Privacy policy
Important notice
This is the privacy notice of HFIS Limited (registration number: 3252806) whose registered office is at Lumiere, Suite 1-3, Elstree Way, Borehamwood, WD6 1JH. HFIS Limited is the Scheme Administrator for client money protect on behalf of the Department for Levelling Up, Housing & Communities (DLUHC).
This privacy notice sets out how we collect and process your personal data. This privacy notice also provides certain information that is legally required and lists your rights in relation to your personal data.
This privacy notice relates to personal information that identifies you as a natural person (whether you are an actual or potential customer, an individual who browses our website or an individual outside our organisation with whom we interact). We refer to this information throughout this privacy notice as personal data or personal information and further detail of what this includes are set out in this privacy notice below.
The privacy and security of your personal information is very important to us so we want to assure you that your information will be properly managed and protected by us at all times. Please read this privacy notice carefully as it explains how we may collect and use your personal data.
This privacy notice may vary from time to time so please check it regularly.
This privacy notice was last updated in February 2021.
How to contact us
Controller and contact details
For the purposes of relevant data protection legislation, we are a controller of your personal data. As a controller we use (or process) the personal data we hold about you in accordance with this privacy notice.
If you need to contact us in connection with the use or processing of your personal data, then you can do so using our contact details on our website.
What information we hold about you and where we obtain this from
The personal data that we collect about you may include the following information:
- Personal data you provide to us in person, via our website or by telephone
- Personal data you provide when you enquire about joining the Scheme such as, business activities, your home or rental properties and tenants
- General information about you, such as your name, address, contact details and date of birth
- Personal data you provide if you subscribe to any of our mailing or newsletter services
- Financial details, such as your bank account and card details
- Information about your use of our website such as your IP address, which is a unique number identifying your computer, including personal data gathered using cookies
We collect your personal data from you as a processor when you join the Scheme, when we make changes to your membership and when dealing with a dispute. This may involve the collection of data from or about others who are associated with you and your membership such as your letting agent or tenants. By giving us information about someone else for the purpose of arranging Scheme membership you confirm that you have their permission to do so and that you have shared this privacy notice with them.
We also collect information from publicly available sources and third party databases made available to the relevant industry for the purposes of reducing fraud and financial crime as well as any other third party databases where your personal data may be held, provided such third parties have lawful bases on which to share such personal data with us.
How we use your personal data and the lawful basis for doing so – where we are relying on a basis other than consent.
We may rely on one or more of the following legal bases when processing your personal data for the following purposes:
| Purposes for which we process your personal data | The basis on which we can do this (this is what the law allows) |
|---|---|
| In order to perform our contractual obligations to you. This would include our fulfilling your requests for insurance services (including obtaining insurance for you, fulfilling requests for mid-term adjustments and obtaining renewals) | The processing is necessary in connection with any contract that you may enter into with us |
| In order to perform our legal obligations to you. This would include our fulfilling your requests for our Membership Schemes | The processing is necessary in connection with any contract that you may enter into with us |
| To administer your account, including financial transactions for the product or service we have provided you | The processing is necessary in connection with any contract that you may enter into with us |
| In the interests of security and to improve our service, telephone calls you make to us may be monitored and/or recorded | The processing is necessary to pursue our legitimate interest in the management and operation of our business |
| To let you know about similar products and services that may be of interest to you | The processing is necessary to pursue our legitimate interest in operating our business |
Who we pass your personal data to
We may need to pass your personal data to other companies which may include:
The insurers of the Scheme in order to comply with any conditions specified by the Insurer. This may also include loss recovery agencies, and other third parties involved (directly or indirectly) in the administration of your membership
Firms that provide administration and processing services to us or on our behalf under contract in order to complete activities such as IT systems and administrative services and other activities set out in this privacy notice, as well as support activities such as finance and auditing services
Organisations that have a specific role laid out in law, such as statutory bodies, regulatory authorities and other authorised bodies
Other organisations where we have a duty to or are permitted to disclose your personal information by law, for example if we received a valid request from the police or other third party organisation in the interest of preventing and detecting crime
- Fraud prevention agencies and operators of registers available to the industry to check information and prevent fraud
- Any tenant where the details of the tenanted property and the persons forming the tenant have been registered with the scheme
- Any interested party who has provided the whole or part of the deposit as a guarantor or in another capacity
- Any tenant who wishes to verify that the deposit has been protected
- Third parties we use to recover money you may owe us or to whom we may sell your debt
- Local Housing Authorities in accordance with section 212A of the Housing Act 2004
- The Ministry of Housing, Communities, Local Government for statistical data in accordance with our contract with them
The information you share with us may be transferred by us or any of the types of firms or organisations we have noted above, to other countries in order for processing to take place, including locations outside of the UK and the European Union. We will only do so if there are adequate levels of protection in place as required by applicable data protection laws.
Your rights
We will only store your data for as long as is necessary to comply with the requirements of your insurance contract(s) and any legal obligations or lawful processing conditions that may exist as a result. If you are a member of one of our Membership Schemes your data will be stored for as long as is necessary to comply with the relevant legal obligations. You have a number of rights concerning the personal information we use, which you may ask us to observe. In some cases even when you make a request concerning your personal information, we may not be required, or be able to carry out your request as this may result in us not being able to fulfil our legal and regulatory obligations under the lawful processing conditions under which we hold your data or because there is a minimum statutory period of time for which we have to keep you information.
You can ask us to:
- Provide a copy of your personal information
- Correct or delete unnecessary or inaccurate personal information
- Restrict or to object to the use of your personal information at any time
- Object to any automated decision, including profiling which may have been used by insurers when underwriting your quotation. Where an automated decision has been made we will advise you of this and of your rights
- Provide your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller. This right only applies where our processing of your personal data is automated and the processing took place initially with your consent or for the performance of a contract with you
- Where we rely on your consent to use your personal information, you can withdraw that consent at any time. Where your consent is withdrawn, your previous consent will remain valid in respect of our use of your information prior to the date you withdrew it, or if any marketing material has been sent prior to you advising that you don’t want us to contact you again
If you have any questions or concerns about this privacy notice or your data protection rights please contact us using our details set out at the beginning of this privacy notice.
You also have the right to make an enquiry or to complain to the Information Commissioner’s Office (ICO) if you are unhappy with our use of your data, or if you think we have breached a legal requirement. Further details about the ICO are available at: www.ico.org.uk.
How we contact you about other products and services
We may from time to time process your personal data to let you know about similar products and services that may be of interest to you. This is because we value your custom and we pride ourselves in offering professional and tailored advice which meets your specific needs within the private rental sector. This includes keeping you informed on the latest and industry information and details of any offers or promotions relating to the services we provide to you. Our lawful basis for processing your personal data in this way is as is necessary to pursue the legitimate interests of our business, unless we have otherwise obtained your consent to do so. We may contact you by post, telephone or e-mail. You will be given the option to stop receiving any communications from us in this regard at any time, however, please note that this will not affect us contacting you about the servicing of products that you have specifically requested from us.
