Data Protection and Data Security Policy
1. Policy Statement
Everyone has rights with regard to the way in which their personal data is handled.
At Halpin Partnership Limited (‘Halpin’ ‘we’ ‘the Company’) we need to store and process personal data (information about you as an individual) to support the smooth running of the company and ensure that we can continue to provide our services.
This document explains what types of personal data we collect, what we do with that information, who has access to it and your rights as a data subject (someone whose data we hold).
Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Director of Operations or Joint CEOs.
2. Definition of Data Protection Terms
Information which is stored electronically, on a computer, or in certain paper-based filing systems.
For the purpose of this policy include all living individuals about whom we hold personal data. A data subject need not be a UK national or resident. All data subjects have legal rights in relation to their personal information.
Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (for example, a name, address or date of birth) or it can be an opinion about that person, their actions and behaviour.
Data controllers are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed. They are responsible for establishing practices and policies in line with GDPR. We are the data controller of all personal data used in our business for our own commercial purposes.
Data users are those of our employees whose work involves processing personal data. Data users must protect the data they handle in accordance with this data protection policy and any applicable data security procedures at all times.
Data processors include any person or organisation that is not a data user that processes personal data on our behalf and on our instructions. Employees of data controllers are excluded from this definition but it could include suppliers which handle personal data on the Company’s behalf.
Processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
Sensitive Personal Data
Sensitive personal data includes information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. Sensitive personal data can only be processed under strict conditions, including a condition requiring the express permission of the person concerned.
3. Data Protection Principles
Anyone processing personal data must comply with the eight enforceable principles of good practice. These provide that personal data must be:
- Processed fairly and lawfully.
- Processed for limited purposes and in an appropriate way.
- Adequate, relevant and not excessive for the purpose.
- Not kept longer than necessary for the purpose.
- Processed in line with data subjects’ rights.
- Not transferred to people or organisations situated in countries without adequate protection.
4. Fair and Lawful Processing
GDPR is not intended to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject.
For personal data to be processed lawfully, they must be processed on the basis of one of the legal grounds set out in the GDPR.
These include, among other things, the data subject’s consent to the processing, or that the processing is necessary for the performance of a contract with the data subject, for the compliance with a legal obligation to which the data controller is subject, or for the legitimate interest of the data controller or the party to whom the data is disclosed. When sensitive personal data is being processed, additional conditions must be met. When processing personal data as data controllers in the course of our business, we will ensure that those requirements are met.
5. Processing for Limited Purposes
In the course of our business, we may collect and process personal data. This may include data we receive directly from a data subject (for example, by completing forms or by corresponding with us by mail, phone, email or on social media) and data we receive from other sources (including, for example, business partners, sub-contractors in technical, payment and delivery services, credit reference agencies and others).
We will only process personal data for the purposes specifically permitted by GDPR.
6. Collection of Data
At Halpin we collect personal data about different groups of people, including:
- Our clients
- Prospective clients
- Event speakers and contributors to our research
- Employees, advisors, and sub-contractors
- Prospective employees, advisors, and sub-contractors
If you fit one or more of these categories we may hold a range of personal data, including some or all of the following:
- Your name, address and contact details, including email address and telephone number and link to social media profiles
- Photographs you have provided, for example if you’re a Halpin employee or sub-contractor and wish for your professional biography to be used in a proposal
- Equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, which you have provided and consented for processing
- Details of your qualifications, skills, experience and employment history
- Records of any communication between you and members of the Halpin e.g. a conversation thread saved automatically in any email browser
The personal data, which may be held in a paper file or on a computer or other media, is subject to certain legal safeguards specified in the General Data Protection Regulation (GDPR) and other regulations, as amended from time to time.
Halpin will collect information about you in a variety of ways, including:
- Directly from you
- Through desk-based research using publicly available and accessible sources
7. Use of Data
Depending on your relationship with Halpin we may use your personal data for some or all of the following purposes:
- Sending you news about our services, and ways to support us, including through research, blogging and events
- Analysing indicators of professional interests, such as professional experience or membership of sector bodies to help prioritise the marketing of our consultancy services and effectively use our resources and staff time
- Analysing the enquiries and engagement we receive to help us to better target our marketing and as part of developing our plans and strategies
- Accounting and financial monitoring
In some cases we are required to store and process your personal data e.g. your professional contact information, job title or department.
We will always ask for your consent before sharing anything publicly (e.g. through our website or social) which identifies you, such as announcing you as a Halpin speaker.
Where neither of these options applies we are storing and processing your data based on a Legitimate Interest as described in the GDPR.
8. Legitimate Interest
On the basis of legitimate interest, your personal data allows us to:
- Plan for the future and ensure we have the staffing and financial capacity to meet the demand for our services
- Continue improving our services so that we always offer the best possible support
- Protect our organisation against ethical, reputational and organisational risk
Some of the information we may hold (e.g. information about your religion or sexuality) is considered to be ‘special category data’ under GDPR. We will only collect and process this information with your specific consent, if we have a legal obligation to do so or if it is necessary to allow us to support you safely.
We will keep your data for only as long as we have a legal obligation, your consent or a Legitimate Interest to do so.
9. Accurate Data
We will ensure that personal data we hold is accurate and kept up to date. We will check the accuracy of any personal data at the point of collection and at regular intervals afterwards. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.
10. Timely Processing
We will not keep personal data longer than is necessary for the purpose or purposes for which they were collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required.
11. Access to Data
Your personal information may be stored electronically and/or on paper. In either case, access to this data will be restricted to only those Halpin employees and sub-contractors who need it in order to effectively carry out their role.
Occasionally we may need to share your data with organisations which provide services to Halpin, such as IT or database maintenance. We will always share as little data as possible and require them to commit, in writing, to maintain the confidentiality of your information, and to take the same level of care to protect and secure it which we would take ourselves.
12. Data Subject Rights
As a data subject, you have a number of rights. You can:
- Access and obtain a copy of your data
- Require us to transfer your data to another organisation
- Require us to change incorrect or incomplete data
- Require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing
- Object to the processing of your data where we are relying on our legitimate interests as the legal basis for processing
You can exercise these rights by contacting firstname.lastname@example.org.
You can also use these contact details to update or withdraw any consent to data storage and processing which you have previously given us. If you are not happy with our response, you can complain to the Information Commissioner’s Office.
13. Data Security
We will take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
We will put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data will only be transferred to a data processor if they agree to comply with those procedures and policies, or if they put in place adequate measures themselves.
We will maintain data security by protecting the confidentiality, integrity and availability of personal data, defined as follows:
Confidentiality means that only people who are authorised to use the data can access it.
Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.
Availability means that authorised users should be able to access the data if they need it for authorised purposes.
14. Disclosure and Sharing of Personal Data
We may disclose personal data we hold to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose personal data we hold to the prospective seller or buyer of such business or assets.
- If we or substantially all of our assets are acquired by a third party, in which case personal data we hold will be one of the transferred assets.
- If we are under a duty to disclose or share a data subject’s personal data in order to comply with any legal obligation, or in order to enforce or apply any contract with the data subject or other agreements; or to protect our rights, property, or safety of our employees, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We may also share personal data we hold with selected third parties in accordance with GDPR.
15. Policy Changes
We reserve the right to change this policy at any time. Where appropriate, we will notify data subjects of those changes by mail or email.
For more information please contact:
Shaun Horan, Joint CEO
Charlotte Stewart, Director of Operations
ICO Registration Number:
ICO Date of Registration:
ICO Registration Expiry:
Data Protection Officer: