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QEasyID Privacy Notice

Textele juridice din QEasyID rămân în limba engleză.

Textul evidențiat între paranteze drepte nu este încă final. Este un detaliu care trebuie completat sau o alegere care trebuie făcută.

DRAFT: pending UK solicitor review

These are drafts for review by a UK solicitor, not legal advice.

Version [VERSION NUMBER]. Last updated [DATE]. Applies from [DATE].

The short version

  • We are [COMPANY NAME] Ltd. We run qeasyid. This notice explains how we use personal information when we decide why and how it is used. The law calls this being the "controller".

  • qeasyid helps organisations onboard new workers. When an organisation collects information about you through qeasyid, such as your onboarding forms and its checks, that organisation is in charge of it. We only store and process it for them. Please read that organisation's privacy notice as well.

  • If you are a worker, you can keep a reusable profile in your own qeasyid account. You decide what to send to each organisation: its required items, with one tap, or the items you pick. Nothing is ever ticked for you, and nothing is sent until you press Send on a summary screen.

  • Some things never travel between organisations: right to work check results, criminal-record or DBS information (even a clear result), health answers, references, and anything an organisation created, such as approvals, notes, contracts and signatures. Each organisation runs its own checks.

  • Once you send something, that organisation keeps its own copy, under its own privacy notice and its own retention rules.

  • Organisations cannot search for you or browse profiles. From your profile, they receive only what you send them.

  • We do not sell personal information. We do not use advertising trackers. We do not make automated decisions about you.

  • You have rights over your information, including getting a copy, correcting it, deleting it and taking it with you. Section A16 explains how to use them. You can complain to us and to the Information Commission (the ICO).

Which parts apply to you

If you are Read
a visitor to qeasyid.com or qeasyid.app A1 to A4, then A7 to A19
an owner, manager, billing contact or other contact at an organisation that uses qeasyid, for example the person who accepted our Customer Agreement for it or a contact named in its order form A1 to A3, A5, then A7 to A19
a worker with a qeasyid account A1 to A3, A6, then A7 to A19
[someone a worker named as an emergency contact or referee] [A1 to A3, A6.12, then A7 to A19]

A1. Who we are and how to contact us

A1.1 qeasyid is provided by [COMPANY NAME] Ltd, a company registered in [England and Wales] under company number [COMPANY NUMBER]. Our registered office is [REGISTERED ADDRESS].

A1.2 To contact us about this notice or your information, email [PRIVACY EMAIL], use [the app: Settings > Privacy > Contact us], or write to us at [REGISTERED ADDRESS].

A1.3 [DATA PROTECTION OFFICER OR CONTACT]

A1.4 [ICO registration: before launch]

A1.5 We are a UK company, so UK data protection law applies to what we do: the UK GDPR, the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR).

A2. Words we use

A2.1 In this notice:

  • qeasyid or the service means the websites at qeasyid.com and qeasyid.app, the qeasyid web app, and the qeasyid apps on the App Store and Google Play.

  • we, us and our mean [COMPANY NAME] Ltd.

  • organisation means an employer, council, school or other organisation that uses qeasyid to onboard its workers under a contract with us.

  • owner and manager mean people an organisation lets use qeasyid on its behalf. Owners have full access. Managers have the access an owner gives them.

  • billing contact means the person we deal with about an organisation's invoices.

  • worker means a person an organisation invites to onboard through qeasyid, such as an employee, agency worker, subcontractor or volunteer, and anyone who has a worker account.

  • worker account means a worker's own qeasyid account.

  • profile means the information a worker keeps in their worker account so that they can send it to organisations.

  • onboarding records means the information an organisation collects or creates about a worker through qeasyid, such as completed forms, uploaded documents, checks, approvals, notes, contracts and signatures, and anything a worker has sent it.

  • send means a worker choosing items from their profile and confirming that we send copies to an organisation.

  • controller means the person or organisation that decides why and how personal information is used. Processor means a person or organisation that handles personal information only on a controller's instructions.

  • personal information means information about a living person who can be identified ("personal data" in the law). Special category information means information about a person's health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric information used to identify them, sex life or sexual orientation.

A3. Two roles: when we are in charge, and when an organisation is

A3.1 We are the controller for:

(a) information about visitors to our websites (section A4);

(b) information about owners, managers, billing contacts and other contacts at organisations that we use to run accounts, keep qeasyid secure, give support, send invoices, keep evidence of our contracts and market our service to organisations (section A5);

(c) each worker's own account and profile, including the worker's remembered choices, our record of what the worker was shown, what they chose, which organisation it went to and when, and the list of organisations the worker joined through qeasyid (section A6);

(d) [a copy of an organisation's activity records, which we keep after its contract ends only to establish, exercise or defend legal claims (A5.5). These records can include information about workers, for example that a manager opened a worker's record.]

A3.2 An organisation is the controller of its onboarding records. These include the forms you complete for it, the documents you upload to it, its checks and decisions, and anything you send it from your profile once it arrives. For onboarding records we are only the organisation's processor. We act on its documented instructions, under a written contract with it (the DPA), and we do not use onboarding records for our own purposes.

A3.3 Please also read the organisation's privacy notice. It explains what the organisation collects, why, its lawful basis, who it shares information with, how long it keeps it and how to use your rights with it. If you send us a request or complaint about onboarding records, we pass it to the organisation within [2] working days and tell you we have done so. If it also concerns your own account or profile, we deal with that part ourselves.

A3.4 Example. You complete a construction company's onboarding form in qeasyid and upload a photo of your CSCS card. The company decides what to ask, what to check and how long to keep it. We store it for the company. If you also keep your CSCS card details in your own profile, we are in charge of that copy.

A3.5 Our staff cannot see an organisation's onboarding records unless that organisation grants them temporary access, for example to fix a problem it has reported. If the law requires us to disclose an organisation's records, we act as our contract with that organisation describes.

A4. Visitors to our websites

A4.1 What we collect.

(a) Technical information that our servers and security tools receive when you visit: your IP address, browser and device type, the pages you request, and the date and time.

(b) What you send us through a form or by email, such as your name, work email address, organisation and message.

(c) If we use statistics, information about how pages are used, combined so that it does not identify you.

A4.2 Why we use it. To show you the website and keep it secure, to answer your questions and requests for a demonstration, and to understand how the website is used overall.

A4.3 Lawful basis. Legitimate interests (section A7). You do not have to use our forms, but if you do not give us your contact details we cannot reply to you.

A4.4 Cookies and similar technologies. See section A12. We do not use advertising cookies or cross-site tracking.

A5. Owners, managers, billing contacts and other contacts at organisations

A5.1 What we collect.

(a) Account details: your name, work email address, [work phone number], job title or role, your organisation, and the permissions your organisation gives you.

(b) Sign-in and security information: sign-in times, IP address, device and browser details, two-step verification settings, failed sign-ins and security alerts.

(c) Support conversations: what you tell us when you ask for help.

(d) For billing contacts: name, contact details, invoices, payment status and correspondence. [PAYMENT PROVIDER] handles card and bank payment details. We do not see or store full card numbers.

(e) Your marketing preferences.

(f) If you accept our Customer Agreement for your organisation: your name, email address and job title, your confirmation that you may accept for it, the date and time[, the IP address used] and the version you accepted.

(g) If an order form names you, for example as the data protection, security incident or freedom of information contact, the contact for notices or disputes, or a person who signs it: your name, role and contact details[, and your signature].

A5.2 Where it comes from. From you, from your organisation (for example when an owner invites you, sets your permissions or names you in an order form), and from our systems when you use qeasyid. You need to give us your name and work email address to have an account. Online acceptance of our Customer Agreement is not possible without the details in A5.1(f).

A5.3 Why we use it.

(a) To create and run your account for your organisation and apply the permissions it sets.

(b) To keep qeasyid secure: two-step verification, spotting unusual sign-ins, and preventing fraud and misuse.

(c) To help you when you ask for support.

(d) To invoice your organisation and keep accounting records.

(e) To send service messages, such as security alerts, notice of changes to the service, and the task alerts your organisation sets up.

(f) To tell you about qeasyid services that may interest your organisation (A5.6).

(g) To deal with legal claims and meet our legal duties.

(h) To keep evidence of our contract with your organisation.

(i) To contact the people an order form names about the matters it names them for.

A5.4 Signing in. Owners and managers sign in with a passkey. A passkey checks two things at once: the device it is on, and that device's fingerprint, face or screen lock. Our Customer Agreement (clause 5.5) requires this.

A5.5 Activity records inside your organisation's workspace. qeasyid records what owners and managers do with onboarding records. For example, each time an owner [or manager] opens health or criminal-record information, the system records who opened it and when. These records belong to your organisation. We keep them for it as its processor, and it decides who can see them. [after an organisation's contract ends, we keep a copy of its activity records as controller, only to establish, exercise or defend legal claims, for [CLAIMS PERIOD].] Separately, we keep our own security logs (A5.1(b)) as controller, and we use them only to keep qeasyid secure.

A5.6 Business-to-business marketing.

(a) We may email you about qeasyid at your work address. Our lawful basis is legitimate interests (A7.2(c)).

(b) If your organisation is a company or another body that is a legal person separate from its members, PECR allows us to email you without asking first, as long as we say who we are and give you a simple way to opt out.

(c) If you are a sole trader, or in a partnership that PECR treats as individuals, we email you only if you have agreed, or if we got your details when you bought, or discussed buying, qeasyid from us. In that second case we tell you only about similar qeasyid services, and you can opt out when we collect your details and in every message.

(d) You can opt out at any time using the link in each email or by writing to [PRIVACY EMAIL]. We then keep your email address on a "do not contact" list so that we do not email you again.

(e) We do not put tracking pixels in our emails.

A5.7 Councils, schools and other public bodies. This section applies to their staff in the same way.

A6. Workers with a qeasyid account

A6.1 Your account. When you accept an invitation, we create your worker account. It holds:

(a) your name, and the email address you sign in with;

(b) the public key of each passkey you make (the private key never reaches us), and your password, if you set one, stored only in a scrambled (hashed) form;

(c) whether you turned on biometric unlock;

(d) your language and notification settings;

(e) security records, such as sign-in times, IP addresses and device details;

(f) the organisations that invited you and that you joined through qeasyid [and the dates], so that you can use your account with each of them;

(g) your remembered choices, and our record of what you were shown, what you chose, which organisation it went to and when (A6.6 and A6.7).

A6.2 Biometric unlock. In the apps you can choose to unlock qeasyid with your phone's fingerprint or face recognition. Your phone does the check and tells the app only whether it worked. We never receive your fingerprint or face data.

A6.3 Your reusable profile.

Your profile is information you choose to keep in your account so that you can send it to organisations without typing it again. It can hold:

(a) your first and last name and date of birth;

(b) your address and phone number;

(c) CSCS and plant operator cards, with their photos;

(d) certificates you hold, other than a driving licence, with their copies;

(e) your work history, as you describe it, for example employer names, dates and job titles.

Your profile does not hold health information or any other special category information.

A6.4 Where profile information comes from. From you. After you send items to an organisation, we offer to keep a copy of what you typed or uploaded, and save it only if you press "Save to my profile". Never-travel items (A6.5) can never be saved to your profile.

A6.5 What never travels. These items are never part of your profile, and are never passed from one organisation to another through qeasyid:

Never travels Why
Right to work check results, including online share-code check results and any verification provider's results Each employer must carry out its own check. A check done for one employer does not count for another.
Criminal-record or DBS information, including a clear result and any self-declaration This is criminal offence data even when the result is clear.
Health answers, and any fitness-for-work outcome Health information is special category data. qeasyid keeps health questions locked until the organisation records a job offer[, apart from the narrow questions the law allows before an offer, such as adjustments for an interview: see Customer Agreement clause 6.5].
References Organisations get references themselves. Schools should get them directly from referees.
Anything an organisation created, such as approvals, decisions, notes, checklists, "checked" or "verified" marks, contracts, signatures, signed documents and activity logs These are the organisation's own records.

Each organisation runs its own checks. A check one organisation made never counts for another, and we never show an organisation that another organisation checked, approved or verified anything about you.

A6.6 How sending works.

(a) An organisation invites you using contact details it already has. It cannot search for you or browse profiles, and we do not match workers with organisations.

(b) Until you respond to an invitation, the organisation does not learn whether you already have a qeasyid account or what is in your profile.

(c) You choose what to send to each organisation: its required items, with one tap, or the items you pick. We send only what you confirm.

(d) You see only the items the organisation asked for. Each is marked required or optional, with the one-line reason the organisation gives. "Send the [number] required items" and "Choose items" are equally visible. The order of the items only helps you find them. It is not advice from us about what to send.

(e) Only organisations we have allowed to ask can request items from your profile.

(f) Your earlier choices. Nothing is ever ticked for you. From the second time you send, you can press "Use your choices from last time", shown next to an equally visible "Choose items", and you can review and change every item before you send. You can clear your remembered choices at any time in [Settings > Sharing]. Clearing them does not delete our record of what you sent (A6.7(f)).

(g) Before anything is sent, you see a summary of exactly what will go to which organisation. Pressing Send on that summary screen is your confirmation.

(h) Nothing is sent automatically, including the names of organisations you used qeasyid with before.

A6.7 After you send: the organisation's own copy.

(a) The organisation receives its own copy. From then on, that copy is part of the organisation's onboarding records. The organisation is its controller, and the organisation's privacy notice and retention rules apply. We hold the copy for the organisation as its processor.

(b) You cannot unsend information. To have it corrected or deleted, ask the organisation. It may have to keep some records by law. For example, employers must keep copies of right to work documents for the whole employment and for two years after it ends.

(c) If you change your profile later, the organisation's copy does not change. You can send the new version if you want the organisation to have it.

(d) Each organisation decides for itself what to do with what you send. Organisations cannot see each other's records through qeasyid.

(e) If you delete your account, organisations keep their copies under their own rules.

(f) We keep a record of what you were shown, what you chose, which organisation it went to and when. You can see it in [Settings > Sharing history]. The record names the items you sent, for example "National Insurance number", and does not keep a second copy of what they contained.

A6.8 Forms you complete for an organisation. When you fill in an organisation's onboarding form or upload a document to it, that information goes straight into the organisation's onboarding records (A3). It is not added to your profile, unless you choose to save it there.

A6.9 Our staff and your profile. Our staff look at your profile only:

(a) when you ask us for help and give permission in the app;

(b) when it is necessary to investigate a security problem or misuse of qeasyid; or

(c) when the law requires it.

Each access is logged.

A6.10 Do you have to give us information? You need an email address to have an account, so that you can sign in safely. Everything in your profile is your choice. If you do not keep a profile, you can still complete an organisation's forms, but you will need to enter your details for each organisation. An organisation may need some information from you for its own reasons, for example to pay you or to meet a legal duty. Its privacy notice explains what it needs and why.

A6.11 Councils, schools and other public bodies. When you join a council, a school or another public body, our own use of your account and profile still relies on our contract with you. We do not rely on that organisation's public functions.

A6.12 [If a worker added your details. If a worker adds you to their profile as an emergency contact or referee, we hold your name and contact details [and your relationship to the worker] as controller. They come from the worker. We use them only so that the worker can send them to organisations the worker chooses, and we do not contact you ourselves. Once the worker sends them, each organisation keeps its own copy under its own privacy notice. We keep them until the worker deletes them or their account. You have the rights in A15 and can complain as A17 describes.]

A7. Our lawful bases

A7.1 The law requires a lawful basis for each use of personal information. These are ours:

Who What we do Lawful basis
Website visitors Show the website and keep it secure (server logs, protection against attacks and automated abuse) Legitimate interests
Website visitors Answer enquiries and demonstration requests Legitimate interests
Website and app users Combined statistics to improve qeasyid, if used Legitimate interests, with a simple way to object
Owners and managers Create and run accounts and permissions for your organisation Legitimate interests, because our contract is with your organisation. If you are the customer yourself, for example a sole trader: contract
Owners, managers and billing contacts Support and service messages Legitimate interests
Billing contacts Invoices, payments and accounting records Legitimate interests; legal obligation (keeping accounting and tax records)
People who accept our Customer Agreement for an organisation Keep a record of the acceptance as evidence of the contract Legitimate interests
Contacts named in an order form Contact you about the matters the order form names you for Legitimate interests
Business contacts Business-to-business marketing Legitimate interests. You can object at any time
Workers Run your account: sign-in, passkeys, biometric unlock setting, notifications Contract with you
Workers Keep your profile Contract with you
Workers Keep a list of the organisations you joined through qeasyid Contract with you
Workers Send the items you choose to the organisations you choose, and keep your last choices so that you can reuse them Contract with you
Workers Keep a record of what you were shown, what you chose, which organisation it went to and when Contract with you (to show you your history); legitimate interests (to deal with disputes and legal claims)
[Workers] [Count, across all workers, how often each type of item is sent, so that we can list the most-sent items first] [Legitimate interests]
Workers Optional extras Consent, which you can withdraw at any time
[Emergency contacts and referees] [Hold the details a worker adds, so that the worker can send them to organisations they choose] [Legitimate interests (ours and the worker's)]
Everyone Security and fraud prevention Legitimate interests
Everyone Handling complaints and rights requests; meeting other legal duties; answering requests from courts, the police and other authorities that the law requires us to answer Legal obligation
Everyone Giving information to the police or another public body where the law allows but does not require it, and only to detect, investigate or prevent crime, to protect national security, to respond to an emergency, to safeguard a vulnerable person, or when a public body asks for it and says it needs it for its public tasks (A8.1(e)) Recognised legitimate interests
Everyone Making, pursuing or defending legal claims Legitimate interests

A7.2 Legitimate interests explained. When we rely on legitimate interests, we have weighed our interests against yours:

(a) Security and fraud prevention. Our interest is keeping accounts, documents and personal details safe, and stopping account takeovers, fake accounts and people pretending to be someone else. This protects you too: identity documents and bank details are valuable to criminals. The law gives ensuring the security of network and information systems as an example of a legitimate interest. We use sign-in records, IP addresses, device details, security alerts and, where we need to investigate, how an account was used. Safeguards: we use the minimum; only authorised staff can see it; we keep it only for the periods in A10; we never use it for marketing; and we never give it to organisations to help them make decisions about you. If we find that someone used an account to pretend to be someone else, we may tell the organisations that received information from that account, so that they stop relying on it. We believe the balance favours this processing: weak security would put you at far greater risk than keeping limited security records for a short time.

(b) Statistics. Our interest is understanding which parts of qeasyid are used, so that we can improve them. We use only combined statistics that do not track you as an individual, across sites or for advertising. Any provider we use acts only on our instructions. You can object at any time at [OPT-OUT LINK].

(c) Business-to-business marketing. Our interest is telling organisations about qeasyid. The law gives direct marketing as an example of a legitimate interest. We use only work contact details, we send marketing emails only as A5.6 describes, and if you object we stop.

(d) Running accounts for organisations. Our contract is with your organisation, not with you personally. Our interest, and your organisation's, is that you can use the service your organisation pays for, that we can show how and when the contract was made, and that we can reach the people it names. We use only what we need for those purposes.

(e) Legal claims. We keep limited records, such as our record of what a worker was shown, what they chose, which organisation it went to and when, so that we can show what happened if there is a dispute.

(f) [Ordering the sending screen. Our interest is helping workers find the items they need quickly. Using our own records of sends, we count how often each type of item is sent across all workers. We keep only the totals, which do not identify anyone. We never use organisations' forms or onboarding records for this, we never tick anything for you, and we do not label items as popular. The order never changes what is sent: only you decide that.]

(g) [Emergency contacts and referees. Our interest, and the worker's, is that the worker can give an organisation these details without typing them again. We use them for nothing else, and the worker can delete them at any time.]

A7.3 You can object to any use of your information that relies on legitimate interests or on a recognised legitimate interest. See A15.7.

A7.4 Consent. We ask for consent only for optional extras, such as [OPTIONAL EXTRAS, IF ANY]. We never use pre-ticked boxes. You can withdraw consent at any time in [Settings] or by writing to us. Withdrawing does not affect what we did before.

A7.5 Legal obligations. Some processing is required by law, for example keeping accounting records and answering rights requests and complaints.

A8. Who we share information with

A8.1 We share personal information only as this notice describes:

(a) Organisations you choose (workers). We send copies of the items you confirm to the organisations you choose (A6.6).

(b) Your organisation (owners, managers and billing contacts). Your organisation's owners can see your account details, permissions and activity in its workspace.

(c) Our service providers. Companies that provide services to us, such as hosting, file storage, email, text messages, payments and customer support, act only on our instructions, under contracts that protect your information. [SERVICE PROVIDER LIST] We publish the current list at [SERVICE PROVIDERS PAGE URL].

(d) Professional advisers, such as lawyers, accountants, auditors and insurers, who must keep information confidential.

(e) Authorities and others, where the law requires or allows it, for example to comply with a court order, to prevent or detect crime, to protect someone's safety, or to deal with legal claims. We check each request and give only what is needed.

(f) A buyer or successor, if our business or its assets are sold or reorganised. They must protect your information as this notice describes, and we will tell you.

A8.2 Apple and Google run the app stores. When you download or update a qeasyid app, they collect information under their own privacy notices. We do not control that.

A8.3 We do not sell personal information, and we do not share it for advertising.

A9. Transfers outside the UK

A9.1 We store personal information in [the UK] [the UK or the European Economic Area (EEA)].

A9.2 Some service providers may access personal information from outside the UK, for example to give support. That counts as a transfer.

A9.3 When personal information leaves the UK, we protect it in one of these ways:

(a) UK law treats transfers to EEA countries as approved;

(b) US companies certified under the UK Extension to the EU-US Data Privacy Framework, where the certification covers the type of information;

(c) otherwise, the International Data Transfer Agreement or the UK Addendum to the EU standard contractual clauses issued by the ICO, after we have assessed that protection will not be materially lower than in the UK.

Contact us for a copy of the safeguards.

A9.4 Some of our service providers belong to groups based outside the UK. The laws of those countries may allow their authorities to require information from the provider even when it is stored in the UK. [SAFEGUARDS WE USE]

A10. How long we keep information

A10.1 We keep personal information only as long as we need it for the purposes in this notice.

Information How long we keep it
Website server and security logs [N] days
Website enquiries and demonstration requests [N] months after our last contact with you
Owner and manager accounts While the account is active, then [N] months after it is removed or the organisation's contract ends
Record of online acceptance of our Customer Agreement (A5.1(f)) While the contract runs, then [N] years after it ends
Contacts named in an order form (A5.1(g)) While the contract runs, then [N] years after it ends
[Copy of an organisation's activity records after its contract ends (A5.5)] [[CLAIMS PERIOD], then deleted]
Security logs for all accounts [N] months
Support conversations [N] years after the conversation ends
Billing and accounting records [N] years
Business marketing contacts Until you opt out, or [N] years after our last contact. Opt-outs stay on our "do not contact" list
Worker account and profile Until you delete them, or until we close an inactive account (A10.3)
Organisations you joined through qeasyid [PERIOD]
Remembered choices (for "Use your choices from last time") Until you clear them or delete your account
Record of what you were shown, what you chose, which organisation it went to and when [N] years after the send
[Emergency contacts' and referees' details] [Until the worker deletes them or their account]
Complaints and rights requests [N] years after we close them
Backups Deleted or put beyond use within [N] days

A10.2 Onboarding records are kept for as long as each organisation decides. Its privacy notice tells you how long.

A10.3 Inactive worker accounts. If you do not sign in for [N] years, we will delete your worker account and profile. We will email you [N] days before, and again [N] days before. If you sign in, your account stays open.

A11. How we protect information

A11.1 We protect personal information with technical and organisational measures that suit the risk. They include:

(a) encryption when information travels and when it is stored;

(b) keeping each organisation's records separate[, with separate encryption keys];

(c) passkeys, which every owner and manager must have and workers use as clause B5.2 says; a lost passkey is replaced only through a one-use link, never emailed, after someone confirms who you are;

(d) staff access only where needed, approved and logged, and no staff access to onboarding records without the organisation's temporary permission (A3.5);

(e) regular security updates, monitoring and testing;

(f) encrypted backups.

A11.2 No system is completely secure. If a personal data breach involving information we control is likely to put you at high risk, we will tell you without undue delay. For onboarding records, the organisation decides whether to tell you, and we help it.

A11.3 You can help: make your passkey on a device only you can unlock, use a strong password that you do not use anywhere else if you set one, never share your sign-in details, and turn on biometric unlock only if you are the only person whose fingerprint or face is set up on your phone.

A12. Cookies and similar technologies

A12.1 Cookies and similar technologies store or read small pieces of information on your device, for example cookies, local storage in your browser and storage inside the apps. PECR controls how they are used.

A12.2 PECR lets us store or read information on your device without asking for your consent where this is strictly necessary to provide a service you asked for, for example to keep you signed in, to keep the service and your device secure, or to prevent fraud. Since 5 February 2026, PECR also allows this without consent where the only purpose is to collect statistics about how the service is used so that we can improve it, or to make our websites and apps look or work the way you prefer. For those uses we must give you clear and comprehensive information and a simple, free way to object. You can object at [OPT-OUT LINK].

A12.3 We store or read information on your device only for the uses in A12.2. We do not use advertising cookies, advertising pixels, cross-site tracking or profiling.

A12.4 What we store:

Name Where What it does Kind How long
[SESSION COOKIE NAME] Websites and web app Keeps you signed in Strictly necessary [Until you sign out, or N hours]
[SECURITY TOKEN NAME] Web app Protects forms against forged requests Strictly necessary [Session]
[BOT PROTECTION, IF USED] Websites and web app Tells people apart from automated attacks Strictly necessary (security) [N]
[LANGUAGE SETTING NAME] Websites, web app and apps Remembers the language you chose [Strictly necessary, or website preferences] [N months]
Saved form progress Web app and apps Keeps answers you chose to save on this device Strictly necessary Until you submit, clear or sign out
Sign-in token Apps (the phone's secure storage) Keeps you signed in and, with biometric unlock, lets your phone unlock the app Strictly necessary Until you sign out or turn biometric unlock off
Notification token Apps Delivers the notifications you allowed Strictly necessary Until you turn notifications off
[STATISTICS TOOL, IF USED] [WHERE] Combined statistics Statistics [N]

A12.5 Phone permissions in the apps. The apps use your camera only when you take a photo of a document, send notifications only if you allow them, and use biometric unlock only if you turn it on. You can change these in your phone's settings.

A13. Children and young workers

A13.1 [TO BE DECIDED]

A13.2 Our websites are for organisations and workers. They are not aimed at children.

A14. Automated decisions

A14.1 We do not make decisions about you based solely on automated processing. qeasyid may show an organisation that an item is missing or about to expire, but that is a prompt for its staff, not a decision. The organisation makes its own decisions about you, and qeasyid never approves or rejects anyone.

A15. Your rights

A15.1 You have the rights below over personal information we control. Some depend on our lawful basis, and some have limits.

A15.2 Access. You can ask for a copy of your personal information and for details of how we use it. We search for it in a reasonable and proportionate way.

A15.3 Correction. You can correct most of your information yourself in your account. You can also ask us to correct information that is wrong or incomplete.

A15.4 Erasure. You can delete items in your profile, or your whole account (clause B13 of the Worker Account Terms), or ask us to delete information. We may keep some information where the law allows, for example to deal with a legal claim.

A15.5 Portability. You can download the information you gave us for your account and profile in a structured, commonly used and machine-readable format. You can also ask us to send it directly to another organisation, where that is technically feasible.

A15.6 Restriction. You can ask us to limit how we use your information, for example while we check whether it is accurate.

A15.7 Your right to object. You can object at any time, on grounds relating to your particular situation, to our use of your information that relies on legitimate interests or on a recognised legitimate interest. We will stop unless we can show compelling legitimate grounds that override your interests, rights and freedoms, such as keeping accounts secure, or we need the information to make or defend a legal claim. You can object to business marketing at any time, and we will stop.

A15.8 Withdrawing consent. Where we rely on consent, you can withdraw it at any time.

A15.9 Onboarding records. For information an organisation holds, use your rights with that organisation. If you contact us instead, we pass your request on (A3.3).

A15.10 Complaints. You can also complain to us, and to the ICO, as section A17 explains.

A16. How to use your rights

A16.1 You can do many things yourself in the account settings: [Download my data], [Edit my profile] and [Delete my account].

A16.2 You can also email [PRIVACY EMAIL] or write to [REGISTERED ADDRESS].

A16.3 We may need to confirm your identity first. If so, our time limit starts when we have what we need.

A16.4 We reply within one month. If your request is complex, or you send several, we may extend this by up to two more months. If we do, we will tell you, with our reasons, within the first month.

A16.5 Using your rights is free. If a request is manifestly unfounded or excessive, for example because it is repetitive, the law allows us to charge a reasonable fee or to refuse. If we refuse, we will tell you why, and that you can complain to us or to the ICO, or go to court.

A17. Complaints

A17.1 If you are unhappy with how we use your personal information, please complain to us using our online form at [COMPLAINT FORM URL], by email to [PRIVACY EMAIL] or by post to [REGISTERED ADDRESS].

A17.2 We will acknowledge your complaint within 30 days of receiving it. We will look into it, keep you informed of progress, and tell you the outcome without undue delay.

A17.3 If your complaint is about an organisation's onboarding records, please complain to that organisation. If you send it to us, we pass it on and tell you.

A17.4 You can also complain to the Information Commission (the ICO), the UK data protection regulator, at any time: ico.org.uk/make-a-complaint, [ICO HELPLINE NUMBER AND POSTAL ADDRESS].

A18. Changes to this notice

A18.1 We update this notice when our use of personal information or the law changes. The date at the top shows the current version. Earlier versions are at [VERSION HISTORY URL].

A18.2 If we make an important change, we will tell you at least [N] days before it applies, by email or in the app.

A19. Language

A19.1 This notice is in English, whatever language you use qeasyid in. If you would like help understanding it, contact us at [PRIVACY EMAIL].