This notice supplements the main Harwick privacy notice, including its information about international transfers and your rights.
Who we are and who this covers
Harwick Intelligence Limited, company number 17545458, registered office 71-75 Shelton Street, Covent Garden, London WC2H 9JQ, is responsible for its own decisions about personal information used in investigations. ICO registration: ZC286587. This notice covers people investigated, witnesses and individuals incidentally appearing in evidence. For privacy requests use our contact form, stating that your request concerns personal information. Harwick will agree a secure channel for sensitive material.
What we collect and sources
Depending on a particular lawful assignment, information may include identity, public business and property records, public online material, relevant third-party statements, and time-limited observations or images lawfully obtained. Some information may be supplied by the client, public bodies, legitimate commercial sources or authorised specialists. We screen for relevance and seek to limit incidental information about others.
We do not treat publicly accessible information as exempt from data-protection law. We do not authorise unlawful access, interception, harassment or deceptive acquisition of protected data.
Purposes and lawful bases
Purposes may include establishing facts for actual or prospective disputes, fraud enquiries, due diligence or other specific legitimate enquiries. We assess each instruction for lawful purpose, necessity, proportionality and risks to individuals. Where appropriate we rely on Article 6(1)(f) legitimate interests, identifying whose interest and weighing the effects on people. A different lawful basis may apply to a particular purpose and is documented where used.
We avoid special category and criminal-offence data unless necessary and a separate applicable Article 9 or Article 10 / Data Protection Act 2018 Schedule 1 condition is documented, with any required appropriate policy document.
When we provide information directly
Normally, where information has not come from you, Article 14 requires us to provide privacy information within a reasonable period and no later than one month, or earlier if we first communicate with you or disclose the information to someone else before then. In a particular enquiry we may delay or limit direct notice only where a specific lawful exception or exemption applies. For example, providing notice may seriously impair the objective of an investigation. We assess and document the precise legal ground and likely prejudice case by case and review it as circumstances change. This published notice does not automatically replace individual notice.
Sharing and overseas access
Relevant material may be provided to the instructing client for its agreed lawful purpose, or to authorised investigators, service providers, advisers, insurers, courts or authorities where justified. Specialist providers may act as processors or independent controllers according to their actual role and obligations. We limit access and protect transfers. Information is not sold for marketing. Overseas processing takes place only with a valid legal basis and applicable transfer safeguards.
Retention and rights
We generally schedule closed case files for review and deletion at six years, subject to shorter retention for irrelevant material and specific legal claims, holds or other necessary exceptions. You may request access, correction, erasure, restriction or object to legitimate-interests processing, as applicable. Rights are not removed just because an enquiry exists. Any restriction is assessed individually under the law, and we will explain our response so far as we lawfully can.
Contact Harwick through our website contact form. We may require proportionate proof of identity. We normally respond within one month, subject to any lawful extension or relevant timing rule. You may complain to the Information Commissioner’s Office (ICO).