Last updated: 1 January 2026
1. Data Controller
HLB International Limited (Company No. 02181222), registered at 3 Brook Business Centre, Cowley Mill Road, Uxbridge, Middlesex, UB8 2FX, United Kingdom, is the data controller for personal data processed through the Global Independence System ("GIS").
2. Personal Data We Collect
We collect and process the following categories of personal data:
- Account information — name, work email address, firm affiliation
- Authentication data — hashed passwords, multi-factor authentication enrolment
- Usage data — login timestamps, pages visited, actions performed within GIS
- Entity data — client and entity names, identifiers, and classification data entered by authorised users
- Diagnostic data — error messages, stack traces, the page or action in progress when an error occurred, and, where an error triggers a session replay, a masked recording of the affected session (see section 9)
- Technical data — IP address, browser type, device information
3. Legal Basis for Processing
We process personal data under the following lawful bases (UK GDPR Article 6):
- Legitimate interests — operating the GIS platform, maintaining audit trails, ensuring regulatory compliance across the HLB network, and maintaining the security, availability and integrity of the platform (including error monitoring and diagnostics)
- Legal obligation — complying with professional independence and conflict-of-interest requirements
4. How We Use Your Data
- Authenticating and authorising access to GIS
- Performing conflict-of-interest and independence checks
- Maintaining audit logs for regulatory compliance
- Generating reports for firm administrators and compliance officers
- Improving platform performance and reliability
5. Data Sharing
Personal data is shared only within the HLB network on a need-to-know basis for conflict-checking purposes. We do not sell personal data to third parties. Data may be shared with:
- Other HLB member firms — limited to data necessary for conflict checks
- Infrastructure providers — for hosting and security (subject to appropriate safeguards)
- Functional Software, Inc. trading as Sentry — our error monitoring and diagnostics processor (see section 9)
- Regulators or law enforcement — where required by law
6. International Transfers
As HLB is a global network, data may be transferred outside the UK. Where this occurs, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner's Office. Diagnostic data processed by Sentry is sent to its European Union region (Germany).
7. Data Retention
Personal data is retained for the duration of your account and for a period of 7 years after account closure, in line with professional regulatory requirements. Audit logs are retained for a minimum of 7 years. For full details, see our Data Retention Policy.
8. Your Rights
Under the UK GDPR, you have the right to:
- Access the personal data we hold about you
- Rectify inaccurate data
- Request erasure (subject to legal retention obligations)
- Restrict or object to processing
- Data portability
- Withdraw consent at any time (where processing is based on consent)
- Lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk
HLB International Limited is registered with the Information Commissioner's Office under registration reference Z1203365.
9. Cookies, Local Storage and Error Monitoring
9.1 Cookies and local storage
GIS uses strictly necessary cookies for authentication and session management. We also use your browser's local and session storage to hold your language preference, your acknowledgement of the cookie notice, and — where an error occurs — a temporary identifier used by our error monitoring service. We do not use advertising or marketing cookies, and we do not use product analytics or cross-site tracking technologies.
9.2 Error monitoring and diagnostics (Sentry)
We use Sentry as a processor to monitor errors and diagnose faults in GIS. Sentry is initialised whenever GIS loads, so that faults occurring before or outside any preference selection are still captured. Data is sent to Sentry's European Union region (Germany).
Sentry receives:
- Error events — the error message and stack trace, together with technical data such as browser type, device information and IP address
- Diagnostic breadcrumbs — a short trail of preceding activity, including error responses returned by our backend database, remote procedure and authentication endpoints
- Performance traces — sampled at 10% of page loads and navigations, used to identify slow or failing operations
- Session replay — a reconstruction of the affected session. Replay is disabled for ordinary sessions and is captured only when an error occurs. All text is masked, all form inputs are masked, and all media is blocked, so the content you view or type is not transmitted to Sentry
The lawful basis for this processing is our legitimate interests in maintaining the security, availability and integrity of the platform. You have the right to object to processing carried out on this basis — see section 8.
You can review this notice again at any time via your profile settings, in accordance with the Privacy and Electronic Communications Regulations 2003 (PECR).
10. Security
We implement appropriate technical and organisational measures to protect personal data, including encryption in transit and at rest, multi-factor authentication, role-based access controls, and regular security assessments.
11. Data protection enquiries
For data protection enquiries, please contact:
Abu Bakkar
HLB International Limited
123 Buckingham Palace Road
London SW1W 9SH
United Kingdom