Information presented on this website is advertising in nature

Last Updated: 1 November 2024

Dapper-harbor is committed to compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This page explains how we uphold your rights and protect your personal data in accordance with these regulations.

Our Role as Data Controller

For personal data collected through our website and business enquiries, Dapper-harbor acts as the data controller. This means we determine the purposes and means of processing personal data and are responsible for ensuring compliance with data protection laws.

For data processed as part of our client services, we typically act as a data processor on behalf of our financial institution clients, who remain the data controllers for their customer data.

Your Rights Under GDPR

The UK GDPR provides you with specific rights regarding your personal data. Below we explain each right and how to exercise it.

Right of Access (Article 15)

You have the right to obtain confirmation that your data is being processed and to access that data. You may request a copy of your personal data free of charge. We will respond to your request within one month, though this may be extended by two months for complex requests.

Right to Rectification (Article 16)

You have the right to request correction of inaccurate personal data and to have incomplete data completed. We will rectify your data without undue delay upon verification of the correct information.

Right to Erasure (Article 17)

Also known as the "right to be forgotten," you may request deletion of your personal data when:

  • The data is no longer necessary for the original purpose
  • You withdraw consent and there is no other legal basis
  • You object to processing and there are no overriding legitimate grounds
  • The data has been unlawfully processed
  • Erasure is required for legal compliance

Note: This right may be limited where we have legal or regulatory obligations to retain data.

Right to Restriction of Processing (Article 18)

You may request restriction of processing when:

  • You contest the accuracy of your data (during verification)
  • Processing is unlawful and you prefer restriction over erasure
  • We no longer need the data but you require it for legal claims
  • You have objected to processing (pending verification)

Right to Data Portability (Article 20)

Where processing is based on consent or contract and is automated, you may receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller.

Right to Object (Article 21)

You may object to processing based on legitimate interests or public interest at any time. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests. You have an absolute right to object to direct marketing processing.

Rights Related to Automated Decision-Making (Article 22)

You have the right not to be subject to decisions based solely on automated processing that produce legal effects or similarly significantly affect you, except where:

  • It is necessary for contract performance
  • It is authorised by law
  • It is based on your explicit consent

Lawful Bases for Processing

We process personal data under the following lawful bases:

  • Consent: For marketing communications and certain analytics
  • Contract: For service delivery and related communications
  • Legitimate Interests: For business enquiry management, security, and service improvement
  • Legal Obligation: For regulatory compliance and record-keeping requirements

Data Protection Impact Assessments

We conduct Data Protection Impact Assessments (DPIAs) for processing activities that are likely to result in high risk to individuals. This includes new systems, technologies, or processing operations that could significantly affect how we handle personal data.

International Data Transfers

When personal data is transferred outside the United Kingdom, we ensure appropriate safeguards are in place:

  • Transfers to countries with adequacy decisions
  • Standard Contractual Clauses approved by the ICO
  • Binding Corporate Rules where applicable

Data Breach Procedures

We maintain procedures for detecting, reporting, and investigating personal data breaches. Where a breach is likely to result in a risk to individuals' rights and freedoms, we will notify the Information Commissioner's Office within 72 hours. Where there is a high risk, we will also notify affected individuals without undue delay.

Exercising Your Rights

To exercise any of your GDPR rights, please contact our Data Protection Officer:

Data Protection Officer
Dapper-harbor
47 Moorgate
London EC2R 6BQ
Email: [email protected]

When making a request, please provide sufficient information to verify your identity and specify which right(s) you wish to exercise. We may request additional information to confirm your identity before processing your request.

Complaints

If you believe we have not handled your personal data appropriately, you have the right to lodge a complaint with the supervisory authority:

Information Commissioner's Office
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
Tel: 0303 123 1113
Website: ico.org.uk

We encourage you to contact us first so we can address your concerns directly.