This is the privacy notice of Highland Brokers Ltd (‘we’, ‘our’, or ‘us’), Company number SC698264.
OUR REGISTERED OFFICE IS AT:
24 Longman Drive
This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.
In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.
This notice applies to personal data collected through our website and through social media platforms e.g., Facebook (now known as Meta).
We will only disclose to a third party, e.g. HMRC, any essential information collected through our website.
DATA PROTECTION OFFICER
If you have any questions about how we process your personal data, including any requests to exercise your legal rights, please contact our DPO, Linda Nicholls, at firstname.lastname@example.org.
PERSONAL DATA WE PROCESS
How we obtain personal data
The information we process about you includes information:
you have directly provided to us
that we gather from third party databases and service providers, e.g., NHS Highland
as a result of monitoring how you use our website or our services
TYPES OF PERSONAL DATA WE COLLECT DIRECTLY
When you use our website or our services, we ask you to provide personal data. This can be categorised into the following groups:
personal identifiers, such as your first and last names, your title and your date of birth
contact information, such as your email address, your telephone number and your postal addresses
pre-paid Financial Services information, including your username and password
payment information, such as bank account details
records of communication between us including messages sent through our website, email messages and telephone conversations
In addition, we may also process:
documentation that confirms your identity, such as an image of your passport or driver’s licence
an image that shows your face, such as a passport photograph
TYPES OF PERSONAL DATA WE COLLECT FROM THIRD PARTIES
We confirm some of the information you provide to us directly using data from other sources. We also add to the information we hold about you, sometimes to remove the need for you to provide it to us.
The additional information we collect can be categorised as follows:
information that confirms your identity
information that confirms your contact information
TYPES OF PERSONAL DATA WE COLLECT FROM YOUR USE OF OUR SERVICES
By using our website and our services, we process:
information you contribute to our community, including reviews
technical information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages
transaction information that includes the details of the services you have bought from us and payments made to us for those services
how you wish to communicate with us; and responses and actions in relation to your use of our services.
OUR USE OF AGGREGATED INFORMATION
We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.
For example, we may aggregate usage information to assess whether a feature of our website is useful.
However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice.
SPECIAL PERSONAL DATA
Special personal data is data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
It also includes information about criminal convictions and offences.
We do not collect any special personal data about you unless there is a lawful basis on which to do so.
IF YOU DO NOT PROVIDE PERSONAL DATA WE NEED
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract.
In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.
THE BASES ON WHICH WE PROCESS INFORMATION ABOUT YOU
The law requires us to determine under which defined bases we process different categories of your personal data, and to notify you of the basis for each category.
If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data.
If the basis changes, then if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
1. Information we process because we have a contractual obligation with you
When you buy a service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal data.
We may use it in order to:
verify your identity for security purposes when you use our services
provide you with our services
provide you with suggestions and advice on services
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
2. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our services, you provide your consent to us to process information that may be personal data.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, we ask you to agree to our use of non-essential cookies when you access our website.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at email@example.com. However, if you do so, you may not be able to use our services further.
We aim to obtain and keep your consent to process your information. However, while we take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent us from continuing to process it. The law may allow us to continue to process your personal data, provided that there is another basis on which we may do so. For example, we may have a legal obligation to do so.
3. Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
whether the same objective could be achieved through other means
whether processing (or not processing) might cause you harm
whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
improving our services
record-keeping for the proper and necessary administration of our business
responding to unsolicited communication from you to which we believe you would expect a response
preventing fraudulent use of our services
exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property
insuring against or obtaining professional advice that is required to manage business risk
protecting your interests where we believe we have a duty to do so
4. Information we process because we have a legal obligation
Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal data.
5. Information we process to protect vital interests
In situations where processing personal information is necessary to protect someone’s life, where consent is unable to be given and where other lawful bases are not appropriate, we may process personal information on the basis of vital interests.
For example, we may inform relevant organisations if we have a safeguarding concern about a vulnerable person.
HOW AND WHEN WE PROCESS YOUR PERSONAL DATA
1. Your personal data is not shared
We do not share or disclose to a third party any information collected through our website.
2. Information you provide
We collect and process personal identifiers, contacts and characteristics (for example, name and email address), plus any additional information provided by you in our Contact Us form, or any other means by which you contact us.
3. Payment information
We store information about your Pre-paid Financial Services card when you first provide it to us.
We store this payment information at your request in order to make repeat payment of services for your care.
We take the following measures to protect your payment information:
we keep your payment information encrypted on our servers
access to your payment information is restricted to authorised staff only
When you agree to set up a regular payment arrangement for our fee, the information you give to us is passed to our own bank (The Co-operative Bank) for processing according to our instructions.
We keep this information only for the duration of the regular payment arrangement.
4. Information obtained from third parties
Although we do not disclose your personal data to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal data from third parties whose services we use.
5. Third party links on our website
Third parties may be linked on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you.
We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.
6. Service providers and business partners
We may share your personal data with relevant bodies, including our payroll software provider. We may also pass personal information to agencies such as NHS Highland if we strongly suspect fraud on our website or in any other aspect of our business.
USE OF INFORMATION WE COLLECT THROUGH AUTOMATED SYSTEMS
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.
They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.
They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.
Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.
Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.
The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.
to track how you use our website
to record whether you have seen specific messages we display on our website
to keep you signed in to our website
2. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
1. Your rights
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data.
We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org
2. Use of our services by children
We do not allow children to purchase our services, nor do we market to children. Our contracts are with appointed adults, even when the recipient of care for which Self Directed Support is provided is a child.
We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.
3. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
4. Delivery of services using third party communication software
With your consent, we may occasionally have to communicate using software provided by a third party such as Facebook, now known as Meta (WhatsApp or Messenger), Apple (Facetime) or Zoom Video Communications (Zoom).
Such methods of communication should secure your personal data using encryption and other technologies. The providers of such software should comply with all applicable privacy laws, rules, and regulations, including the GDPR.
If you have any concerns about using a particular software for communication, please tell us.
5. Data may be processed outside the UK
Our website is hosted outside the UK. Accordingly, data obtained within the UK or any other country could be processed outside the UK. This is very common practice and nothing to be concerned about.
Our website provider works with a team of experts to help ensure that their services are in compliance with privacy regulations. This means your information is secure.
6. Control over your own information
It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes.
At any time, you may contact us to request that we provide you with the personal data we hold about you.
When we receive any request to access, edit or delete personal data we first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Please be aware that we are not obliged by law to provide you with all personal data we hold about you, and that if we do provide you with information, the law allows us to charge for such provision if doing so incurs costs for us. After receiving your request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
We remind you that we are not obliged by law to delete your personal data or to stop processing it simply because you do not consent to us doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which we may process it, we may do so on that basis.
7. Communicating with us
When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
If we receive a complaint, we will record the information you have given to us on the basis of consent. We use that information to resolve your complaint.
If we think your complaint is vexatious or without any basis, we shall not be required to correspond with you about it.
If your complaint reasonably requires us to notify some other person, we may decide to give to that other person some of the information contained in your complaint. We would aim to do this as infrequently as possible, but it is a matter for our sole discretion whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal data, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.
9. Retention period
Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us:
to provide you with the services you have requested
to comply with other law, including for the period demanded by our tax authorities
to support a claim or defence in court
10. Compliance with the law
We shall update this privacy notice from time to time as necessary.