When you request information from the GFW Letting or use any of our services, GFW Letting obtains information about you. This statement explains how we look after that information and what we do with it.
We have a legal duty under the General Data Protection Regulations to prevent your information falling into the wrong hands. We must also ensure that the data we hold is accurate, adequate, relevant and not excessive.
Our use of your personal data is subject to your instructions, the EU General Data Protection Regulation (GDPR), other relevant UK and EU legislation and our professional duty of confidentiality.
It would be helpful to start by explaining some key terms used in this document:
|We, us, our||GFW Letting (part of the George F. White group)|
|Personal data||Any information relating to an identified or identifiable individual|
|Special category personal data||Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic and biometric data
Data concerning health, sexual orientation, etc
Personal data we collect about you
The table below sets out the personal data we will or may collect in the course of advising and/or acting for you.
|Personal data we will collect||Personal data we may collect depending on why you have instructed us|
|Your name, address, email address and telephone number(s)||Your National Insurance and tax details|
|Information relating to the matter in which you are seeking our advice or representation||Your bank and/or building society details|
|Information to enable us to undertake a credit or other financial checks on you||Details of your professional online presence, e.g. LinkedIn profile|
|Information to enable us to undertake a credit or other financial checks on you||Information to enable us to check and verify your identity, e.g. your date of birth or passport details|
|Information about your use of our IT, communication and other systems, and other monitoring information||Your financial details so far as relevant to your instructions|
|Information to enable us to undertake a credit or other financial checks on you|
This personal data is required from you to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
How your personal data is collected
We collect most of this information from you. However, we may also collect information:
- from publicly accessible sources, e.g. Companies House or HM Land Registry
- directly from a third party, e.g.
- credit reference agencies
- client due diligence providers
- from a third party with your consent, e.g.
- your bank or building society, another financial institution or advisor
- consultants and other professionals we may engage in relation to your matter
- property portals including Rightmove, OnTheMarket and UK Land and Farms
- social media including Facebook, Twitter, Instagram, Youtube and LinkedIn
- via our information technology systems, e.g.
- case management, document management and time recording systems
- www.gfwletting.co.uk website
- automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.
- to comply with our legal and regulatory obligations
- for the performance of our contract with you or to take steps at your request before entering into a contract
- for our legitimate interests or those of a third party, or
- you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal data for and our reasons for doing so:
|What we use your personal data for||Our reasons|
|To provide professional services to you||For the performance of our contract with you or to take steps at your request before entering into a contract|
|Conducting checks to identify our clients and verify their identity||To comply with our legal and regulatory obligations|
|Screening for financial and other sanctions or embargoes||To comply with our legal and regulatory obligations|
|Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator||To comply with our legal and regulatory obligations|
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests or those of a third party|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party
To comply with our legal and regulatory obligations
|Statistical analysis to help us manage our practice, e.g. in relation to our financial performance, client base, work type or other efficiency measures||For our legitimate interests or those of a third party|
|Preventing unauthorised access and modifications to systems||For our legitimate interests or those of a third partyTo comply with our legal and regulatory obligations|
|Updating and enhancing client records||For the performance of our contract with you or to take steps at your request before entering into a contractTo comply with our legal and regulatory obligationsFor our legitimate interests or those of a third party|
|Statutory returns||To comply with our legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party
|Marketing our services:
– existing and former clients;
– third parties who have previously expressed an interest in our services;
– third parties with whom we have had no previous dealings.
|For our legitimate interests or those of a third party|
|Credit reference checks via external credit reference agencies||For our legitimate interests or a those of a third party|
|External audits and quality checks, e.g. ISO, RICS and the audit of our accounts|| For our legitimate interests or a those of a third party
To comply with our legal and regulatory obligations
The above table does not apply to special category personal data, which we will only process with your explicit consent.
We may use your personal data to send you updates (by email, text message, telephone or post) about developments that might be of interest to you and/or information about our services, including exclusive offers, events, promotions or new services/products.
We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations outside George F. White for marketing purposes without your specific consent.
You have the right to opt out of receiving promotional communications at any time by:
- contacting us at firstname.lastname@example.org
- write to The Data Protection Officer, c/o The Communications Team, GFW Letting, 4-6 Market Street, Alnwick, Northumberland, NE66 1TL
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
- updating your marketing preferences – click here to update.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal data with
We routinely share personal data with:
- professional advisers who we instruct on your behalf
- other third parties where necessary to carry out your instructions e.g. Agricultural Mortgage Company
- credit reference agencies
- our insurers and brokers
- external auditors, e.g. in relation to ISO accreditation and the audit of our accounts
- our bank
- external service suppliers, representatives and agents that we use to make our business more efficient, e.g., marketing agencies, document collation or analysis suppliers – our current suppliers are:
- Dotmailer – email marketing software provider
- Dezrez – estate agency software provider
- Gemini –property management software provider
- Landmark Systems Ltd – accounting and property management software
- TSG – IT support provider
- Rightmove – property portal
- OnTheMarket – property portal
- UK Land and Farms – property portal
- Northern Print Solutions – print and mailing solutions
- Hootsuite – social media marketing software
- Google Analytics – digital marketing analysis software
- Cameo Digital – SEO consultants
- LPC Law Ltd – court advocacy services
- STA International – debt recovery and credit control agency
- Hadfield & Co Solicitors – civil money claims in debt recovery
- Van Mildert – tenant referencing services
- Tenant Shop – utility services
- Verismart – property management inventory services
- Contractors – during the nature of our property management services there will be a need on occasion to request that contractors attend a property to action urgent or periodic remedial works, at all times this will be with the consent of the client and also subject to reasonable prior notice with the tenant. The tenant will be provided with the details of the contractor prior at the time of arranging suitable access to the property.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structure. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal data with any additional third party without your prior and specific consent.
Where your personal data is held
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.
How long your personal data will be kept
We will keep your personal data after we have finished acting for you. We will do so for one of these reasons:
- to respond to any questions, complaints or claims made by you or on your behalf
- to show that we treated you fairly
- to keep records required by law
We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data.
When it is no longer necessary to retain your personal data, we will delete or anonymise it, where possible.
Transferring your personal data out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), e.g.
- with your and our service providers located outside the EEA
- if you are based outside the EEA
- where there is an international dimension to the matter in which we are advising you
These transfers are subject to special rules under European and UK data protection law.
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal data (the right of access)|
|Rectification||The right to require us to correct any mistakes in your personal data|
|To be forgotten||The right to require us to delete your personal data – in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal data – in certain circumstances, e.g. if you contest the accuracy of the data|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations|
|To object||The right to object:- at any time to your personal data being processed for direct marketing (including profiling)
– in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests
|Not to be subject to automated individual decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us – see below: ‘How to contact us’; and
- let us have enough information to identify you (e.g. your full name, address and client or matter reference number)
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill) and
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns.
This privacy notice was published on 24th May 2018 and last updated on 24th May 2018.
We may occasionally make changes and corrections to this policy. If we believe that these changes are significant, we will let you know by doing one (or more) of the following:
- posting the changes on our website
- sending you an email or message about the changes
We will also give you the opportunity to consent to these material changes. Changes will be effective upon the posting of the changes and your acceptance of the changes, which may be through your continued use of the site after the changes take effect.
How to contact us
Our contact details are shown below:
The Data Protection Officer, c/o The Communications Team, GFW Letting,
4-6 Market Street, Alnwick, Northumberland NE66 1TL
Telephone: 01665 603231
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