We support and adhere to the Data Protection Principles, and as such when we process data we will ensure that it is:
- Processed lawfully, fairly and in a transparent way.
- Processed no further than for the legitimate purposes for which it was collected.
- Limited to what is necessary in relation to the purpose.
- Accurate and kept up to date.
- Kept in a form which permits identification of the data subject for no longer than is necessary.
- Processed in a manner that ensures security of that personal data.
- Processed by a controller who can demonstrate compliance with the principles.
Furthermore, the Company will:
- Observe fully the conditions regarding having a lawful basis to process personal information.
- Meet its legal obligations to specify the purposes for which information is used.
- Collect and process appropriate information only to the extent that it is necessary to fulfil operational needs or to comply with any legal or professional requirements.
- Ensure the information held is accurate and up to date.
- Ensure that the information is held for no longer than is necessary.
- Ensure that the rights of people about whom information is held can be fully exercised under the GDPR (i.e. the right to access personal information on request; to prevent processing in certain circumstances, and to correct, rectify, block or erase information that is regarded as wrong information)
- Take appropriate technical and organisational security measures to safeguard personal information.
- Ensure that personal information is not transferred outside the EU, to other countries or international organisations without an adequate level of protection.
PROCESSING INFORMATION ABOUT YOU
We will only administer personal information in accordance with the lawful bases for processing. At least one of the following will apply when we process data:
Consent – You have given clear consent for us to process your personal data for a specific purpose.
Contract – The processing is necessary for a contract we have with you, or because we have asked you to take specific steps before entering into a contract.
Legal obligation – The processing is necessary for us to comply with the law (not including contractual obligations).
Vital interests – The processing is necessary to protect someone’s life.
Public task – The processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
Legitimate interests – The processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests.
The personal data we collect about you
Personal data collected, used, stored and transferred by us include:
Identity Data – Your name, address and signature. Contact Data – Email and telephone numbers. Financial Data – Depending on the reason we are dealing with you this could include bank statements for use as identification, source of funds and mortgage information to confirm purchasing ability, income to confirm rental ability, financial history to confirm rental suitability. Transaction Data – Price offered or paid for property bought, sold, let rented or subject to a review of the rent, where such information about a transaction is provided to us or uncovered as part of our investigation of comparable evidence in accordance with our professional duties.
Details of current property if a purchase or rental is dependent on the ownership or sale of same. Technical Data – including internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform and other technology on the devices used to access the Saul Gerrard surveyors website Profile and Usage Data – including feedback and survey responses, and how you use our website, products and services Marketing and Communications Data – including your communication preferences, your preferences in receiving property alerts, market and property news from us and when requested third party businesses such as recommended solicitors or mortgage brokers.
How do we collect your personal data?
Personal data is collected by us using the following methods:
Direct interactions with a member of staff in person, by post, telephone, email or otherwise when selling, letting or sourcing property for sale or to let or applying for mortgage or protection products
Automated technologies or interactions with our website and property portals, by using a web enquiry form.
Third parties such as other surveyors; solicitors; accountants or other property professionals.
Publicly available sources processing Identity, Contact and Financial categories of personal data, and property information.
How do we use your personal data?
We use your personal data in the following circumstances and relying on the following lawful basis for processing: Purpose / Activity
Why we need this information
Property enquiry, seller or landlord enquiry or general enquiry – For us to deal with your enquiry.
Potential Buyers and/or Tenants – To deal with your property enquiry or search. To properly process and support an offer to purchase or rent and to progress any subsequent purchase or tenancy. For safety and security purposes before conducting any property viewing. To comply with regulatory and legislative requirements, including confirming ID.
Sellers and Landlords – For us to provide our desired level of service. To be able to introduce interested parties to you properly market your property and to process any subsequent sale or rental. To comply with regulatory and legislative requirements, including confirming ID and to contact you to stay up to date with current values.
Managed Tenants – For us to properly carry out our obligations as introducers to managing agents. To comply with regulatory and legislative requirements.
Freeholders and Lessees – For us to provide our desired level of service. To properly manage introductions to other professionals. To comply with regulatory and legislative requirements, to contact you to to stay up to date with current values
We may analyse the personal information we collect directly from you and obtain using automated technical means to create a profile of your interests and preferences so that we can contact you with information relevant to you (if you have chosen to receive marketing communications from us). We may make use of additional information about you when it is available from external sources to help us do this effectively. These sources include the publicly accessible Land Registry.
We may also use any of your personal information that we collect from you directly and additional information about you from external sources where necessary to detect and reduce fraud and credit risk. Our legal basis for this use of your personal information is our legitimate interests in preventing our business being subject to fraud or credit risk.
Change of purpose
We will only use your personal data for the purposes stated above, unless we reasonably consider that we need to use it for another reason and it is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Changes to our Privacy Notice
We keep our Privacy Notice under regular review and we will place any updates on our web page. This Privacy Notice was last updated on 26th April 2018. Historic versions can be obtained by contacting us.
We will endeavor to only contact you when we have reason to believe you would have a genuine interest I the service being offered or news upon which we are rerporting.
You can opt-out of receiving these types of communications at any time by amending the preferences on the relevant email communication or by contacting our Data Protection team at firstname.lastname@example.org copying in email@example.com or by writing to us.
Please note that your personal information will not be passed to any third-party for marketing purposes.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an un-authorised way, altered or disclosed. We also limit access to your personal data to only those members of staff, and contacts who have a business or legitimate need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Website Third-party links
The Saul Gerrard Surveyors website may in the future include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We will control those third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Sharing of personal data outside of the European Economic Area
We do not believe any personal data is held or shared with any organisations outside the EEA. We at some point employ external suppliers who maybe based outside the EEA so their processing of your personal data may involve a transfer of data outside the EEA. If and when we use providers based in the US, data may be transferred to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. We may also from time to time use specific contracts approved by the European Commission that provide the same level of protection for personal data as it has in the EEA.
Who we disclose personal data to
Your personal data may be shared with third parties for the following purposes:
A full list of the professional, contractors and suppliers we currently deal with are available on request. These companies are required to ensure appropriate security measures are in place and maintain the confidentiality of your personal data, and to use your personal data only in the course of providing such services and in accordance with contractual, legitimate or regulatory purposes .
How long is your personal data retained?
We only retain your personal data for as long as necessary for us to provide a service or as legally required. After these retention periods if there is no other on-going client relationship your personal data will either be deleted or anonymised so that it can be used for statistical purposes but without any method of identifying you individually.
You have the right to:
• Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. • Request correction of the personal data. This enables you to have any incomplete or inaccurate data corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete personal data where there is no good or legal reason for us continuing to process or store it. You can also ask us to delete your personal data where you have successfully objected to the processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to delete the data for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data.
This enables you to ask us to Purpose / Activity Who Data may be shared with:
Property enquiry, seller or landlord enquiry or general enquiry
CRM Software providers, Regulating authorities
Potential Buyers and/or Tenants
CRM Software providers, Financial Services provider, Solicitors, Surveyors, Referencing agencies, Landlords, Regulating authorities.
Sellers and Landlords
CRM Software providers, Financial Services provider, Solicitors ands, Surveyors, Debt Collection Agencies, Professional Services providers, Referencing agencies, Regulating authorities.
CRM Software providers, Referencing Agencies, Contractors, Suppliers, Utility providers, Local Authority, Debt collection agencies, Regulating authorities.
Freeholders and Lessees
CRM Software providers, Solicitors, Surveyors, Contractors, Suppliers, Utility providers, Regulating authorities.
Suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, format.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you have any questions or complaints relating to how we use your personal data, or if you wish to exercise any of your rights regarding your personal data, please contact the Data Protection Manager by emailing firstname.lastname@example.org copying in email@example.com or by writing to us. We will respond to you as soon as is possible.
The length of time will depend on the type and complexity of the request, but you will receive a response no later than one month from the initial request.
What if I am still not satisfied?
If you are not satisfied with how Saul Gerrard Surveyors has responded to your enquiry, you have the right to complain to the Information Commissioner’s Office (ICO), who is the regulator for data protection in the United Kingdom.