This privacy notice explains how Harp and Crown uses any personal information we collect about you.
Harp and Crown is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified, you can be assured that it will only be used in accordance with this Privacy Notice. This notice explains how we do this and tells you about your privacy rights, and how the law protects you.
What we collect:
Harp and Crown will collect information about you when you register or apply for membership of any of our services. We may also collect information when you voluntarily supply information to us, update your personal details, participate in surveys or offer feedback.
We may collect the following categories of information depending on the services you avail of:
- Personal details;
- Family details;
- Health Details;
- Financial details;
- Legal information;
- Employment details;
- Lifestyle or social circumstances.
We collect this information to pursue the representation of you as a member; for example, providing you with a service or assisting you with a query. We must have a lawful basis on which to process your information. The lawful basis will be for one of the following reasons:
Where the use is for our Legitimate Interest - as Harp and Crown cannot reasonably perform its representation of members without processing their personal data, there is a reasonable expectation that Harp and Crown need to process members’ information, and a relevant and appropriate relationship between the Controller and Data Subjects.
We ask for your consent - Consent will only be relied upon where the individual is required to provide special category data, which includes information relating to race, ethnic origin, politics, religion, trade union membership, genetics, biometrics, health, sex life or sexual orientation. Consent will be specific to the special category information requested.
We have a Legal Obligation - this may be in the event that we must comply with a legal obligation to supply information to regulatory authorities or law enforcement agencies.
We need to protect a Vital Interest – this will only be used in exceptional circumstances where processing is necessary to protect an individual’s life.
How we will use the information collected:
We collect personal information about you to manage your membership, and contact you if necessary. We use this information to provide the services and products requested, maintain records, and to send you information on updates or renewals to services, or to tell you about new services or products available. Harp and Crown will not share your information for marketing purposes with any other companies.
In managing your membership, providing you with a service, or representing you in any way, it may be necessary for us to share your information with other agencies.
Who we may share your information with:
- Police Service of Northern Ireland;
- Legal Advisors;
- Auditors and Business Advisors;
- Family, associates or representatives of the individual whose personal data we are processing;
- Ombudsmen and Regulatory Authorities;
- Credit reference agencies;
- Debt collection and tracing agencies.
All the personal data you provide will be processed by our staff in the Federation Office, Garnerville, unless we need to transfer all or part of it to the agencies listed above. We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place robust physical, electronic and governance procedures to safeguard and secure the information we collect.
How long we will keep it:
We will retain your personal data as long as we require it to maintain and record membership of the services and products you avail of; or if there is a statutory requirement to do so.
We want to make sure that your personal information is accurate and up-to-date, and you have the right to request a copy of the information that we hold about you.
You may ask us to correct, or remove information you believe to be inaccurate. You also have the right to request the erasure of your data.
If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate this matter.
If you are not satisfied with our response, or believe we are processing your data in contravention of the law, you can complain to the Information Commissioner’s Office (ICO).
Our Data Protection Officer can be contacted at email@example.com
This policy was updated on 24th May 2018, and will be reviewed at least annually.