Privacy Policy2018-06-05T23:12:35+00:00

Privacy Notice                               

Our Privacy Notice explains how we use your personal data, describes the categories of personal data we process and for what purposes. We are committed to collecting and using such data fairly and in accordance with the requirements of the General Data Protection Regulation (GDPR).

We take your privacy seriously and you can find out more here about your privacy rights and how we gather, use and share your personal information.

 

Summary

Who we are

HRC Group of Ground Floor, Mikasa House, Asama Court, Newcastle Business Park, Newcastle Upon Tyne, NE4 7YD acts as controller for the personal information you provide to us.

Your rights

You have the right to object to how we process your personal information. You also have the right to access, correct, sometimes delete and restrict the personal information we use. In addition, you have a right to complain to us and to the data protection regulator. Contact details are shown here.

  • info@hrcgroup.net or write to us at the address shown above.
  • Information Commissioner: ico.org.uk/global/contact-us

Your privacy rights are detailed more fully on the following pages.

How we gather and use personal information

We need to obtain information about you, so that we can provide the financial advice you require. This information is normally obtained directly from clients in a face to face meeting. It may also be obtained by telephone, post or other means. We hold such information as Data Controllers in accordance with the requirements of the Data Protection Act 2018 and the EU General Data Protection Regulation, together referred to as the ‘Regulations’. We use this information to analyse your current and future financial needs so that we can ensure that any subsequent advice takes due account of, and is suitable to, your circumstances. We will not share your information with any other party except as indicated in this Privacy Statement or where required to do so by any statutory, governmental or regulatory body for legitimate purposes.

Sharing and transferring personal information

Where necessary to the provision of our service, we may share your personal information with third parties. The categories of third party are listed later in this notice. We will confirm the actual third parties with whom we might/will share your information when we have identified the product/service providers that we recommend you use. This will usually be done in our suitability report in which we detail our recommendations to you.

Until you have been informed of the actual third parties with whom we might share your information, and have not withdrawn your consent to that sharing, we will only share in a way that does not enable the third party to identify you. Sometimes we transfer personal information to other countries outside the UK for these purposes, where suitable protection is in place.

Keeping personal information

We keep your personal information securely for as long as we need to for providing you with financial advice under the terms of our service/fee agreement (contract) or for as long as we are required to by relevant regulations.

Legal basis for collecting/processing information

The legal basis on which most of the information that you provide will be collected and processed is to enable us to provide the financial advice that we have agreed you require. However, some types of information require your explicit consent.  In relation to any adverse health history you might have. We will seek your consent if required. Where you have given us consent, you have the right to withdraw it at any time.

 

Full Privacy Notice

Introduction

We take your privacy seriously and you can find out more here about your privacy rights and how we gather, use and share your personal information.

 

Your Privacy Rights

You have the right to see what personal information we hold about you and you can ask us to correct inaccuracies, delete or restrict personal information or ask for some of your personal information to be provided to someone else. You have the right to object to how we use your personal information. If you need to contact us in relation to any of your rights or wish to make a complaint about how we have used your personal information directly to us or to the Information Commissioner’s Office, you can use the contact details indicated on the first page of this notice.

 

  • Right to withdraw consent: Where you have given us your consent to use personal information, you can withdraw your consent at any time.
  • Access to your personal information: You can request access to a copy of your personal information. We will not normally charge for providing this information to you.
  • Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a commonly used electronic form.
  • Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
  • Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it. Note that we might be required by regulations to retain your information even if you want it to be deleted.
  • Right to object: You can object to our processing of your personal information.
  • Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.

 

Legal basis for collecting/processing information

The legal basis on which most of the information that you provide will be collected and processed is to enable us to provide the financial advice that we have agreed you require.

However, some types of information require your explicit consent.  Where we identify that it is relevant to obtain details from you in relation to any adverse health history you might have, we will seek your explicit consent.

 

Where you have given us consent, you have the right to withdraw it at any time.

 

What kinds of personal information we use

We use information relating to your personal situation and financial position.

 

How we gather your personal information

We obtain personal information:

  • directly from you, usually in a face to face meeting but potentially also by telephone or other means;
  • from other organisations such as investment/pension/insurance providers, where you have provided authority for them to share information relating to your existing plans;
  • from your professional advisers, where you have provided authority for them to share information.
  • We may also obtain some personal information from recording calls or meetings or by making contemporaneous notes of calls or meetings.

 

How we use your personal information

We hold your personal information as Data Controllers in accordance with the requirements of the Data Protection Act 2018 and the EU General Data Protection Regulation, together referred to as the ‘Regulations’.

We use this information to analyse your current and future financial needs so that we can ensure that any subsequent advice takes due account of, and is suitable to, your circumstances.

We will not share your information with any other party except as indicated in this Privacy Statement or where required to do so by any statutory, governmental or regulatory body for legitimate purposes.

 

Sharing and transferring personal information

Where necessary to the provision of our service, we may share your personal information with third parties. The categories of third party are listed below.

 

  • Insurance Providers
  • Pension Providers
  • Annuity providers
  • Investment Providers
  • Investment Platforms
  • Providers of pension transfer comparison reports
  • Compliance Advisers
  • Legal Advisers
  • Back Office Systems Providers
  • Third Party Software Providers
  • HRC Group

 

We will confirm the actual third parties with whom we might/will share your information when we have identified the product/service providers that we recommend you use. This will usually be done in our suitability report in which we will detail our recommendations to you.

 

Until you have been informed of the actual third parties with whom we might share your information, we will only share in a way that does not enable the third party to identify you.

 

Where necessary to implement the service that you require, your personal information might be transferred to other countries outside the UK, but only to jurisdictions where suitable protection is in place.

Keeping personal information

We keep your personal information securely for as long as we need to for providing you with financial advice under the terms of our service/fee agreement (contract) or for as long as we are required to by relevant regulations.

 

Data Protection Policy

 

HRC Group, Ground Floor, Mikasa House, Asama Court, Newcastle Business Park, Newcastle Upon Tyne, NE4 7YD, operates in the financial services sector where data handling and confidentiality are key issues. All the information we collect will be treated with the utmost confidentiality.

 

So that we may fully understand your circumstances and requirements, we will need to collect information about you, which we will hold as Data controllers under the Data Protection Act 2018 (DPA 2018). We will use this information to analyse your current and future financial needs so that we can ensure that any subsequent advice is suitable to your circumstances.

 

Our regulator the Financial Conduct Authority requires us to keep records of our business transactions for minimum periods of time depending on the transaction type. However, we will not keep records longer than is necessary. Where other companies and / or third parties provide services to us, then circumstances may arise which warrant the disclosure of more than just your basic contact details. On these occasions, such as processing business and obtaining compliance and regulatory advice, you are aware that sensitive personal information (for example health details) held by us may be disclosed on a confidential basis to such companies. You also agree that for the purposes described above your data may be transferred to countries outside the European Union.

Under the DPA 2018, you or your appointed agent, have a right to inspect computer and certain manual records relating to yourself and your transactions, and where appropriate have them corrected or deleted. All such requests for information must be referred to the Data Protection Officer. As we treat all client records as confidential, we reserve the right to give you copies of your records, where in certain circumstances to release the original would compromise other clients’ confidentiality or where access to your data is necessary to protect your privacy. We reserve the right to make a charge for releasing such documentation to you.

Where relevant, you understand that for any mortgage application your records may be passed to a credit agency and details of your personal records may be shared with other companies in relation to credit and preventing fraud.

 

Distance Marketing Directive

On the rare occasions when it may be necessary to conduct our business without any personal contact we will advise you if this requires the creation of a distance marketing contract between us. In this event you will be provided with additional information as required by the Directive.

 

 

Additional information requirements: distance communications 

Where you are likely to do business with us at a distance whereby we communicate exclusively by telephone, email, post or fax, then it is very important that you read the following points in addition to those above.

 

(i)      The firm will provide you with a service as detailed in these terms and conditions, the information about our services document, the key facts about our services and costs document (mortgage and insurance business only) and fee agreement.

(ii)     The total price that we charge for our services is set out in our fee agreement which you must sign prior to our undertaking any service on your behalf. Please ask us if you are unsure as to any aspect of our pricing. There will be other charges and expenses imposed by the providers of insurance, mortgage and investment products which will be detailed separately

(iii)    Please note there is the possibility that other taxes or costs may exist that are not paid through the firm or imposed by it.

(iv)   There are no specific additional costs imposed by the firm for dealing exclusively at a distance.

(v)    You should note that some of our recommendations may involve investments that can fluctuate in value, for example depending on financial markets. These fluctuations will be outside of our control and you should therefore consider carefully potential fluctuations before entering into this type of contract. Our recommendations may also involve mortgages where the interest rate can fluctuate, for example depending on the bank interest rate. Please take care to read the warnings issued in this document and any provider literature. If you are unsure then please ask us to explain in more detail.

(vi)   The firm does not place any specific limitations on the period for which the information provided remains valid. If you are unsure if something remains valid then please ask and we will clarify.

(vii)  The provisions of any contractual agreement to provide an ancillary advisory service and the relationship created by it shall be governed by English Law and subject to the exclusive jurisdiction of the English courts.

(viii) Any such contract is supplied in English Language and will be communicated in English Language.

 

 

 

Where it applies and relating specifically to any contractual agreement with the firm to provide an ancillary advisory service to you there will be a right to cancel our fee. This right to cancel will be detailed in the fee agreement. In the event of any dispute, unless there is clear written evidence to the contrary, we will treat the date cited for cancellation as being the date when notice was given, posted or otherwise sent.  If you do not exercise your right to cancel, then the fee we charge cannot be returned at some later date.  For the avoidance of doubt, please note that you do not have a right to cancel a regulated mortgage contract concluded with a lender. Also, any cancellation provisions relating to an investment or insurance product are integral to the provider’s product and where they apply will be detailed separately in the provider’s literature.

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