Please note: we are working as usual despite the Coronavirus and still taking telephone calls and emails.
This Privacy Notice explains the types of personal data we may collect about you and how this is stored when you become a Halkin customer and use some of our services or app.
The government has updated the General Data Protection Regulations which state businesses must better inform customers about the data they collect and how this is used and stored. Under the Regulations, Halkin is acting as a Data Controller.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how Halkin uses your data. Depending on the type of service you have, we are required to collect some information from you to validate your identity under the HMRC 2017 Money Laundering Regulations. We are also obligated under the FSA to hold some financial data for 5 years after you last took services from us.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example; to enable us to, contact you and explain what we do prior to entering into a contract with you, we need your address, phone number and email address. If your registered office is your home address, we will need to hold this information.
Legal compliance
If the law requires us to, we may need to collect and process your data.
For example; we are required under the HMRC MLR 2017 regulations to collect and verify details of company directors in accordance with our Compliance Policy. We have to hold copies of documents to show HMRC if the audit our procedures.
Legitimate business operation
We require your data to allow you to access the building and services you have purchased. We also hold data other systems, such as the meeting room booking and visitor management system. The regulation deems these systems, and the data held, as reasonably expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example; we will provide you with access to our app and members portal to book meeting rooms, view your bill and communicate with Halkin and other Halkin Members. We need your email and phone number to send you booking confirmations.
We also use your email or phone number to notify you of any visitors or packages you may have.
We will also use your email address details to send you information telling you about member events and services that we think might interest you.
Consent
In specific situations, we can collect and process your data with your consent.
For example; when you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is in connection with a particular service. In most instances we will only require your name, email address and phone number.
For example; we collect notes from our conversations with you, details of any feedback or comments you make, details of meeting room bookings and other services you may purchase.
We’ll only ask for and use your personal data collected to enable us to fulfil our service obligations to you. Of course, it’s always your choice whether you share such details with us, however we may not be able to provide some of the regulated services such as Halkin Smart Virtual without you confirming your identity.
We want to provide you with the best possible service. One way to achieve that is to get the full picture of you and your business requirement for our service by combining the data we have about you. We then use this to offer you products and services that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
Here’s how we’ll use your personal data and why:
For example; your details may need to be passed to a third party to supply or deliver the product or service such as telephone or internet access, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations.
For example; in the event of an audit of information we hold on you from HRMC
Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.
We want to bring you offers and promotions that are most relevant to your business needs at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered as described above. For this purpose, we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us – such as the Brokers or Companies House mentioned above.
We know how much data security matters to all our customers. With this in mind, we will treat your data with the utmost care and take all appropriate steps to protect it. Your data will be held in our management software Microsoft 365 and Dynamics CRM and other accounts and business management systems.
We have verified with all our data storage and system providers that they are using the correct encryption methods to comply with the GDPR regulations.
We secure access to all transactional areas of our websites and apps using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by highly regulated 3rd party providers using SSL encryption.
Our partners regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
For example;
Contracted Customers – We are legally required to keep records for 5 years after you last do business with us, so we can comply with the FSA regulations.
Enquiry details – If you have contacted for information regarding one of our services we will retain your information for 3 years or until you tell us you wish to be removed.
We share your personal data with trusted third parties.
For example; our security company and our Internet and telephony partners, to enable us to provide the services you have purchased.
The policy we apply to those organisations to keep your data safe and protect your privacy is listed below;
Examples of the kind of third parties we work with; – IT companies who support our business systems and provide internet services.
Sharing your data with third parties for their own purposes
We will only do this in very specific circumstances, for example;
For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as Australia or the USA.
This is not something we currently do, if we do in the future, we will apply the same procedures to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
An overview of your different rights
You have the right to request;
For example; when you withdraw consent, or object and we have legitimate overriding interest, or once the purpose for which we hold the data has come to an end
Review by a Partner of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
If we choose not to action your request, we will explain to you the reasons for our refusal.
Your right to withdraw consent;
Direct marketing
Checking your identity
There are two ways you can stop direct marketing communications from us:
Please note that you may continue to receive communications for a short period after changing your preferences while out systems are fully updated.
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
To contact them go to www.ico.org.uk/concerns (please note we can’t be responsible for the content of external websites)