Making sure personal data is secure and properly dealt with is of paramount importance in our dealings with you. It is therefore important you understand what information we will take, why we need it, and how we will process your details.
Who will process my data?
HL Partnership Limited will process your data in order to provide our services. HL Partnership Limited is authorised and regulated by the Financial Conduct Authority.
What data will you ask me for?
In order to verify that you meet the required standards of fitness and propriety, we need to obtain information about you, your personal circumstances, your financial services experience and your future ambitions. Some of the information will be private and may be sensitive, such as financial information including business and personal debts and credit commitments, legal proceedings and adverse credit.
Do I have to provide my personal data?
In order for us to consider an application to become an adviser or appointed representative of HL Partnership Limited, you must provide all the information we ask for as openly and honestly as possible. Non-disclosure could result in your application being declined or, where the non-disclosure is discovered post appointment, could lead to the agreement being terminated. If you are unsure whether information needs to be disclosed, you should either disclose this anyway to allow us to decide whether it is relevant, or speak to a member of the team for guidance.
How will you use my data?
The primary reason we will process your data is to do our job (performance of contract). Specifically we will use your data to:
- Assess your fitness and propriety as a potential member of the HL Partnership Limited network;
- Assess your ongoing fitness and propriety once appointed to the network;
- Provide network and market updates to member firms and advisers;
- Provide training and development opportunities to help businesses and individuals be more successful.
We may also process your information in order to meet our legal and regulatory requirements. These may include:
- Complying with the regulations set out by the Financial Conduct Authority and other regulators as required;
- Preventing financial crimes such as money laundering and fraud by passing your details to other relevant bodies such as the police and National Crime Agency where required.
We may also process your personal data for our own legitimate interests. Typically, these would be limited to:
- Analysing our business for trends and research how we can improve our services to members;
- Reviewing the work we have carried out for you to ensure we have met the regulations and quality standards;
- Ensuring we are able to exercise or defend legal challenges in the future.
How long will you store my data?
We will only keep your personal information as long as necessary. How long that is depends on the type of data however in most cases, your personal data will be stored for an indefinite period as we need to keep evidence that we have fulfilled our legal and regulatory requirements.
Can I see a copy of my personal data?
Yes. Please write to our Data Controller (details below) and we will provide a copy of any personal data we hold about you within one calendar month of receiving your request. Please note that we may need to verify your identity before providing the information.
What if my data is incorrect or incomplete?
You have the right to have your data corrected or completed by contacting our Data Controller in writing (details below). Please be aware that we may need to maintain records of information as it was disclosed at the time of your application.
Can I have my data erased?
In most cases, we will not normally be able to erase your personal data. This is because we are obliged to maintain records of our dealings with you, even where applications to join the network are unsuccessful. This is typically to evidence compliance with regulatory processes and in some cases, to exercise or defend legal claims in future.
Who is the data controller
| Name | HL Partnership Limited |
| Address | HL Partnership Unit 1, 2nd floor, Southern Gate Office Village, Southern Gate, Chichester PO19 8GR |
| Telephone | 01903 602664 |
| compliance@hlpartnership.co.uk | |
| Data Controller Registration Number | Z8588911 |
How can I get more information?
If you would like further details on how we use your personal information or if you have any data protection queries, please write to The Data Protection Officer at the above address.
How can I make a complaint about how my data has been handled?
Please write in the first instance to the Data Protection Officer at the above address
If you are not satisified with the Data Protection Officer’s response, you can make a complaint to:
| Name | The Information Commissioner’s Office |
| Address | Wycliff House Water Lane Wilmslow Cheshire SK9 5AF |
| Telephone | 0303 123 1113 (local rate) or 01625 545 745 (national rate) |
| Email through their website | https://ico.org.uk/concerns/ |
COOKIES & USING THIS WEBSITE
Using the HLP Website
By submitting your personal data on our website, you agree to the data being transfered, stored and processed in line with this policy. We will take all reasonable steps to ensure that your data is treated securely and in accordance with applicable regulations.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. You must not share your password with anyone.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Cookies
Our website uses cookies to distinguish you from other users of our website. A cookie is a small file of letters and numbers that we put on your computer. Cookies contain information that is transferred to your computer’s hard drive.
The cookies we use are ‘analytical’ cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our website works, for example by ensuring that users are finding what they are looking for easily.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
| NAME | EXPIRATION | DESCRIPTION |
|---|---|---|
| _ga | 2 years | Used to distinguish users. |
| _gat | 10 minutes | Used to throttle request rate. |
| __utmat | 2 years from set/update | Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics. |
| __utmt | 10 minutes | Used to throttle request rate. |
| __utmb | 30 mins from set/update | Used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics. |
| __utmc | End of browser session | Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit. |
| __utmz | 6 months from set/update | Stores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics. |
| __utmv | 2 years from set/update | Used to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics. |
| eucookie | 1 year | Used to record displayed cookie disclaimer notification |
These cookies do not record any personally identifiable information (PII).
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
CHANGES TO OUR PRIVACY & COOKIES POLICY
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy and Cookies Policy.
Important Notes on Protecting your own Data
Please be aware of cybercrime and protecting your own information online, particularly financial information. Do not send unsecure personal information over the internet. We recommend you use encryption software or provide any information to us using the online tools we provide.
Do not respond to emails asking you to pay money. Never make a payment purely in response to an email. Always call the company to validate any payment requests and check the phone number independently from the email (i.e. via a secure web site). If you receive a phone call asking for payment ensure you are satisfied the call is genuine, or else call the company back to check. HL Partnership Limited will not take responsibility if you transfer money to a fraudster in error.
