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Visit tracking privacy notice

Template

Each organisation is the controller here. The tracking page and Tracker app show this notice filled in with the organisation's name and privacy contact, or link to the organisation's own notice instead.

Draft for legal review. A template that [the organisation] adopts or replaces with its own notice.

[the organisation] sends you a link to follow your visit, so you know who is coming and when they'll arrive. This notice explains what information that uses.

[the organisation] is responsible for your information (the "controller"). It uses ROCC Tracker, provided by [ROCC legal entity name], to run the tracking page and send messages. ROCC only uses your information for [the organisation], following its instructions. For questions, or to use your rights, contact [the organisation's privacy contact].

What's used​

  • About you: your name, the visit address, and your email address or mobile number if [the organisation] has them. They're used to send you the link and updates. Your name and contact details are not shown on the tracking page.
  • About the visit: the appointment window, whether the operative is on the way or has arrived, and the expected arrival time. If the operative is running late, the page and a message tell you their new time.
  • About the operative: their name, their photo if [the organisation] has added one, and where they are while travelling to you. That's so you know who to expect, and can check it's them at the door.
  • If you turn on notifications: your browser gives the page an address at its notification service, run by the browser's maker (for example Google, Apple, Mozilla or Microsoft). It's used to tell you when the operative sets off, is about 5 minutes away and has arrived. Notifications show [the organisation]'s name, not the operative's name or your address, because lock screens can be seen by others. The address is deleted when the visit ends. Messages are encrypted, so the notification service can't read them. You can turn notifications off on the page, or in your browser's settings, at any time.
  • When you open the page: your device's IP address and browser details, which the hosting provider processes to deliver the page and protect it from attacks. The page doesn't use cookies, or advertising or analytics trackers. If you turn on notifications, your browser keeps a small notification helper (a service worker) for the site.

Why it's used, and on what basis​

To keep you informed about a visit [the organisation] has arranged with you. Notifications on your device are optional, and only sent if you turn them on. The lawful basis is [the organisation]'s legitimate interest in running visits efficiently and safely, and telling residents what's happening. Where your tenancy or contract with [the organisation] covers repairs or visits, it is also part of performing that contract.

Messages are only about your visit. They aren't marketing.

Who can see it​

  • [the organisation]'s staff, to arrange and manage visits.
  • ROCC and its hosting and email providers, only to run the service.
  • Anyone you share your link with. They can see the visit status and where the operative is while they're on the way, so please keep it to yourself and people you trust.

How long it's kept​

  • The operative's location on the way to you: shown only while they're travelling, then deleted 24 hours (or up to 30 days with visit history, or less if the organisation chooses) after the visit. It's mainly the operative's information, but it also shows when your visit happened.
  • The visit record (your name, contact details, address and the visit times): deleted the period the organisation sets (6 to 36 months; 24 by default) after the visit.
  • The record of messages sent to you: deleted after the period the organisation sets (3 to 24 months; 12 by default).

The link stops showing any location once the visit ends.

Your rights​

You can ask [the organisation] for a copy of your information, to correct it, or to delete or restrict it. You can also object to it being used. Contact [the organisation's privacy contact].

If you're unhappy with how your information is handled, you can complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113.