Privacy Policy

Here at HOGEN DATA we are passionate about demystifying Data Protection and all things Privacy. In a world that is complex enough, we aim to make your compliance journey as simple as possible.

We avoid over-complicated technical jargon and ‘consultant speak’, bringing to life the Data Principles by talking you through real-life examples we’ve come across in the last two decades of managing Information, Data and Intelligence

So, our Simple approach starts here, in our Privacy Notice. You may sometimes hear this document referred to as an FPN or Fair Processing Notice too. In short, it’s a snapshot of how our organisation processes your personal data whilst delivering a first-class service to our customers

By taking the time to read the below, you will have a good idea of what HOGEN DATA does with your data, from obtaining it in the first instance, right through to deletion. We’ve also added in which Rights you have too!

Because we aim to instil a Privacy First culture into the DNA of your business from the outset, a great place to improve your knowledge is through this notice. To that end, you might want to grab yourself a coffee and take the plunge……you might just learn something?

#Trusthogen (‘we’ and ‘us’) is a trading name of HOGEN DATA LTD.

We are what’s known as the Data Controller, meaning we are an ‘entity’ that decides how and why your personal data is used.

Using your personal information
When you contact us, we’ll collect some of your personal details to enable us to contact you about your query and enter into a contract should you wish to use our services

We’ll never ask for more information than we need to process your relationship with us, collecting only what is deemed adequate to carry out the task.

Examples of the types of personal information we usually collect are:

Name
Address
Telephone number (including mobile)
Email address
Payment details (Direct Debit, credit/debit card number)
I.P. address for your device (if visiting our website)

Unless we tell you otherwise, the personal data and information you supply will never be used for any other purpose without your permission.

Lawful Basis
We have several internal processes that enable us to service your requirements. For each, we must tell you about the lawful basis we will rely upon. In short, it’s simply the reasoning and the justification to ensure we have a use for the data we obtain from you.

Consent – We rely on this lawful basis, specifically around Direct Marketing

We may also rely on this basis should you decide to chose to activate any of the other cookie types. For your information, we don’t collect information about you via cookies others than those that are deemed essential.

In any case, you can clear your cache at your own leisure.

Contract – You may have asked us to do something, for example, provide a quote for a service or perhaps one off assistance.

Equally, we will also use this basis to enable us to deliver a service to you

Keeping and storing your data
If you’re an existing customer or we have had a relationship previously, we’ll keep your personal data for 6 years from the time our services to you cease.

This is because we have a legal obligation to the HMRC should they wish to make an inquiry with us. It also enables us to handle any complaints more effectively.

Should you make a query and decide not to proceed with us, we’ll typically keep your data for 28 days, unless you tell us we can keep it to market to you in the future.

Your data really matters to us, so we make inquiries with our suppliers to establish where they may store your data or share it with their sub processors. At the time of writing, all of your personal data is stored within the European Economic Area (‘EEA’).

Sharing your data with third parties
As you would expect, we don’t share any of your personal data with third parties for marketing purposes, though we will share it with companies in the course of managing our services to you.

Our suppliers are chosen following due diligence and vetting checks to ensure they are legitimate and trusted and will only be shared in order to:

To deliver the services you’ve asked for, which includes sharing your information with a specialist consultant from our network (if required for a specific service)
For legal or regulatory purposes including fraud prevention
If we buy or sell any business or company assets

Examples of this might be where we are undertaking legal advice on your behalf with organisations such as the Data and Marketing Association.

If we are acting as an outsourced DPO for your organisation, we may also have cause to speak with the Information Commissioners Office upon receipt of correspondence from the Regulator.

Some of our Software Platforms, for example Prove Privacy, assist us by maintaining and hosting your personal data & commercial information within our class leading DPOaaS solution. In the unlikely event of a system failure the information accessed by Prove Privacy is strictly controlled by Hogen Data and protected by Non Disclosure Agreements and contractual terms

Marketing preferences
HOGEN DATA and the wider #Trusthogen brands are constantly improving our services and products for our clients. We believe these are exciting times for our company and want to bring you on the journey with us. However, we understand if you don’t want to hear from us………besides, you can always change your mind later !

For those that do wish to hear from us, we’ll ask you how best to contact you, be it SMS, email, post or phone. You will also be able to unsubscribe via the link at the base of every marketing email.

Your rights
The Data Protection Act was updated in 2018, with Rights being at the forefront of the Regulators minds from the outset. We totally support this and list the Rights you have (and more importantly, what they mean) below:

Right of Access – This means you have the right to ask Hogen Data Ltd about the Personal Data they are currently holding about you
Right to be informed – You have a right to be aware of how your data is being processed. We look to uphold this Right by providing you with THIS notice. Please be assured, should the way we process your data change, we’ll let you know
Right to Data Portability – In basic terms, should you wish us to help you move your data to another organisation, we will do so in a secure and legible format
Right to Erasure – In certain circumstances, you may have the right to have your personal data deleted. This will depend on whether there are other reasons that we may have to hold onto your information
Right to Object – This might be a request to stop marketing to you, or perhaps insist we stop processing your data for other reasons. Unless there is a compelling reason for us not to do so, we will cease the processing of your data
Right to Rectification – It is important that the quality and accuracy of your data is of the highest standards and reflective of your circumstances. Requests might include an update of your bank details, contact details or perhaps a change of sex or name?
Right to Restrict – This right is normally upheld by a business upon receipt of a Right to Object request. This means we may ‘pause’ what we are doing with your data whilst we look into your request
Rights in Relation to automated decision making and profiling – At present, Hogen Data Ltd doesn’t make use of profiling of automated decision making. However………..Think! Have you ever applied for something online, perhaps with a financial services company and the ‘computer has said NO’?
This is usually an example of automated decision making, to which you can ask for an actual person to intervene and review the decision

The Legal Bit…
Should you feel you would like to exercise one of the above rights, please contact our DPO Gary Langrish on gary@trusthogen.com

Or by post via

Rights Requests

C/O DPO

Hogen Data

Edward Pavilion

Albert Dock

Liverpool

L3 4AF

Please help us by clearly identifying in the subject line that this is in relation to a RIGHTS REQUEST. We have an obligation to deal with your request asap and in any case, within 1 month of receipt, so any help here is appreciated.

Less Than Happy?
In the unlikely event that you’re unhappy with the way we have processed your personal data, you can contact the Information Commissioners Office, often referred to as the ICO.

For full details about how to share any concerns you may have, visit www.ico.org.uk/concerns/

If it helps, our Registration Number with the ICO is ZA780346

That way they’ll recognise more easily who we are.

Mention of other companies on our website
We pride ourselves on the relationships we have built over the years.

To that end, we might include names and links of trusted partner agencies that we think you could benefit from.

Any contact with a third party will be subject to the rules and overarching Privacy Notices and Policies you have with that ‘specific ‘Data Controller’ and not Hogen Data Ltd directly.

Like with any website or business, please carefully read the conditions and be sure they are capable of effectively safeguarding your personal data before disclosing your details.

Keeping you informed
We have an obligation to ‘Keep you Informed’, so may, from time to time, have a requirement to update this document to accurately reflect the way we process your personal data. We promise to review this Privacy Notice annually, in any case

For your information, this is version V1.0 and was created and reviewed by Gary Langrish (our DPO) on 23/08/2020.what