Your personal informationHow we store, protect and use the information you give us
This policy explains how we’ll collect information about you and then use it to give you a good service. It also goes into the security measures we take to protect your privacy, and expands on a few things that we won’t do.1: Who we are
Richard Saunders and Company and Saunders Lettings Limited are both data controllers in respect of personal information that we process in connection with our business (including the products and services that we provide). In this policy, references to “we”, “us” or “our” are references to Richard Saunders and Company and Saunders Lettings Limited.
Our principal address is 2 High Street Banstead Surrey SM7 2LJ and our contact details can be located at www.richadsaunders.co.uk/call-me-back
We collect and process various categories of personal information at the start of, and for the duration of, your relationship with us. We will limit the collection and processing of information to information necessary to achieve one or more legitimate purposes as identified in this policy. Personal information may include:
- Information that you provide to us such as your name, address, date of birth, telephone number, email address, bank account and payment card details and any feedback you give to us, including by phone, email, post, or when you communicate with us via social media;
- Information about the services that we provide to you (including for example, the things we have provided to you, when and where, what you paid, the way you use our products and services, and so on);
- Information required to make decisions about your application for products and services offered by us (for example, granting of a tenancy or confirming your position when buying a property) such as your employment details, financial position, information taken from identification documents such as your passport or driving licence, your insurance, criminal and medical history;
- information about your family, lifestyle and social circumstances (such as dependents, marital status, next of kin and contact details);
- Your account login details for our services, including your user name and chosen password;
- visual images and personal appearance (such as copies of passports or CCTV images); and
- Information about whether or not you want to receive marketing communications from us;
- Information about any device you have used to access our Services (such as your device’s make and model, browser or IP address) and also how you use our Services. For example, we try to identify which of our apps you use and when and how you use them. If you use our websites, we try to identify when and how you use those websites too;
- Your contact details and details of the emails and other electronic communications you receive from us, including whether that communication has been opened and if you have clicked on any links within that communication. We want to make sure that our communications are useful for you, so if you don’t open them or don’t click on any links in them, we know we need to improve our Services; and
- Information from other sources such as specialist companies that provide customer information (like credit reference agencies such as Experian, fraud prevention agencies, claims databases, marketing and research companies), social media providers and the DVLA, as well as information that is publicly available.
We will only process special categories of information where we’ve obtained your explicit consent or are otherwise lawfully permitted to do so (and then only for the particular purposes and activities set out below in ‘How We Use Your Information’). This may include:
- information about racial or ethnic origin,
- religious or philosophical beliefs;
- trade union membership;
- physical or psychological health details or medical conditions; and
- biometric information, relating to the physical, physiological or behavioural characteristics of a person, including, for example, using voice recognition or similar technologies to help us prevent fraud and money laundering.
Where permitted by law, we may process information about criminal convictions or offences and alleged offences for specific and limited activities and purposes, such as to perform checks to prevent and detect crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions. It may involve investigating and gathering intelligence on suspected financial crimes, fraud and threats and sharing data between banks and with law enforcement and regulatory bodies.3: How we obtain information
Your information is made up of all the financial and personal information we collect and hold about you/your business and the proprietors, officers and beneficial owners of that business and your transactions. It includes:
4: Your rights
- information you give to us;
- information that we receive from third parties – including other third parties who provide services to you or us, credit reference, fraud prevention or government agencies, and other estate agents (where permitted by law);
- information that we learn about you through our relationship with you and the way you operate your accounts and/or services, such as the payments made to and from your accounts;
- information that we gather from the technology which you use to access our services (for example location data from your mobile phone, or an IP address or telephone number) and how you use it (for example pattern recognition); and
- information that we gather from publicly available sources, such as the press, land registry, the electoral register, company registers and online search engines.
We want to make sure you are aware of your rights in relation to the personal information we process about you. You have the right to request:
- Access– You have a right to get access to the personal information we hold about you. In most cases this will be free of charge.
- Correction– You have a right to the correction of inaccurate personal information and to update incomplete personal information.
- Marketing– You have a right to object to direct marketing. You have a right to object at any time to processing of your personal information for direct marketing purposes, including profiling you for the purposes of direct marketing.
- Withdraw consent– You have a right to withdraw your consent. Where we rely on your permission to process your personal information, you have a right to withdraw your consent at any time. We will always make it clear where we need your permission to undertake specific processing activities.
- Lodge complaints– You have a right to lodge a complaint with the regulator. If you wish to raise a complaint on how we have handled your personal information, you can contact our Data Protection Officer who will investigate the matter in the first instance.
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to request a copy of any information about you that we hold at any time, and also to have that information corrected if it is inaccurate.
To ask for your information, please write to us at,Data Protection Officer at Richard Saunders and Company 2, High Street, Banstead Surrey SM7 2LJ. To ask for your information to be amended, please update your online account, or contact our team email@example.com
We hope that we can address any concerns you may have, but you can always contact the Information Commissioner’s Office (ICO). For more information, visitico.org.uk or write to:
Information Commissioner’s Office
Helpline telephone number 0303 123 1113
Please note that in some cases, if you do not agree to the way we process your information, it may not be possible for us to continue to operate your account and/or provide certain products and services to you.5: Changes to the way we use your information
From time to time we may change the way we use your information. Where we believe you may not reasonably expect such a change we will notify you and will allow a period of at least 30 days for you to raise any objections before the change is made. However, please note that in some cases, if you do not agree to such changes it may not be possible for us to continue to operate your account and/or provide certain products and services to you.6: How we use your information
We will only use and share your information where it is necessary for us to lawfully carry out our business activities. We want to ensure that you fully understand how your information may be used. We have described the purposes for which your information may be used in detail below.Contractual necessity
- We may process your information where it is necessary to enter into a contract with you for the provision of our products or services or to perform our obligations under that contract. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide products and services to you. This may include processing to:
- assess and process applications for products, services or property transactions;
- provide and administer those products and services throughout your relationship with us.
- manage and maintain our relationships with you and for ongoing customer service; and
- communicate with you about your account(s) or the products and services you receive from us, such as confirming upcoming appointments.
- When you apply for a product or service (and throughout your relationship with us), we are required by law to collect and process certain personal information about you. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide products and services to you. This may include processing to:
- confirming your identity;
- perform checks and monitor transactions and location data for the purpose of preventing and detecting crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions. This may require us to process information about criminal convictions and offences, to investigate and gather intelligence on suspected financial crimes, fraud and threats and to share data with law enforcement and regulatory bodies;
- assess affordability and suitability towards property transactions and throughout the duration of the relationship, including analysing customer data for regulatory reporting;
- share data with police, law enforcement, tax authorities or other government and fraud prevention agencies where we have a legal obligation, including reporting suspicious activity and complying with production and court orders;
- deliver mandatory communications to customers or communicating updates to product and service terms and conditions;
- investigate and resolve complaints;
- conduct investigations into breaches of conduct and corporate policies by our employees;
- manage contentious regulatory matters, investigations and litigation;
- perform assessments and analyse customer data for the purposes of managing, improving and fixing data quality;
- provide assurance that we have effective processes to identify, manage, monitor and report the risks it is or might be exposed to;
- investigate and report on incidents or emergencies on our properties and premises;
- coordinate responses to business-disrupting incidents and to ensure facilities, systems and people are available to continue providing services;
- We may process your information where it is in our legitimate interests do so as an organisation and without prejudicing your interests or fundamental rights and freedoms.
We may process your information in the day-to-day running of our business, to manage our business and financial affairs and to protect our customers, employees and property. It is in our interests to ensure that our processes and systems operate effectively and that we can continue operating as a business. This may include processing your information to:
7: Sharing with third parties
- monitor, maintain and improve internal business processes, information and data, technology and communications solutions and services;
- ensure business continuity and disaster recovery and responding to information technology and business incidents and emergencies;
- ensure network and information security, including monitoring authorised users’ access to our information technology for the purpose of preventing cyber-attacks, unauthorised use of our telecommunications systems and websites, prevention or detection of crime and protection of your personal data;
- provide assurance on our material risks and reporting to internal management and supervisory authorities on whether we are managing them effectively;
- perform general, financial and regulatory accounting and reporting;
- protect our legal rights and interests;
- manage and monitor our properties and branches (for example through CCTV) for the purpose of crime prevention and prosecution of offenders, for identifying accidents and incidents and emergency situations and for internal training; and
- enable a sale, reorganisation, transfer or other transaction relating to our business.
We will not share your information with anyone outside Richard Saunders and Company or Saunders Lettings Limited except:
- where we have your permission;
- where required for your product or service;
- where we are required by law and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies around the world;
- with third parties providing services to us, such as property maintenance contractors, our customer service centres and sub-contractors acting on our behalf, such as the companies which puts up our ‘for sale’ and ‘to let’ boards;
- with other estate agents, financial advisers, solicitors and surveyors to facilitate a property transaction where you are a connected party to that transaction;
- with debt collection agencies;
- with utility companies, local authorities and any companies employed by us to facilitate the changeover of services;
- with credit reference, tenant referencing and fraud prevention agencies;
- with third-party guarantors or other companies that provide you with benefits or services (such as our professional photographers so they can book an appointment to take property photographs) associated with your product or service;
- where required for a proposed sale, reorganisation, transfer, financial arrangement, asset disposal or other transaction relating to our business and/or assets held by our business;
- in anonymised form as part of statistics or other aggregated data shared with third parties; or where permitted by law, it is necessary for our legitimate interests or those of a third party, and it is not inconsistent with the purposes listed above.
- Software and system providers including but not limited to: Brief Your Market, Jupix, Hands On Computers, Rightmove, Zoopla, OnTheMarket
- Website Hosts and analytics platform providers including but not limited to: Brief Your Market, Webdadi, Hands On Computers
If you ask us to, we will share information with any third party that provides you with services that we may need to contact during our relationship. If you ask a third-party provider to provide you with account information or payment services, you’re allowing that third party to access information relating to your account. We’re not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you.
In the event that any additional authorised users are added to your account, we may share information about the use of the account by any authorised user with all other authorised users.
In the event that you link your assets and liabilities with another person, the sum of the combined assets and liabilities held may be shared with the other. In some instances, this may allow other party to calculate the combined assets and liabilities you hold with us.
Richard Saunders and Company and Saunders Lettings Limited will not share your information with third parties for their own marketing purposes without your permission.8: Transferring information overseas
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as India or the USA.
If you are based outside the UK and contact us for a product or service, we will transfer the personal data that we collect from you to the UK.
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts, please contact our Data Protection Officer on01737 363333 or email firstname.lastname@example.org
Unless you have told us that you do not want to hear from us, we will send you relevant marketing information (including details of other products or services provided by us which we believe may be of interest to you), by mail, phone, email, text and other forms of electronic communication. If you change your mind about how you would like us to contact you or you no longer wish to receive this information, you can tell us at any time by calling us on 01737 363333 or by visiting your local branch or email email@example.com
.10: Communications about your account
We will contact you with information relevant to the operation and maintenance of your account (including updated information about how we process your personal information), by a variety of means including via your online account, email, text message, post and/or telephone. If at any point in the future you change your contact details you should tell us promptly about those changes.
We may monitor or record calls, emails, text messages or other communications in accordance with applicable laws for the purposes outlined in ‘How we use your information’.11: How long we keep your information
By providing you with products or services, we create records that contain your information, such as customer account records, activity records, tax records and lending and credit account records. Records can be held on a variety of media (physical or electronic) and formats.
We manage our records to help us to serve our customers well (for example for operational reasons, such as dealing with any queries relating to your account) and to comply with legal and regulatory requirements. Records help us demonstrate that we are meeting our responsibilities and to keep as evidence of our business activities.
Retention periods for records are determined based on the type of record, the nature of the activity, product or service, and the applicable local legal or regulatory requirements. We normally keep customer account records for up to six years after your relationship with us ends, whilst other records are retained for shorter periods, for example 90 days for CCTV records or 12 months for call recordings. Retention periods may be changed from time to time based on business or legal and regulatory requirements.
We may on exception retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators. This is intended to make sure that we will be able to produce records as evidence, if they’re needed.
If you would like more information about how long we keep your information, please contact us on 01737 363333or by email firstname.lastname@example.org: Security
We are committed to ensuring that your information is secure with us and with the third parties who act on our behalf. For more information about the steps we are taking to protect your information please contact us on 01737 363333 or by email email@example.comEND