HPRM WEBSITE PRIVACY NOTICE
Welcome to HP Risk Management’s privacy notice.
HP Risk Management respects your privacy and is committed to protecting your personal data. This privacy notice sets out how we collect and look after your personal data when you visit our website, register an enquiry about our services or submit any information via our contact form (regardless of where you visit it from). It also covers how we use information about our clients in terms of our general relationship with them. It also tells you about your privacy rights and how the law protects you.
It is important that you read this privacy notice together with any other privacy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you or your personnel so that you are fully aware of how and why we are using that data. This privacy notice supplements other notices and is not intended to override them. For example, if you use our RiskPal risk management tool or app or ask us to provide you with consultancy services, separate notices or data processing provisions will apply (as set out in our terms of business or licence terms).
This website is not intended for children and we do not knowingly collect data relating to children.
2. WHO WE ARE
For the purposes of the General Data Protection Regulation 2016 (GDPR) and the Data Protection Act 2018 (DPA), HP Risk Management is the controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
If you have any questions about this privacy notice or our privacy practices, please contact us:
Full name of legal entity: HP Risk Management Limited
Postal address: Salcot Lodge, Worthy Road, Winchester, SO23 7AG
Telephone number: 44 (0) 7791 866 051
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
3. THIRD-PARTY LINKS
4. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed and cannot be recombined with other information in order to identify an individual again (anonymous data).
We may collect, be provided with, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name(s), last name(s), title, job position etc
• Contact Data includes email addresses, telephone numbers and other contact information such as Skype details.
• Technical Data includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for various purposes. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. (Please note that the Riskpal tool and app do collect this type of data. We may also be provided with this type of data as part of us providing consultancy services. However, this collection and use is covered by our separate terms of business and/or licence terms. If this is applicable to you relationship with us, this will be explained and dealt with separately.)
Occasionally visitors to our website provide unsolicited information to us e.g. speculative CVs, which may contain special categories of personal data or information about criminal convictions and offences. If this occurs, we will use this personal information in line with any relevant provisions within the GDPR and DPA. However, we discourage visitors from submitting unsolicited information.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
5. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Technical Data from analytics providers such as Google.
Direct interactions. You may give us your Identity and Contact information by filling in our contact form or by corresponding with us by post, telephone, email or otherwise using the contact details found on this website. This includes personal data you provide when you:
• enquire about or use our products or services (such as where we provide a proposal for clients, manage client relationships or carry out billing processes);
• create an account on our website (where this function is available);
• subscribe to our publications (where this function is available);
• request marketing information to be sent to you; or
• give us feedback or otherwise contact us.
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
• Identity and Contact Data from your colleagues who may contact us about our services;
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see the section on cookies below for further details.
We will explain if the provision of data is optional or required in relation to any particular query, product or service.
6. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the GDPR or DPA or e-privacy laws allow us to. We must have a lawful basis for processing your information; this will vary on the circumstances of how and why we have your information. Most commonly, we rely on the following bases to use your personal data in the following circumstances:
You have consented to the processing of your personal information for one or more specific purposes e.g. you agree for third party marketing information to be sent to you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests e.g.
to respond to an enquiry about our services by sending you or a colleague information;
to manage our prospects and customers (including preparing proposals, providing consultancy services, billing clients and collecting debts);
to administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you; or
Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will ask for your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Note that we may process your personal data on more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need further details about the specific legal basis we are relying on to process your personal data.
7. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below – these parties will act as independent data controllers of your personal data:
Internal third parties such as:
other companies in the HP Risk Management Group who are based in the United Kingdom and provide integrated risk management services with us and carry out shared administrative services.
External third parties such as:
professional advisers including lawyers, bankers, auditors and insurers based in the UK, EEA and elsewhere who provide consultancy, banking, legal, insurance and accounting services to us;
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances;
law enforcement or other authorities if required by applicable law or by order of court or other competent regulatory body; or
third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We will not share your personal information with any other third party to use for their own purposes unless permitted by applicable law or unless fully anonymised.
Some of the information you provide to us may also be transferred to, stored and processed by third party organisations which process data for us and on our behalf. These third parties may be based (or store or process information) in the UK or elsewhere including outside of the EEA. As with many small businesses, these third parties may include third party IT platforms (including cloud based platforms), suppliers of administrative and support services and suppliers of other specialist products.
We expect all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and in compliance with the GDPR and DPA (including in relation to transfers out of the UK / EU).
8. PROMOTIONAL OFFERS FROM US AND OTHER MARKETING
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You may receive marketing communications from us about our other products, services and offers if you have requested information from us on similar topics and you have not opted out to receiving that marketing.
We will ask for your express opt-in consent before we share your personal data with any third party to use for their own marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time using (as applicable) the details at the beginning of this notice or contacting the relevant third party or via any unsubscribe function on the communication itself.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us and being used for other lawful purposes e.g. discussing proposed transactions or for our legal obligations.
Cookie What it does
svSession Identifies unique visitors and tracks a visitor’s sessions on a site
smSession Identifies logged in site members
TSxxxxxxxx (where x is replaced with a random series of numbers and letters) Security
TSxxxxxxxx_d (where x is replaced with a random series of numbers and letters) Security
Google Analytics Provides a high-level overview of people our using our website so we can see how our different pages are performing.
For more information about cookies generally, please see https://www.aboutcookies.org/
10. CHANGE OF PURPOSE AND CHANGES TO THIS NOTICE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We keep our privacy notice under regular review. This version was last updated on 21 November 2018. We may change this notice from time to time as our business and internal practices and/or applicable laws change.
11. INTERNATIONAL TRANSFERS
We sometimes transfer your personal data outside the UK and European Union (EU). This can include:
where you are based outside of the EU;
where you make an enquiry about our services or products to be provided outside of the EU that require us to contact third party businesses or organisations in the relevant overseas locations;
where we use third party IT platforms (including cloud based platforms) to store data and host our applications and platform; or
where we use other suppliers of administrative and support services such as development and maintenance support for our website.
We ensure that where information is transferred to a country or international organisation outside of the UK / EU, we comply with the relevant legal rules in the GDPR governing such transfers.
12. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
13. HOW LONG WILL YOU KEEP MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. To the extent we are able to specify our current retention periods these are as follows:
By law we have to keep basic information about our customers for six years after they cease being customers for tax purposes. We also keep personal data for up to seven years where we reasonably consider there is a prospect of litigation in respect of our relationship with you. In relation to data collected for marketing purposes we usually keep this for [one] year or for as long as our relationship continues with you (if longer).
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
14. YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact firstname.lastname@example.org Certain other rights also exist under the GDPR e.g. in relation to automated decision making. However, these rights do not arise based on the processing that we carry out under this privacy notice. For example, we do not carry out any automated decision making based on the personal information provided to us via our website. Full information on your rights can be found on the ICO's website.
You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. We will also let you know if a right doesn't apply.