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DATA PROTECTION / PRIVACY NOTICE

HAMILTON BRADSHAW LIMITED

Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our Hamilton Bradshaw Limited
Our data protection officer Pavlos Paschali (Legal Counsel)
Personal data Any information relating to an identified or identifiable individual

 Personal data we collect about you

The table below sets out the personal data we will or may collect in the course of advising and/or acting for you.

Personal data we may collect
  • Your name, address and telephone number
  • Information to enable us to check and verify your identity, eg your date of birth or passport details
  • Electronic contact details, eg your email address and mobile phone number
  • Information relating to the matter in which you are seeking our services
  • Information to enable us to undertake a credit or other financial checks on you
  • Your financial details so far as relevant to your instructions, eg the source of your funds relating to an investment
  • Information about your use of our IT, communication and other systems, and other monitoring information, (eg if using our website or a secure online client portal)
  • Your National Insurance and tax details
  • Your bank and/or building society details
  • Details of your professional online presence, eg LinkedIn profile
  •  Details of your spouse/partner and dependants or other family members, eg if relevant to an investment or KYC checks
  • Your employment status and details including salary and benefits
  • Your nationality and immigration status and information from related documents, such as your passport or other identification, and immigration information
  • Other information related to pre-employment checks, such as credit checks or bankruptcy checks
  • Details of your pension arrangements
  • Your employment records including, eg if relevant to a job application, an investment or KYC checks
  • Other information relevant to the conduct of due diligence or KYC checks
  • Information about your use of our information and communications systems

 

How your personal data is collected

We collect most of this information from you direct. However, we may also collect information:

  • from publicly accessible sources, eg Companies House, HM Land Registry, LinkedIn or a your employer’s corporate website;
  • directly from a third party, eg:
    • employment agencies;
    • credit reference agencies;
    • due diligence service providers;
  • from a third party with your consent, eg:
    • your bank or building society, another financial institution or advisor;
    • consultants and other professionals we may engage with;
  • via our website; and
  • via our information technology (IT) systems.

How and why we use your personal data

Under data protection legislation, we can only use your personal data if we have a proper reason for doing so, eg:

  • to comply with our legal and regulatory obligations;
  • to take steps at your request prior to entering into a contract;
  • for the performance of our contract with you; or
  • for our legitimate interests or those of a third party and your interests and fundamental rights do not override those interests.

The table below explains what we use (process) your personal data for and our reasons for doing so:

What we use your personal data for Our reasons
To assess suitability for employment, eg in a recruitment process For the performance of a contract with you or to take steps at your request before entering into a contract
Conducting checks to identify individuals or entities we interact with and verify their identityScreening for financial and other sanctions or embargoesOther processing necessary to comply with professional, legal and regulatory obligations that apply to our business To comply with our legal and regulatory obligationsFor the performance of a contract with you or to take steps at your request before entering into a contract
Gathering and providing information required by or relating to audits, enquiries or regulatory bodies To comply with our legal and regulatory obligations
Ensuring business policies are adhered to For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures
Operational reasons, such as improving efficiency, training and quality control For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can delivery the best service for you
Ensuring the confidentiality of commercially sensitive information For our legitimate interests or those of a third party, i.e. to protect our intellectual property and other commercially valuable informationTo comply with our legal and regulatory obligations
Statistical analysis to help us manage our practice, eg in relation to our financial performance, work type or other efficiency measures For our legitimate interests or those of a third party, i.e. to be as efficient as we can and deliver the best service
Preventing unauthorised access and modifications to systems For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for youTo comply with our legal and regulatory obligations
Statutory returns To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments To comply with our legal and regulatory obligationsFor our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to:—existing and former investment targets or proposals;—third parties who have previously expressed an interest in our services;—third parties with whom we have had no previous dealings. For our legitimate interests or those of a third party, i.e. to promote our business
Credit reference checks via external credit reference agencies To comply with our legal and regulatory obligationsFor our legitimate interests or those of a third party, eg as part of background checks prior to an investment 

For the performance of our contract with you or to take steps at your request before entering into a contract

Preventing fraud To comply with our legal and regulatory obligationsFor our legitimate interests or those of a third party, eg as part of background checks prior to an investment 

For the performance of our contract with you or to take steps at your request before entering into a contract

Processing invoices and payments To comply with our legal and regulatory obligationsFor the performance of our contract with you or to take steps at your request before entering into a contract

 

We may process special categories of personal information in the following circumstances:

  1. Where we need to carry out our legal obligations or exercise specific rights (either yours or ours) related to employment and in line with our data protection policy.
  2. Where it is needed in the public interest, such as for equal opportunities monitoring, in relation to our occupational pension scheme, and in line with our data protection policy.
  3. Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
  4. In limited circumstances, with your explicit written consent.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about members or former members in the course of legitimate business activities with the appropriate safeguards.

Our obligations as an employer

We may use special categories of personal information in the following ways:

  • We may use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.
  • We may use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
  • We may use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

 

Marketing communications

We may use your personal data to send you updates (by email, text message, telephone or post) about market developments, updates or information about our services that might be of interest to you.

We have a legitimate interest in processing your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

  • contacting us by emailing our Data Protection Officer at pp@hbpe.com
  • using the ‘unsubscribe’ link in emails
  • communicating your preference to us clearly in any other way

Who we share your personal data with

So far as is necessary, we may share personal data with:

  • professional advisers, such as accountants, lawyers, tax advisors or other experts;
  • representatives related to a proposed or on-going investment;
  • other third parties where necessary to carry out your instructions;
  • compliance advisers;
  • credit reference agencies;
  • employment agencies;
  • our insurers and brokers;
  • external auditors, eg in relation the audit of our accounts;
  • our bank; and
  • external service suppliers, representatives and agents that we use to make our business more efficient.

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

Where your personal data is held

Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.

How long your personal data will be kept

We may keep your personal data after completion of our services. We will do so for one of these reasons:

  • to respond to any questions, complaints or claims made by you or on your behalf;
  • to show that we treated you fairly;
  • to keep records required by law.

We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data.

When it is no longer necessary to retain your personal data, we will delete or anonymise it.

Transferring your personal data out of the EEA

It may sometimes be necessary for us to share your personal data outside the European Economic Area (EEA), eg:

  • with our investment partners and service providers located outside the EEA;
  • if you are based outside the EEA;
  • where there is an international dimension to the services we are providing or to an existing or potential investment.

These transfers are subject to special rules under European and UK data protection law.

We will ensure that any transfer complies with data protection laws and that relevant contracts contain appropriate clauses to confirm this. We will ensure that all personal data will be secure.

Your rights

You have the following rights, which you can exercise free of charge:

Access The right to be provided with a copy of your personal data
Rectification The right to require us to correct any mistakes in your personal data
To be forgotten The right to require us to delete your personal data—in certain situations
Restriction of processing The right to require us to restrict processing of your personal data—in certain circumstances, eg if you contest the accuracy of the data
Data portability The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object The right to object:—at any time to your personal data being processed for direct marketing (including profiling);—in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

 

If you would like to exercise any of those rights, please:

  • email, call or write to our Data Protection Officer—see below: ‘How to contact us’; and
  • let us have enough information to identify you (eg your full name, address and email or telephone number;
  • let us have proof of your identity and address (eg a copy of your driving licence or passport and a recent utility or credit card bill); and
  • let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Changes to this privacy policy

We may change this privacy policy from time to time. The latest version will be available on our website.

How to contact us

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our contact details Our Data Protection Officer’s contact details
Hamilton Bradshaw Limited3rd Floor60 Sloane AvenueLondon

SW3 3DD

 

Pavlos Paschali (Legal Counsel)Email: pp@hbpe.comTelephone: 020 7399 6700 

If you have any questions about this notice, please contact us.