Privacy Policy
Why should you read this document?
HCF Partnership Ltd (“HCF”) is dedicated to safeguarding the privacy of its clients. Throughout our dealings with you, we will request detailed personal information about your current circumstances, your financial situation (“Personal Data”), and, in some cases, your health and family health history (“Special Category Data”). This document is crucial as it explains how we will use, store, and protect your data, as well as the various rights you have regarding this.
What do we mean by “Personal Data”?
Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, such as your name, address, date of birth, National Insurance number, or indirectly, such as your employment situation, your physical and mental health history, or any other information that could be linked to your cultural or social identity.
To help with your financial planning needs, we may also need to collect information and documents about your income, employment, and current financial situation, including any existing plans and policies you have in place.
What is meant by “Special Category Data”?
When you ask us to assist with your insurance needs, such as life, accident, or illness insurance, we will request information about your health, medical history, and ethnic origin. We need to record and use any Special Category Data to contact insurance providers about suitable products for your needs and to give you advice on their suitability. We are required to obtain your explicit consent to use this data, which you can do by using the opt-in box before signing our client agreement. You are not obliged to consent to HCF Partnership using this information, but if you do not consent or withdraw your consent — which you are entitled to do — we may be unable to provide our services when such information is necessary.
The basis on which HCF will process your Personal Data
When we discuss your Pension, Investment, Mortgage, and/or Insurance requirements, we do so on the understanding that both parties are entering into a contract for the provision of services.
To execute that contract and organise the products you need, we have the right to use your Personal Data for the purposes specified in the client agreement.
Additionally, whether during initial discussions with you or after our contract has ended for any reason, we have the right to use your Personal Data if it is in our legitimate business interest and your rights are not affected. For instance, we may need to respond to requests from mortgage lenders, insurance providers, and our Compliance Service Provider regarding the advice we have provided to you, or to contact you for feedback on the service you received.
Occasionally, we will use your Personal Data to fulfil our legal obligations to our regulator, the Financial Conduct Authority, or to comply with other legal or regulatory requirements we may be subject to. In such cases, we process your Personal Data to meet a legal, compliance, or other regulatory duty.
Relatives and Associates Personal Data
When HCF collects data about your personal and financial situation, we may also need to gather information about your spouse, children, trustees, beneficiaries, etc., to provide you with more comprehensive advice. The ongoing processing of their data is based on the lawful basis called ‘legitimate interest,’ as it is necessary for continuing the service offered by HCF. Without this information, we may not be able to deliver the personalised and high-standard service we aim to offer all our clients.
How do we collect your Personal Data?
We will gather and record your Personal Data from various sources, primarily directly from you. You typically provide information during our initial meetings or conversations to outline your circumstances, needs, and preferences regarding Pension, Investment, Mortgage, and/or Insurance. This information will be given verbally and in writing, including via email.
To verify your identity, we are required to engage a third-party Anti-Money Laundering provider to carry out the verification services on our behalf. We have selected Sanctions Search and Smartsearch because they are highly reputable and uphold the high standards HCF expects from its contractors. As a result, they are considered Joint Data Controllers since we share some of your Personal Data with them to obtain certain verification documents.
What happens to your Personal Data when it is disclosed to us?
During the processing of your Personal Data, we will record and store it in our paper files, on mobile devices, and within our computer systems (including websites, emails, hard drives, and cloud services). Access to this information is restricted to our employees and consultants, and only when necessary to provide our services, such as submitting and communicating with Product Providers, Mortgage Lenders, Commercial Lenders, and/or Insurance Product Providers, whether in paper form or online via a secure portal. Sharing this information with third parties is crucial for progressing any enquiry or application made on your behalf and for addressing any additional questions or administrative matters raised by lenders and providers.
Sharing your Personal Data
Depending on the advice you need, your Personal Data will be shared with investment, mortgage, and insurance providers. Additional third parties may include compliance advisers, product specialists, estate agents, legal services, and IT providers. In each case, your Personal Data will only be shared for the purposes outlined in this customer privacy notice, i.e., to progress your Pension, Investment, Mortgage, and/or Insurance enquiry.
Please note that sharing your Personal Data with third parties does not give them the right to send you marketing or promotional messages. It is shared solely to enable us to adequately fulfil our responsibilities to you, and as otherwise outlined in this Privacy Notice.
We do not anticipate that our performance of the service will result in your Personal Data being transferred outside the European Economic Area.
Security and retention of your Personal Data
Your privacy is important to us, and we will keep your Personal Data secure in accordance with our legal obligations. We will take reasonable measures to protect your Personal Data from being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to protect your own privacy when transferring information to us, such as avoiding sending confidential information over unsecured email, ensuring email attachments are password protected or encrypted, and using only secure postage methods when sending original documentation to us.
Your personal data will be retained by us either electronically or on paper for a minimum of six years after the termination of the contract. However, if we have a legal right to such information, we will keep records indefinitely.
Your rights in relation to your Personal Data
Your rights have been strengthened and updated to give you greater control over the data held by HCF. You can request copies of your Personal Data, ask us to explain how we use your Personal Data, request correction, deletion, or restriction of its use (if permitted), ask us to send an electronic copy to another organisation, and modify your consent to enable us to contact you for marketing purposes in the future (including withdrawing any consent). Please contact us directly for further information.
How to make contact with our Firm in relation to the use of your Personal Data
If you have any questions or comments about this document, or wish to contact us to exercise any of your rights outlined within it, please get in touch with the Data Protection Officer at HCF Partnership Ltd via the contact details provided in the header. If we believe we have a legal right not to respond to your request or to handle it differently from how you have requested, we will inform you of this at the time.
If you have any concerns or complaints about how we have handled your Personal Data, you may lodge a complaint with the UK’s data protection regulator, the ICO. You can contact them through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
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Where we are
HCF Partnership
Ground Floor, 8 Beaumont Gate,
Shenley Hill, Radlett,
Hertfordshire, WD7 7AR