TRACE LMS Personal Data Notice

Notice About Your Personal Data
PROCESSED BY TRACE’s Learning Management System


Who needs your personal data?

TRACE International, Inc. and/or TRACE Inc. (“TRACE”) are joint “Controllers” of the personal data that you provide to us, that we already have or will gather about you, as you take online training courses provided by TRACE.  If your training was required by your employer or another company (“Company”), your training progress may be shared with them. Any such Company is a separate controller of your personal data.  Contact details for TRACE are set out below in the “What are your rights?” section.

Why we need it

In order to provide compliance training to you, TRACE needs to know some basic information about you and to keep track of your training progress.

What personal data we need

We collect and process the following categories of personal data in relation to you:

  • Basic contact information such as name, email address, and sometimes telephone number;
  • Employment-related information such as your employer and title; and
  • Training progress such as the names of TRACE courses you have taken, progress, and the dates of completion.

What we do with it

All personal data is processed by TRACE’s staff in the United States of America. TRACE’s limited number of service providers may have access to your personal data.  For example, for the purposes of IT hosting and maintenance this information is located on servers within the European Union that are hosted and maintained by a third party service provider.

If your training is required or otherwise sponsored by a Company, TRACE may provide information about your training results with the Company.

Any transfers of your personal data between countries will be done strictly in compliance with applicable law.  Your data may be transferred to the United States of America by TRACE in order for us to administer the online training platform.  Transfers of personal data of EU data subjects will done pursuant to TRACE Privacy Shield registrations, which are available to view at www.privacyshield.gov/list.

How long we keep it

We generally keep your personal data for three years from the date you complete the training course after which time it will be destroyed.  More information on our retention schedule can be found on TRACE’s website at www.TRACEinternational.org/policy.

What are your rights?

At any time, you may:

  • request to see your personal data that we have;
  • request to correct or delete your personal data if you believe it is incorrect;
  • object to our processing of your personal data or to transfer of your data to TRACE or to Company’s business partners; or
  • bring a complaint on how we have handled your personal data.

In any such instance, please contact TRACE’s Data Protection Officer by email at [email protected] or by regular mail at TRACE, 151 West Street, Annapolis, MD 21401, USA.  In addition, you can contact TRACE’s EU Representative at [email protected].  If contacted, we may seek additional information from you to make sure that the personal data we may possess belongs to you.  Once verified, we will evaluate your request and provide you with a response.

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you may file a complaint with the Data Protection Commissioner at [email protected] or the supervisory authority located in your jurisdiction.