Privacy Policy  

Introduction

This Privacy Notice outlines Harwell Protection Group Limited (‘we’, ‘our’ or ‘the Company’) practices with respect to information collected from users who access our website (‘Site’) or otherwise share personal information with us (collectively: ‘Users’).

Why should you read this notice?

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 our ‘Principal’ – Harwell Finance Group Limited – so we can offer the highest standard of service to our clients and for the purposes of ensuring compliance with Financial Conduct Authority regulations. Harwell Finance Group Limited’s Privacy Notice is available on request. 

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.

What do we mean by ‘Your Personal Data’?

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 Insurance requirements, Your Personal Data may include:

• Title, name, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity;
• Employment and remuneration information, including salary/bonus schemes, overtime, sick pay or other benefits and employment history;
• Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents;
• Health status and history, details of treatment and prognosis, medical reports. Further details are provided below, specifically with regard to the processing we may undertake in relation to this type of information; and
• Any existing insurance products and the terms and conditions relating to these.

The basis upon which we will deal with Your Personal Data

When we speak with you about your 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 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.

The basis upon which we will process certain parts of Your Personal Data

Where you ask us to assist you with, for example, your insurance needs, in particular life insurance and accident or illness insurance, we 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.

How do we collect Your Personal Data?

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

What happens to Your Personal Data when it is disclosed to us?

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

• Record and store Your Personal Data in our paper files, mobile devices and on our computer systems. This information can only be accessed by employees and consultants within Harwell Protection Group Limited and Harwell Finance Group Limited, and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.
• Submit Your Personal Data to Insurance product providers, both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.
• Use Your Personal Data for the purposes of responding to any queries you may have in relation to any mortgage/finance product or insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware.

Sharing Your Personal Data

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

• Insurance providers where appropriate;
• Our ‘Principal’ – Harwell Finance Group Limited (who will also be data controller); and
• Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include, but may not be limited to, our compliance advisers, product specialists and providers of customer satisfaction surveys to help us improve and develop the services we provide to you where we believe this to be required due to your particular circumstances.

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 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.

Security and retention of Your Personal Data

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 by unencrypted email 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. 

Your rights in relation to Your Personal Data

You can:

• request copies of Your Personal Data that is under our control;
• ask us to further explain how we use Your Personal Data;
• ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request);
• ask us to send an electronic copy of Your Personal Data to another organisation should you wish; and
• change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety).

How to make contact with us in relation to the use of Your Personal Data

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 Road, Haywards Heath, West Sussex, RH16 3EN or telephone: 01444 719040 or where possible email: info@harwellprotectiongroup.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 Information Commissioner's Office, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Technical Data Processing

What other information do we collect?

We collect two types of data and information from Users of our Site.

The first type of information is unidentified and 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.).

The second type of information Personal Information, which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes: Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.

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:

1. 'session cookies' , which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;
2. 'persistent cookies ', which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;
3. 'third-party cookies' , which are set by other online services who run content on the page you are viewing, for example by third-party analytics companies who monitor and analyse our web access.

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.

Use of script libraries (Google Web Fonts)

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.

Calling script libraries or font libraries automatically triggers a connection to the library operator. In theory, it is possible – but currently also unclear whether and, if so, for what purposes – that operators of corresponding libraries collect data.

The privacy policy of the library operator Google can be found here: https://www.google.com/policies/privacy .

Corporate transaction

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 Notice.

Minors

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow the use of our services by minors without prior consent or authorisation by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us.

Updates to this Privacy Notice

We reserve the right to periodically amend or revise the Privacy Notice; material changes will be effective immediately upon the display of the revised Privacy notice. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Notice and your agreement to be bound by the terms of such amendments.

Last Modified: 1 December 2020