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Access to information: You have the right to request a copy of the information we hold about you.
- Ensuring accuracy of information: We want to make sure that your personal information is accurate and up-to-date. You may ask us to correct or complete information that is inaccurate or incomplete.
- Right to erasure: You may have a right to erasure, which is more commonly known as the ‘right to be forgotten’. This means that in certain circumstances you can require us to delete personal information held about you.
- Ability to restrict processing: You may also have the right to require us to restrict our use of your personal information in certain circumstances. This may apply, for example, where you have notified us that the information we hold about you is incorrect and you would like us to stop using such information until we have verified that it is accurate.
- Right to data portability: You may have the right to receive personal data we hold about you in a format that enables you to transfer such information to another data controller (e.g. such as another service provider).
- Review by an independent authority: You will always have the right to lodge a complaint with a supervisory body, including the ICO as listed above.
- Preventing direct marketing: We do not sell your personal data. From time to time, we may send emails containing marketing information and other news about us. This is considered direct marketing. We will always ensure that we have your consent to use of your personal data for direct marketing.
- Objecting to other uses of your information: You may also have the right to object to our use of your information in other circumstances. In particular, where you have consented to our use of your personal data, you have the right to withdraw such consent at any time.
If you would like further information on how you can exercise these rights, please email us at firstname.lastname@example.org.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.