Harrison Hill Castle & Co are committed to protecting and respecting the personal data that we hold. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others on behalf of individuals. We may use personal data provided to us for the purposes described in this privacy statement or as made clear in another form before collecting personal data.
Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we process personal data.
We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose differ, and are set out in the relevant sections below.
The personal data that is provided to us is provided either directly from the individual concerned, from a third party acting on behalf of an individual, or from publicly available sources (such as internet searches, and Companies House).
Where we receive personal data from a third party that relates to an individual, we request that this third party inform the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.
We take the security of all the data we hold seriously. Staff are trained on data protection, confidentiality and security, and we maintain a culture of confidentiality.
We have a framework of policies and procedures which ensure that we keep the data we hold secure.
All information you provide to us is stored on our locally hosted secure servers.
PERSONAL DATA THAT WE HOLD
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 collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data includes, in relation to you or a family member, first name, maiden name, last name, username or similar identifier; marital status; title; date of birth; gender; data contained on a passport, photocard driving licence or other identity card; and data contained in photographs.
- Contact Data includes home address and billing address (if different), email address and telephone numbers.
- Financial Data includes income, personal expenditure, charitable donations, taxation and other financial-related details; investments and other financial interests; bank account and payment card details; pension details; and data relating to the membership of professional bodies.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Usage Data includes information about how you use our products and services.
We provide services to individuals as well as businesses, non-profits, and other organisations. The exact data held will depend on the services to be provided.
Where we engage with clients for professional services, we may collect and process personal data in order to satisfy a contractual obligation. We request that clients only provide the personal data that is required for us to fulfil our contractual obligation.
Where we are legally permitted to do so, we shall notify our clients if we receive a request for a data subject to exercise their rights under GDPR, or if we are served with information from a supervisory authority.
Why do we process data?
Where data is collected for professional services, it is used for a number of purposes, such as;
- Providing services to clients. Data is processed in order to provide the service detailed in our letter of engagement between our clients and us, and may sometimes be further clarified in written documentation supplied before any data processing may occur;
- Client management. When communicating with and assessing the needs of clients, personal data may be processed in order to ensure that their needs are appropriately satisfied. This may include assessing whether the right collection of services is being provided to our clients.
- Administration. In order to manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing client relationships and maintaining internal operating processes.
- Regulatory. In order to undertake professional services, we may from time to time be required to collect and process personal data in order to fulfil regulatory, legal or ethical requirements. This may include the verification of identity of individuals.
What data is processed?
The data that is processed is dependent on the service that is being provided and on the recipient of this service.
- Services to businesses, non-profits, and other organisations. We process the personal data of individuals associated with our clients. Personal data may include any relevant financial or non-financial information necessary for us to provide our services. As an example, this may include contact details, payroll data, employee information (including details about dismissal), lists of shareholders, customers and suppliers and any other specifically relevant data.
- Services to individuals. Personal data may include contact details and tax identifiers, information about business activities, investments, and other financial interests, payroll and other income, and any other specifically relevant data.
How long do we hold data for?
We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years). We may keep data for longer in order to establish, exercise, or defend our legal rights and the legal rights of our clients.
In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.
We collect personal data for our people as part of the administration, management and promotion of our business activities.
Where an individual is applying to work for Harrison Hill Castle & Co, personal data is collected through the application process.
Why do we process data?
There are a number of purposes that personal data for applicants are collected.
- Employment. We process an applicant’s personal data in order to assess their potential employment at Harrison Hill Castle & Co.
- Administration and management. We may also use this personal data in order to make informed management decisions and for administration purposes.
How long do we hold data for?
Personal data collected for applicants is held for as long as necessary in order to fulfil the purpose for which it was collected, or for a maximum of two years where those purposes no longer become necessary.
We collect and process personal data about our suppliers, subcontractors, and the individuals associated with them. The data is held to manage our relationship, to contract and receive services from them, and in some cases to provide professional services to our clients.
Why do we process data?
- Receiving goods and services. We process personal data in relation to our suppliers and their staff as necessary to receive the services.
- Providing services to our clients. Where a supplier is helping us to deliver professional services to our clients, we process personal data about the individuals involved in providing the services in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our clients.
- Administering, managing and developing our businesses and services. We process personal data in order to run our business, including:
- managing our relationship with suppliers;
- developing our businesses and services, such as identifying client needs and improvements in service delivery;
- maintaining and using IT systems;
- administering and managing our website and systems and applications.
- Security, quality and risk management activities. We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers. We collect and hold personal data as part of our supplier contracting procedures. We monitor the services provided for quality purposes, which may involve processing personal data.
- Complying with any requirement of law, regulation or a professional body of which we are a member. We are subject to legal, regulatory and professional obligations. We need to keep certain records to show we comply with those obligations and those records may contain personal data.
What data do we hold?
We hold the data that is necessary for the purposes listed above. As an example, we will typically hold supplier’s names, contacts names, and contact details of suppliers.
How long do we hold data for?
We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). Data may be held for longer periods where required by law or regulation and in order to establish, exercise or defend our legal rights.
SHARING PERSONAL DATA
We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.
Personal data held by us may be transferred to:
- Third party organisations that provide applications/functionality, data processing or IT services to us. We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services.
- Third party organisations that otherwise assist us in providing goods, services or information.
- Other professional advisers, but only with your express written authority to do so.
- Law enforcement or regulatory agencies or those required by law or regulations.
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
LOCATIONS OF PROCESSING
All personal data resides within the UK territory.
Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights as follows:
- Individuals may request access to their personal data held by us as a data controller.
- Individuals may request us to rectify personal data submitted to us.
- Individuals may request that we erase their personal data
- Where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us.
- Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.
- Individuals may request information about, or for human intervention into, any automated data processing that we may undertake.
If you wish to exercise any of these rights, please contact us at firstname.lastname@example.org.
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to email@example.com. We will look into and respond to any complaints we receive.
You also have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner’s Office (“ICO”). For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns
DATA CONTROLLER AND CONTACT INFORMATION
The data controller is Paul Castle.
If you have any questions about this privacy statement or how and why we process personal data, please contact us at:
Harrison Hill Castle & Co
34 Southborough Road
Phone: 020 8295 0555
CHANGES TO OUR PRIVACY STATEMENT
Updates to this privacy statement will appear on this website. This privacy statement was last updated on 23rd May 2018.