During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history - ‘Your Personal Data’. Your Personal Data will also be securely shared with Harwell Protection Group Limited, if you ask us to assist you with your insurance needs. This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data. Harwell Protection Group Limited’s Privacy Notice is available on request.

Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly - for example, your name, address, date of birth and National Insurance number. Your Personal Data may also identify you indirectly - for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity. 

In the context of providing you with assistance in relation to your Mortgage and Insurance requirements, Your Personal Data may include:

When we speak with you about your mortgage and insurance requirements, we do so on the basis that both parties are entering a contract for the supply of services. In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.

Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from mortgage lenders, insurance providers and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.

On occasion, we will use Your Personal Data for contractual responsibilities we may owe our regulator - The Financial Conduct Authority - or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.

Where you ask us to assist you with, for example, your insurance needs, in particular life insurance and accident or illness insurance, we and Harwell Protection Group Limited will ask you information about your ethnic origin, your health and medical history - ‘Your Special Data’. We will record and use Your Special Data in order to make enquiries of insurance providers in relation to insurance products that may meet your needs and to provide you with advice regarding the suitability of any product that may be available to you.    

If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.

The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together ‘Criminal Disclosures’). This is relevant to insurance related activities such as underwriting, claims and fraud management. 

We will use Your Special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.

Information on Special Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.

We will collect and record Your Personal Data from a variety of sources, but mainly directly from you and via our appointed representatives. You will usually provide information during the course of our initial contact, meetings or conversations with you to establish your circumstances and needs and preferences in relation to mortgages/finance and insurance. 

We will set out your Personal Data communication options at outset, as well as making you aware of our secure Client Portal which we can use if this is your preferred method of communication. 

 

We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the voters roll when carrying out electronic ID checks. 

In the course of handling Your Personal Data, we will:

From time to time, Your Personal Data will be shared with:

In each case, Your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice - in other words, to progress your mortgage/finance and/or insurance enquiry and to provide you with our professional services. 

 

Please note that the sharing of Your Personal Data does not entitle relevant third parties to send you marketing or promotional messages. It is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.

We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.

As we continue to develop our business, we may sell to, merge with, or be acquired by, another company. As a consequence, customer information, including Your Personal Data, generally is one of the transferred and shared business assets. The information transferred and shared remains subject to the promises made in any pre-existing Customer Privacy Notice you have agreed with us.  

Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.

We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us. Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right to such information, we will retain records indefinitely.

You can:

Non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“ Non-personal Information ”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

A "cookie" is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help make sure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We use a tool which is based on the Snowplow Analytics technology to collect information about your use of the Site. The tool collects information such as how often users access the Site, which pages they visit when they do so, etc. The tool does not collect any Personal Information and is only used by our Site hosting and operating service provider to improve the Site and services.

In order to present our contents correctly and make them graphically appealing across all browsers, we use script libraries and font libraries such as Google Web Fonts ( https://www.google.com/webfonts ) on this website. Google Web Fonts are transferred to your browser's cache to avoid multiple loading. If your browser does not support Google Web Fonts or does not allow access, content will be displayed in a default font. 

This Privacy Policy does not apply to the practices of companies that we do not own or control, nor to individuals whom we do not employ or manage, including any of the third parties which we may disclose information to as set out in this Privacy Policy. 

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it, please contact: The Head of Data Privacy, Harwell Finance Group Limited, Oathall House, 68-70 Oathall Rd

Haywards Heath, West Sussex, RH16 3EN or telephone: 01444 719040 or where possible email: info@harwellfinancegroup.co.uk.

 

If we feel we have a legal right not to deal with your request, or to action it in different way to how you have requested, we will inform you of this at the time.

You should also contact us as soon as possible if you know of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.

If you have any concerns or complaints as to how we have handled Your Personal Data, you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted through their website or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Last update: 1st December 2020