HPAPI Project Services Limited (“HPSL”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data.
This privacy notice aims to give you information on the types of data we collect and process about you, what we do with your personal data and why we use your personal data.
HPSL is the controller and responsible for your personal data.
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.
Data protection law in the UK changed on 25 May 2018.
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.
Our website may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
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 which we have grouped together follows:
Identity Data includes first name, maiden name, last name, title and date of birth.
Contact Data includes address, email address, telephone numbers and job title.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with 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.
Where we need to comply with a legal or regulatory obligation.
Where you have contacted us or where we have exchanged contact information in the common interest area covered by what HPSL does and where you have opted into receive marketing communications from us, we will rely this as consent for processing your personal data. You have the right to withdraw consent to marketing at any time simply by contacting us.
We plan to retain your personal data for use in a very limited way; only in connection with managing the important matter of health and safety; that is, for initial contact, for contracting with your company, to deliver services to your company, to manage our commercial relationship with you, to make suggestion about services that may be useful for your company, to communicate interesting and relevant information to you. We will not Spam you.
You will receive very infrequent marketing communications from us (less than 5 times per year) if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by contacting us at any time at firstname.lastname@example.org
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.
In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example where we are complying with legal obligations, a court order, or a governmental authority.
In providing services to our clients and in complying with our legal obligations, we may share your personal data with the following third parties:
Suppliers and service providers, including IT service providers, system administrators, professional advisers, including lawyers, bankers, insurers, experts and medical practitioners, HM Revenue & Customs, government agencies, regulators and other authorities.
We do not transfer your personal data outside the European Economic Area (EEA) unless your specific matter requires that we do or unless it is necessary due to your geographic location and you have given your prior consent.
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.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
In some circumstances you can ask us to delete your data see below for further information. However, by law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
· Request access to your personal data. 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may 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.