Privacy Policy
Effective date: April 4 2025
Contact details
Post: 41 Market Square, Connect Dungannon, Dungannon, Tyrone, BT70 1JN, GB
Email: hartelandcoea@gmail.com
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
- Names and contact details
- Addresses
- Gender
- Occupation
- Date of birth
- Marital status
- Employment details (including salary, sick pay and length of service)
- Credit history and credit reference information
- Information relating to compliments or complaints
- Website user information
We collect or use the following personal information for the prevention, detection, investigation or prosecution of crimes:
- Names and contact information
- Financial information eg for fraud prevention or detection
We collect or use the following personal information for information updates or marketing purposes:
- Names and contact details
- Addresses
- Marketing preferences
We collect or use the following personal information for research or archiving purposes:
- Names and contact details
- Addresses
We collect or use the following personal information to comply with legal requirements:
- Name
- Contact information
- Identification documents
- Client account information
We collect or use the following personal information to protect client welfare:
- Names and contact information
- Client account information
We collect or use the following personal information for recruitment purposes:
- Contact details (eg name, address, telephone number or personal email address)
- Date of birth
- National Insurance number
- Copies of passports or other photo ID
- Employment history (eg job application, employment references or secondary employment)
- Education history (eg qualifications)
- Right to work information
- Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks )
- Security clearance details (eg basic checks and higher security clearance)
We collect or use the following personal information for dealing with queries, complaints or claims:
- Names and contact details
- Address
- Purchase or service history
- Correspondence
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
- Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
- Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
- Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
- Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
- Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
- Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
- Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for the prevention, detection, investigation or prosecution of crimes are:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information for information updates or marketing purposes are:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Our lawful bases for collecting or using personal information for research or archiving purposes:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Our lawful bases for collecting or using personal information to comply with legal requirements:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information to protect client welfare are:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for recruitment purposes are:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
- Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Where we get personal information from
- Directly from you
How long we keep information
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to meet legal, regulatory, tax, accounting or reporting requirements. The following is our standard data retention schedule:
Client Contact Information:
We retain contact details of buyers, sellers, landlords, and tenants for 7 years after the last contact. This is to manage potential future enquiries, complaints, or legal matters.
Identification Documents (e.g. passports, utility bills):
These are collected to comply with anti-money laundering (AML) regulations and are retained for 5 years after the end of the client relationship, in line with legal requirements.
Tenancy Applications:
Details submitted in rental applications are retained for 6 years after the tenancy ends to deal with any potential disputes or legal issues.
Tenancy Agreements:
Contracts and associated documents are kept for 6 years after the tenancy ends, as required under the Limitation Act 1980, to allow for defence against legal claims.
Property Sale Agreements and Related Records:
These are retained for 7 years after completion of a sale, to comply with financial regulations and for audit purposes.
Financial Information (including bank details, invoices, and payment records):
Financial data is retained for 6 years to meet HMRC tax and accounting obligations.
Property Maintenance Records:
Maintenance and repair logs for managed properties are kept for 6 years after the issue is resolved, to ensure compliance with health and safety regulations and to manage any future disputes.
CCTV Footage (if used on our premises):
Retained for 30 days unless required longer due to an incident or investigation, in line with ICO guidelines.
Marketing Preferences and Consent Records:
We retain records of marketing consent for up to 2 years, or until the individual withdraws consent—whichever is sooner.
Employee and Job Applicant Information:
Employment records are retained for 6 years after the end of employment. Unsuccessful job applicant data is retained for up to 12 months.
All personal data that is no longer required is securely deleted or anonymised. Data subjects have the right to request deletion of their data in accordance with UK GDPR.
Who we share information with
- Other financial or fraud investigation authorities
- Professional or legal advisors
- Organisations we’re legally obliged to share personal information with
- Previous employers
- Suppliers and service providers
- Professional consultants
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline number: 0303 123 1113