1. Who we are?
1.1 This privacy notice applies to all personal information processing activities carried out by Harry Taylor of Ashton Ltd (HTA)
1.2 HTA is a data controller in respect of personal information that we process in connection with our business (including the products and services that we provide). In this notice, references to “we”, “us” or “our” are references to HTA.
1.3 Our principal address is Kitsons Works Aylesbury Road, Bromley, Kent BR2 0QZ and our contact details can be located at www.harrytaylor.co.uk
1.4 We respect individuals’ rights to privacy and to the protection of personal information. The purpose of this Privacy Notice is to explain how we collect and use personal information in connection with our business. “Personal information” means information about a living individual who can be identified from that information (either by itself or when it is combined with other information). We may update our Privacy Notice from time to time. When we do we will communicate any changes to you and publish the updated Privacy Notice on our website. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.
2. The information we process
2.1 We collect and process various categories of personal information at the start of, and for the duration of, your relationship with us. We will limit the collection and processing of information to information necessary to achieve one or more legitimate purposes as identified in this notice. Personal information may include: a) basic personal information, including name and address, and contact details; b) financial information, including account and transactional information and history; c) goods and services provided.
3. How we obtain information
3.1 Your information is made up of all the financial and personal information we collect and hold about you/your business and the proprietors, officers and beneficial owners of that business and your transactions. It includes:
a) information you give to us;
b) information that we receive from third parties – including third parties
who provide services to you or us, credit reference, fraud prevention or government agencies,
and banks (where permitted by law);
c) information that we learn about you through our relationship with you and the way you operate your accounts and/or services.
d) information that we gather from publicly available sources, such as the press, the electoral register, company registers and online search engines
4. Your rights
4.1 We want to make sure you are aware of your rights in relation to the personal information we process about you. We have described those rights and the circumstances in which they apply.
If you wish to exercise any of these rights, if you have any queries about how we use your personal information that are not answered here, or if you wish to complain please call 020 8464 0915.
Access – You have a right to get access to the personal information we hold about you.
If you would like a copy of the personal information we hold about you,
please write to: Harry Taylor of Ashton Ltd, Kitsons Works, Aylesbury Road, Bromley, Kent BR2 0QZ
Rectification – You have a right to rectification of inaccurate personal information and to update incomplete personal information. If you believe that any of the information that we hold about you is inaccurate,
you have a right to request that we restrict the processing of that information and to rectify the inaccurate personal information.
Please note that if you request us to restrict processing your information, we may have to suspend the operation of your account and/or the products and services we provide to you.
Erasure – You have a right to request that we delete your personal information.
You may request that we delete your personal information if you believe that:
• we no longer need to process your information for the purposes for which it was provided;
• we have requested your permission to process your personal information and you wish to withdraw your consent; or
• we are not using your information in a lawful manner.
Please note that if you request us to delete your information, we may have to suspend the operation of your account and/or the products and services we provide to you.
Restriction – You have a right to request us to restrict the processing of your personal information.
You may request us to restrict processing your personal information if you believe that:
• any of the information that we hold about you is inaccurate;
• we no longer need to process your information for the purposes for which it was provided, but you require the information to establish, exercise or defend legal claims; or
• we are not using your information in a lawful manner.
Please note that if you request us to restrict processing your information, we may have to suspend the operation of your account and/or the products and services we provide to you.
Portability – You have a right to data portability.
Where we have requested your permission to process your personal information or you have provided us with information for the purposes of entering into a contract with us, you have a right to receive the personal information you provided to us in a portable format.
5. Changes to the way we use your information
From time to time we may change the way we use your information. Where we believe you may not reasonably expect such a change we will notify you and will allow a period of at least 30 days for you to raise any objections before the change is made. However, please note that in some cases, if you do not agree to such changes it may not be possible for us to continue to operate your account and/or provide certain products and services to you.
6. Sharing with third parties
6.1 We will not share your information with anyone outside HTA except:
a) where we have your permission;
b) where required for your product or service;
c) where we are required by law and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies around the world;
d) with third parties providing services to us, such as agents and sub-contractors acting on our behalf.
7. Marketing information
Unless you have told us that you do not want to hear from us, we will send you relevant marketing information (including details of other products or services provided by us which we believe may be of interest to you), by mail, phone, email, text and other forms of electronic communication. If you change your mind about how you would like us to contact you or you no longer wish to receive this information, you can tell us at any time by contacting us on 020 8464 0915 or by e-mail info@harrytaylor.co.uk or via our website www.harrytaylor.co.uk.
8. Communications about your account
8.1 We will contact you with information relevant to the operation of equipment or services we have provided and maintenance of your account (including updated information about how we process your personal information), by a variety of means including email, text message, post and/or telephone.
If at any point in the future you change your contact details you should tell us promptly about those changes.
8.2 We may monitor or record calls, emails, text messages or other communications in accordance with applicable laws for the purposes outlined in Schedule A – Purposes of Processing.
9. Credit reference and fraud prevention agencies
9.1 We may access and use information from credit reference and fraud prevention agencies when you open your account and periodically to:
a) manage and take decisions about your accounts, including assessing your creditworthiness.
b) prevent criminal activity, fraud and money laundering;
c) check your identity and verify the accuracy of the information you provide to us; and d) trace debtors and recover debts.
9.2 Decisions may be taken based solely on automated checks of information from credit reference and fraud prevention agencies and internal HTA records.
9.3 We will continue to share information with credit reference agencies about how you manage your account including your account balance, payments into your account, the regularity of payments being made, credit limits and any arrears or default in making payments, while you have a relationship with us. This information will be made available to other organisations (including fraud prevention agencies and other financial institutions) so that they can take decisions about you.
9.4 If false or inaccurate information is provided and/or fraud is identified or suspected, details will be passed to fraud prevention agencies. Law enforcement agencies and other organisations may access and use this information.
9.5 If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services you have requested, or we may stop providing existing services to you.
9.6 A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. Fraud prevention agencies can hold your information for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
9.7 When credit reference and fraud prevention agencies process your information, they do so on the basis that they have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect their business and to comply with laws that apply to them.
9.8 If you would like a copy of your information held by the credit reference and fraud prevention agencies we use, or if you want further details of how your information will be used by credit reference agencies, please visit their websites or contact them using the details below. The agencies may charge a fee.Credit reference agency Contact details
Experian Limited (experian.co.uk/crain)
Post: Experian, PO BOX 9000, Nottingham, NG80 7WF. Website: experian.co.uk/consumer/contact- us/index.html Email: consumer.helpservice@uk.experian.com Phone: 0344 481 0800 or 0800 013 8888
10. How long we keep your information
10.1 By providing you with products or services, we create records that contain your information, such as customer account records, activity records, and credit account records. Records can be held on a variety of media (physical or electronic) and formats.
10.2 We manage our records to help us to serve our customers well (for example for operational reasons, such as dealing with any queries relating to your account) and to comply with legal and regulatory requirements. Records help us demonstrate that we are meeting our responsibilities and to keep as evidence of our business activities.
10.3 Retention periods for records are determined based on the type of record, the nature of the activity, product or service, and the applicable legal or regulatory requirements. We normally keep customer account records for up to seven years after your relationship with HTA or 12 months for call recordings. Retention periods may be changed from time to time based on business or legal
and regulatory requirements.
10.4 We may on exception retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators. This is intended to make sure that we will be able
to produce records as evidence, if they’re needed.
10.5 If you would like more information about how long we keep your information, please contact us at 020 8464 0915.
11. Security
We are committed to ensuring that your information is secure with us and with the third parties who act on our behalf. For more information about the steps we are taking to protect your information please contact us on 020 8464 0915.
Schedule A – Schedule of Purposes of Processing
We will only use and share your information where it is necessary for us to carry out our lawful business activities. We want to ensure that you fully understand how your information may be used. We have described the purposes for which your information may be used in detail below:
A Contractual Necessity
We may process your information where it is necessary to enter into a contract with you for the provision of our products or services or to perform our obligations under that contract. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide products and services to you. This may include processing to:
a) assess and process applications for products or services;
b) provide and administer those products and services throughout your relationship with us, including opening, setting up or closing your accounts or products; collecting and issuing all necessary documentation; executing your instructions; processing transactions, resolving any queries or discrepancies and administering any changes. Calls to our service centre and communications to our mobile and online helplines may be recorded and monitored for these purposes.
c) manage and maintain our relationships with you and for ongoing customer service.
d) communicate with you about your account(s) or the products and services you receive from us.
B Legal obligation
When you apply for a product or service (and throughout your relationship with us), we are required by law to collect and process certain personal information about you. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide products and services to you. This may include processing to:
e) confirm your identity
f) share data with police, law enforcement, tax authorities or other government and fraud prevention agencies where we have a legal obligation, including reporting suspicious activity and complying with production and court orders;
f) deliver mandatory communications to customers or communicating updates to product and service terms
and conditions;
g) investigate and resolve complaints;
h) conduct investigations into breaches of conduct and corporate policies by our employees;
i) manage contentious regulatory matters, investigations and litigation;
j) perform assessments and analyse customer data for the purposes of managing, improving and fixing
data quality;
k) provide assurance that HTA has effective processes to identify, manage, monitor and report the risks it is or might be exposed to;
l) coordinate responses to business-disrupting incidents and to ensure facilities, systems and people are available to continue providing services.
C Legitimate Interests of HTA
We may process your information where it is in our legitimate interests to do so as an organisation and without prejudicing your interests or fundamental rights and freedoms.
a) We may process your information in the day-to-day running of our business, to manage our business and financial affairs and to protect our customers, employees and property. It is in our interests to ensure that our processes and systems operate effectively and that we can continue operating as a business. This may include processing your information to:
(i) monitor, maintain and improve internal business processes, information and data, technology and communications solutions and services;
(ii) ensure business continuity and disaster recovery and responding to information technology and business incidents and emergencies;
(iii) ensure network and information security, including monitoring authorised users’ access to our information technology for the purpose of preventing cyber-attacks, unauthorised use of our telecommunications
systems and websites, prevention or detection of crime and protection of your personal data;
(iv) provide assurance on HTA’s material risks and reporting to internal management and supervisory authorities on whether HTA is managing them effectively;
(v) perform general, financial and regulatory accounting and reporting;
(vi) protect our legal rights and interests;
(vii) enable a sale, reorganisation, transfer or other transaction relating to our business.
b) It is in our interest as a business to ensure that we provide you with the most appropriate products and services and that we continually develop and improve as an organisation. This may require processing your information to enable us to:
(i) identify new business opportunities and to develop enquiries and leads into applications or proposals for new business and to develop our relationship with you;
(ii) send you relevant marketing information (including details of other products or services provided by us which we believe may be of interest to you);
(iii) understand our customers’ actions, behaviour, preferences, expectations, feedback and financial history
in order to improve our products and services, develop new products and services, and to improve the relevance of offers of products and services by HTA;
(iv) monitor the performance and effectiveness of products and services;
(v) assess the quality of our customer services and to provide staff training. Calls to our service centres and communications to our mobile and online helplines may be recorded and monitored for these purposes;
(vi) perform analysis on customer complaints for the purposes of preventing errors and process failures and rectifying negative impacts on customers;
(vii) compensate customers for loss, inconvenience or distress as a result of services, process or regulatory failures;
(viii) identify our customers’ use of third-party products and services in order to facilitate the uses of customer information detailed above; and
(ix) combine your information with third-party data, such as economic data in order to understand customers’ needs better and improve our services.
We may perform data analysis, data matching and profiling to support decision-making with regards to the activities mentioned above. It may also involve sharing information with third parties who provide a service to us.
c) It is in our interest as a business to manage our risk and to determine what products and services we can offer and the terms of those products and services. It is also in our interest to protect our business by preventing financial crime. This may include processing your information to:
(i) carry out financial, credit and insurance risk assessments;
(ii) manage and take decisions about your accounts;
(iii) carry out checks (in addition to statutory requirements) on customers and potential customers, business partners and associated persons;
(iv) share data with credit reference, fraud prevention agencies and law enforcement agencies;
(v) trace debtors and recovering outstanding debt;
(vi) for risk reporting and risk management.