Privacy Statement


Spear Technical Group Ltd is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client.

It is the intention of this privacy statement to explain to you the information practices of Spear Technical Group Ltd in relation to the information we collect about you.

For the purposes of the GDPR the data controller is:  Brian Comley

Contact details of data controller or by writing to

GDPR Compliance Officer,
Spear Technical Group Ltd,
Unit 7.
Colebrook Way
Hampshire, SP10 3BB

When we refer to ‘we’ it is Spear Technical Group Ltd trading as Spear Technical Group, Spear Electrical, Spear Design Projects and Spear Energy. We share information within this group to help us provide our services and comply with the regulatory requirements and improve our service standards.

Please read this Statement carefully as this sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Who are we?

Spear Technical Group Ltd trading as Spear Technical Group, Spear Electrical, Spear Design & Build and Spear Energy.

The company is incorporated the UK registration number 3768740 and is registered as a business in 1999.

The company has been trading since the 12th of May 1999. Initially as an electrical contractor and then providing specific service through Spear Energy and Spear Design Projects.

Our GDPR Compliance Owner can be contacted directly here:

  • Brian Comley

Why we are processing your data? Our legal basis.

To use your information lawfully, we rely on one or more of the following legal bases:

  • your consent;
  • performance of a contract;
  • legal obligation (e.g. “Minimum Competency Code”, “Fitness & Probity”, TCA 1997);
  • protecting the vital interests of you or others;
  • public interest; and
  • our legitimate interests or the legitimate interests of a third party (e.g. your employer).
  • Contractual basis – Spear Technical Group Ltd needs to process your data as this is necessary in relation to a contract of insurance to which the individual has entered into or because the individual has asked for something to be done so they can enter into a contract.
  • When you become a client of ours, we would like to make you aware of products and services which may be of interest to you, we will send you direct marketing based on our legitimate interest and you can always opt- out of receiving marketing information from us.


In any event, Spear Technical Group Ltd  are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

How will Spear Technical Group Ltd  use the personal data it collects about me?

Spear Technical Group Ltd  will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary.

Special Categories of personal data

If we collect any special categories of personal data (e.g. health, religious beliefs, racial, ethnic origin – financial information is not classified as special categories of personal data) we will ensure the below.

Subject to suitable and specific measures being taken to safeguard the fundamental rights and freedoms of data subjects, the processing of data concerning health shall be lawful where the processing is necessary and proportionate for the purposes of the following:

(a) a policy of insurance or life assurance,

(b) a policy of health insurance or health-related insurance,

(c) an occupational pension, a retirement annuity contract or any other pension arrangement, or

(d) the mortgaging of property

Data Subjects Rights:

Spear Technical Group Ltd facilitate you, our clients, rights in line with our data protection policy and the subject access request procedure. This is available on request.

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that Spear Technical Group Ltd refuses your request under rights of access, we will provide you with a reason as to why.

All of the above requests will be forwarded on should there be a third party involved as we have indicated in the processing of your personal data.

Additional information we are providing you with to ensure we are transparent and fair with our processing

Retention of your personal data

Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. Spear Technical Group Ltd will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body, the Central Bank of Ireland and our Internal Governance.

In the event that you wish to make a complaint about how your personal data is being processed by Spear Technical Group Ltd or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Spear Technical Group Ltd.’s data protection representatives Data Protection Officer / GDPR Owner

Tel: 0303 123 1113 

(local rate) or 01625 545 745

if you prefer to use a national rate number

Fax: 01625 524 510

If we are collecting your data for a contract and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect.

Profiling – automatic decision making

  • Automated Decision Making

We, in conjunction with lenders and life assurance companies use calculators and quotation tools to establish your affordability for credit and when providing quotations to you for associated insurance products.  Whilst some providers may carry out these processes on an automated basis, we operate with human intervention and take into account information you provided us in your application form for a mortgage or proposal form for an insurance product, your health history, your credit history, other credit facilities you have with financial institutions, amount of mortgage requested, amount of life assurance request, the repayment or cover period etc.  If you disagree with any of these decisions please contact us via the channels outlined in this document.

  • Risk Profiling

To establish a customer’s attitude to investment risk in relation to pensions, advisors may use automated calculators which calculate the customers’ attitude to various levels of risk having answered a series of questions.

  • Profiling for marketing purposes.

When we seek to contact you about other services, as outlined we run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs.

Additional Processing

If we intend to further process your personal data for a purpose other than for which the data was collected, we will provide this information prior to processing this data.

Contact Us

Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us.

Privacy policy statement changes

Spear Technical Group Ltd may change this privacy policy from time to time. When such a change is made, we will post a revised version online. Changes will be effective from the point at which they are posted. It is your responsibility to review this privacy policy periodically so you’re aware of any changes. By using our services you agree to this privacy policy.

This privacy policy was last reviewed in May 2018

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