Privacy Policy

Last Updated: September 2026

Harrington Raine Ltd takes the protection of personal information seriously. This Privacy Notice explains how we collect, use, store and share personal information when you visit our website, contact us, use our services, work for or with one of our clients, apply to work with us, or otherwise interact with Harrington Raine.

This notice applies to personal information relating to:

  • website visitors;

  • prospective and existing clients and their representatives;

  • employees, workers, contractors and other individuals connected with our clients;

  • individuals involved in HR, Employment Law, Employment Tribunal or Health & Safety matters;

  • suppliers, professional contacts and referral partners;

  • job applicants; and

  • other individuals who communicate or interact with us.

It does not cover Harrington Raine employees, who will be provided with separate employee privacy information.

1. Who we are

Harrington Raine Ltd is a UK regulatory consultancy specialising in HR, Employment Law and Health & Safety services.

Harrington Raine Ltd
Company number: 17463089
Registered office: Office 20, Bank Farm Buildings, Chester Road, Aldford, Chester, United Kingdom, CH3 6HJ

For questions about this Privacy Notice or how we use personal information, please contact:

Email: info@harringtonraine.com

Harrington Raine Ltd is registered in England and Wales.

2. Our role under data protection law

For much of the personal information described in this notice, Harrington Raine acts as a data controller. This means we determine why and how the personal information is used.

Examples include information relating to:

  • website visitors;

  • prospective clients;

  • client contacts;

  • our marketing activities;

  • billing and administration;

  • recruitment;

  • our own legal and regulatory obligations; and

  • our business records.

When providing services to a client, we may also process personal information about the client’s employees, workers or other individuals.

Depending on the service and the circumstances, Harrington Raine may act as:

  • a data processor, processing personal information on the client’s documented instructions; or

  • a data controller, where Harrington Raine independently determines the purposes and means of particular processing or needs to process information for its own legal, regulatory or professional purposes.

Where Harrington Raine acts as a processor, the client will normally be the controller and its own privacy information should explain how it uses personal information.

Our agreements with clients will address the parties’ respective data protection responsibilities where appropriate.

3. Personal information we may collect

The information we collect depends on your relationship with us.

Identity and contact information

This may include:

  • name;

  • job title;

  • employer or business;

  • business and personal contact details where relevant;

  • telephone number;

  • email address; and

  • correspondence details.

Website and enquiry information

If you contact us through our website, we may collect:

  • your name;

  • company name;

  • email address;

  • telephone number;

  • employee headcount;

  • the nature of your enquiry; and

  • subsequent correspondence with you.

We may also collect technical information associated with use of our website, such as IP address, browser type, device information, pages visited and information collected through cookies or similar technologies.

Client and account information

Where you or your organisation becomes a client, we may hold information including:

  • contact details;

  • job roles and responsibilities;

  • contracts and engagement information;

  • correspondence;

  • instructions;

  • service history;

  • advice provided;

  • case or matter records;

  • meeting notes;

  • telephone notes or summaries;

  • invoices and payment information; and

  • records relating to the client relationship.

Employee and workplace information

Clients may provide us with personal information about their employees, workers, contractors, applicants, former employees or other individuals where this is necessary for us to provide HR, Employment Law, Employment Tribunal or related services.

This may include:

  • name and contact details;

  • job title and employment history;

  • employment contracts;

  • working arrangements;

  • salary, benefits and other remuneration information;

  • attendance and absence records;

  • performance information;

  • disciplinary records;

  • grievance information;

  • redundancy or restructuring information;

  • meeting notes and correspondence;

  • witness statements;

  • photographs, CCTV or audio material where relevant;

  • information relating to Employment Tribunal or other proceedings; and

  • other information relevant to an employment or workplace matter.

We ask clients to provide only the information reasonably necessary for the matter on which we are advising or assisting.

4. Special category and sensitive information

The work we undertake may require us to process more sensitive categories of personal information.

This may include information concerning:

  • physical or mental health;

  • disability;

  • racial or ethnic origin;

  • religious or philosophical beliefs;

  • political opinions where relevant;

  • trade union membership;

  • sex life or sexual orientation;

  • genetic or biometric information where relevant; and

  • other information treated as special category data under data protection law.

For example, sickness absence, reasonable-adjustment or capability matters may require us to review medical information supplied by a client or employee.

We may also process information relating to alleged or actual criminal offences where this is relevant to an employment, disciplinary, safeguarding, Health & Safety or legal matter.

We will only process this information where there is an appropriate lawful basis and, where required, an additional legal condition allowing the processing of special category or criminal offence information.

Depending on the circumstances, this may include processing necessary for:

  • employment and social protection law;

  • establishing, exercising or defending legal claims;

  • complying with legal obligations;

  • reasons of substantial public interest where applicable; or

  • another condition permitted by law.

Where we act solely as a processor on behalf of a client, the client is responsible for identifying the underlying lawful basis and any additional condition required for its processing.

5. Where we obtain personal information

We may obtain information:

  • directly from you;

  • from your employer or another client of Harrington Raine;

  • from employees, workers, witnesses or other people involved in a matter;

  • from professional advisers or representatives;

  • from Acas, Employment Tribunals, courts or other public authorities where relevant;

  • from insurers, brokers or other organisations involved in a matter;

  • through referrals or professional contacts;

  • from business databases or lead-generation providers;

  • from publicly available sources such as company websites, Companies House, professional directories and LinkedIn;

  • from advertising and marketing platforms; and

  • from suppliers and service providers used to support our operations.

Where we obtain personal information from another source rather than directly from you, we will handle it in accordance with applicable data protection law.

6. How and why we use personal information

We use personal information only where we have a lawful reason to do so.

Responding to enquiries

We use enquiry and contact information to:

  • respond to questions;

  • understand what support may be required;

  • prepare proposals or quotations;

  • arrange conversations or meetings; and

  • take steps towards entering into a client relationship.

Depending on the circumstances, we rely on steps taken before entering into a contract and/or our legitimate interests in responding to prospective clients and developing our business.

Providing our services

We use personal information to:

  • provide HR, Employment Law and Health & Safety advice and support;

  • understand workplace issues;

  • prepare correspondence, documents, policies and other materials;

  • assist with disciplinary, grievance, capability, absence, redundancy and other employee-relations matters;

  • provide HR Consultancy & Meeting Support;

  • manage Employment Tribunal matters;

  • provide Health & Safety support;

  • communicate with relevant individuals and organisations;

  • maintain records of work undertaken; and

  • manage the client relationship.

Depending on the individual concerned and the service being provided, we may rely on:

  • performance of a contract or steps taken before a contract;

  • legitimate interests;

  • compliance with legal obligations; and

  • where relevant, the establishment, exercise or defence of legal claims.

Where special category or criminal offence information is involved, an additional legal condition will also be identified where required.

Administration and billing

We use information to:

  • administer client accounts;

  • issue and process invoices;

  • collect payments;

  • maintain accounting and tax records;

  • manage contracts; and

  • deal with queries relating to our services.

We may rely on contractual necessity, legal obligations and our legitimate interests in operating and administering our business.

Security, fraud prevention and legal compliance

We may use information where necessary to:

  • protect our systems and information;

  • prevent fraud or misuse;

  • investigate security incidents;

  • establish, exercise or defend legal claims;

  • comply with legal and regulatory obligations; and

  • respond to lawful requests from regulators, courts, law enforcement bodies or other authorities.

Improving our services

We may use information to:

  • monitor service quality;

  • improve our procedures;

  • train and supervise our team;

  • maintain accurate records;

  • understand how clients use our services; and

  • improve our website and communications.

Where personal information is involved, this will normally be based on our legitimate interests, provided those interests are not overridden by the rights and interests of the individuals concerned.

7. Telephone calls, transcription and summaries

We may use technology to help create accurate written records or summaries of telephone or online conversations.

Where such technology is used, audio may be processed temporarily by an automated transcription or summarisation service in order to produce a written transcript, note or summary.

Unless we specifically tell you otherwise, Harrington Raine does not intend to retain an audio recording of the call.

The resulting written note, transcript or summary may be retained as part of the relevant enquiry, client or matter record.

We may use these tools for purposes including:

  • accurate record keeping;

  • reducing manual note-taking;

  • improving follow-up;

  • maintaining continuity between advisers; and

  • improving service quality.

Where appropriate, we will provide additional information about the use of transcription or recording technology at the time it is used.

We do not use automated call summaries to make decisions about individuals without appropriate human involvement.

8. Artificial intelligence and automated tools

Harrington Raine may use artificial intelligence and other technology-assisted tools to support its work.

These tools may be used for activities such as:

  • summarising information;

  • producing call or meeting notes;

  • assisting with document preparation;

  • organising information;

  • reviewing documents;

  • supporting research; and

  • improving administrative efficiency.

The use of an AI tool does not remove human responsibility for our work. Professional decisions, recommendations and client advice remain subject to appropriate human review.

Where personal information is processed using an AI or technology provider, we will apply appropriate confidentiality, security and contractual controls.

We do not use solely automated decision-making that produces legal or similarly significant effects on individuals.

9. Website analytics, cookies and similar technologies

Our website may use cookies, scripts, pixels and similar technologies to:

  • make the website function properly;

  • protect website security;

  • remember user preferences;

  • understand how the website is used;

  • measure website performance;

  • measure the effectiveness of advertising;

  • understand whether an enquiry resulted from an advertising campaign; and

  • support relevant advertising and marketing activities.

Depending on how the website is configured, these services may include technologies provided by organisations such as:

  • Google;

  • Microsoft;

  • Meta; and

  • LinkedIn.

Some technologies are essential to the operation or security of the website and do not require consent.

Certain limited statistical analytics may also be used without prior consent where permitted by law and configured to satisfy the relevant exemption requirements.

We will obtain consent before using non-essential technologies where consent is required, including technologies used for behavioural advertising, profiling, advertising conversion tracking or similar non-exempt purposes.

Where available, visitors will also be given appropriate controls to object to or manage non-essential analytics and tracking.

Further details about individual technologies, providers and retention periods may be provided in our Cookie Notice or website privacy controls.

10. Website pricing calculator

Our website may include calculators that allow businesses to obtain indicative service pricing based on information such as employee headcount and selected service options.

The pricing calculator does not require you to provide your name, company name, email address or telephone number.

Technical information may be processed temporarily for security and abuse-prevention purposes. This may include a short-lived pseudonymous or hashed identifier derived from technical information such as an IP address and browser information.

These controls are used to protect the calculator from excessive or automated requests and are not intended to create a permanent visitor-tracking record.

11. Direct marketing

We may use contact information to tell prospective and existing business clients about:

  • Harrington Raine services;

  • relevant additional services;

  • events or webinars;

  • employer updates;

  • guides and resources;

  • regulatory or legal developments; and

  • other information we reasonably believe may be relevant to their business.

Marketing may take place by email, telephone, social media or other appropriate channels.

We may rely on consent where consent is legally required.

Where the law permits, particularly in a business-to-business context, we may instead rely on our legitimate interests in promoting our services to relevant businesses and business contacts.

We will respect applicable rules concerning sole traders and other recipients who receive additional protections under electronic marketing law.

You can ask us to stop using your personal information for direct marketing at any time.

We may retain a limited suppression record after an opt-out so that we can ensure we do not accidentally contact you again for marketing purposes.

12. Advertising audiences and social media

Where permitted by law and subject to any necessary consent, we may use advertising services provided by platforms such as Google, LinkedIn or Meta.

This may involve:

  • measuring advertising performance;

  • recording advertising conversions;

  • creating business audiences;

  • matching contact information against platform users;

  • displaying advertisements to relevant audiences; or

  • creating similar or lookalike audiences.

We will only use these services where an appropriate lawful basis exists and any required cookie, tracking or marketing consent has been obtained.

13. Employment Tribunal and legal matters

Where we assist with Employment Tribunal or other legal matters, information may be shared where necessary with organisations or individuals such as:

  • Acas;

  • Employment Tribunals and HM Courts & Tribunals Service;

  • claimants or respondents;

  • legal representatives;

  • barristers, advocates or other representatives;

  • witnesses;

  • experts;

  • insurers;

  • professional advisers; and

  • other persons involved in the proceedings.

Information will only be shared where reasonably necessary for the matter, permitted by law or required by a court, Tribunal or other competent authority.

14. Health & Safety matters

Where relevant to Health & Safety work, information may be shared with:

  • the Health and Safety Executive;

  • local authorities;

  • insurers;

  • external Health & Safety specialists;

  • legal or professional advisers;

  • accident investigators;

  • experts; and

  • other competent authorities.

We will only share information where necessary for the service, required by law or otherwise permitted under applicable data protection law.

15. Insurance and protection arrangements

Where requested by a client and relevant to the service being provided, we may share information with an insurer, broker, underwriting partner or other insurance-related organisation in order to obtain, arrange or administer insurance or protection.

This is not a routine disclosure of client information.

The information shared will be limited to what is reasonably required for the proposed insurance or protection arrangement.

16. Who we share personal information with

We may use third parties to support our business and services.

Depending on the circumstances, these may include:

  • website and hosting providers, including Hostinger;

  • Microsoft and other email, communication, cloud or business software providers;

  • CRM providers;

  • telephone and communications providers;

  • accounting providers, including Xero;

  • payment providers, including Stripe;

  • IT and cybersecurity providers;

  • analytics, advertising and marketing providers;

  • document management and electronic-signature providers;

  • AI, transcription and productivity technology providers;

  • accountants and auditors;

  • insurers and brokers;

  • professional advisers;

  • barristers, advocates and other specialist consultants;

  • regulators and public authorities;

  • courts and Tribunals;

  • law enforcement bodies where required; and

  • prospective purchasers, investors or advisers in connection with a legitimate corporate transaction.

Where a supplier processes personal information on our behalf, we require appropriate contractual and security protections.

We do not sell personal information to third parties.

17. International transfers

We aim to use UK-based hosting and processing arrangements where reasonably practicable.

However, some of the technology and service providers we use may process or make personal information accessible outside the United Kingdom.

Where personal information is transferred internationally, we will take steps required by applicable data protection law. Depending on the destination and provider, this may include reliance on:

  • UK adequacy regulations;

  • approved contractual safeguards;

  • the UK International Data Transfer Agreement;

  • the UK Addendum to approved contractual clauses; or

  • another lawful transfer mechanism.

We may also carry out appropriate transfer-risk assessments where required.

18. How long we keep personal information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including legal, regulatory, accounting and dispute-resolution requirements.

Our general retention approach is currently:

Prospective client enquiries
Normally up to 24 months from the last meaningful interaction, unless a longer period is justified.

Client and service records
Normally for six years after the client relationship or relevant matter ends. Information may be retained for longer where necessary because of an ongoing dispute, legal claim, regulatory requirement or another justified reason.

Employee and case information received from clients
Where we act as a processor, retention will be governed by the client’s instructions and the applicable client agreement. Where Harrington Raine acts as a controller, information will normally be retained in line with the relevant client or matter file.

Employment Tribunal and dispute files
Normally for six years after conclusion of the matter, subject to any reason requiring longer retention.

Financial, accounting and payment records
Normally for at least six years where required for accounting, tax or legal purposes.

Call notes, transcripts and summaries
Normally retained as part of the enquiry, client or matter record to which they relate.

Marketing information
Until you opt out, the information is no longer required or we determine that continued use is no longer appropriate. A minimal suppression record may be retained for longer so that an opt-out can continue to be honoured.

Unsuccessful job applications
Normally for 12 months after completion of the relevant recruitment process.

Website and analytics information
For the period appropriate to the relevant technology and purpose. More specific periods may be set out in our Cookie Notice.

We periodically review information we hold and delete or anonymise information when there is no longer a legitimate reason to retain it.

19. Security

We use appropriate technical and organisational measures designed to protect personal information against:

  • unauthorised access;

  • loss;

  • disclosure;

  • alteration;

  • misuse; and

  • destruction.

Access to personal information is limited to people who reasonably require it for their role or for the provision of our services.

Our security arrangements are reviewed and developed as our business, systems and services change.

No internet or electronic storage system can be guaranteed to be completely secure. We therefore continually assess the measures appropriate to the information we process and the risks involved.

20. Your data protection rights

Depending on the circumstances, you may have rights including the right to:

  • request access to personal information we hold about you;

  • ask us to correct inaccurate or incomplete information;

  • ask us to erase your personal information;

  • ask us to restrict the way we use your information;

  • object to certain processing;

  • receive certain information in a portable format;

  • withdraw consent where processing is based on consent; and

  • object at any time to the use of your personal information for direct marketing.

These rights are not absolute and may not apply in every circumstance.

Where Harrington Raine holds information only as a processor on behalf of one of our clients, we may need to refer your request to that client as the relevant controller.

To exercise a data protection right, contact:

info@harringtonraine.com

We may need to verify your identity before responding.

21. Complaints

If you have concerns about how Harrington Raine uses your personal information, please contact us first so that we can investigate the issue.

You also have the right to complain to the UK data protection regulator:

Information Commissioner’s Office (ICO)

Further information about making a complaint is available from the ICO at www.ico.org.uk.

22. Children

Our website and services are intended for businesses and employers and are not directed at children.

We do not intentionally collect personal information directly from children through our website for marketing or commercial purposes.

Information relating to a person under 18 may occasionally form part of a client matter where this is relevant to the services being provided. Where this occurs, it will be handled in accordance with applicable data protection requirements.

23. Changes to this Privacy Notice

We may update this Privacy Notice where our services, systems, suppliers, legal obligations or data-processing activities change.

The latest version will be published on our website and the date at the top of this notice will be updated when material changes are made.

24. Contact us

If you have questions about this Privacy Notice, want to exercise a data protection right or have a concern about how we use personal information, please contact:

Harrington Raine Ltd
Office 20
Bank Farm Buildings
Chester Road
Aldford
Chester
United Kingdom
CH3 6HJ

Email: info@harringtonraine.com

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