ANDERSON ROSE PRIVACY NOTICE, MAY 2018
Anderson Rose is totally committed to ensuring that your privacy is protected and our use of your personal information is governed by this Privacy Notice. We do not sell or otherwise disclose personal information we collect about you, except as described in this Privacy Notice or as indicated via the consent process at the time the data is collected.
Anderson Rose is a data controller for the personal information that it collects and uses about you. We will treat your personal information as confidential and in accordance with applicable data protection legislation and your personal information will only be shared with others in accordance with this Privacy Notice.
This Privacy Notice clarifies the following;
If there are any changes to the way in which your personal information is used, this Privacy Notice will be updated.
If you do not want us to process your personal information as described in this Privacy Notice, please do not provide information to Anderson Rose or use our website www.andersonrose.co.uk.
1. WHAT IS PERSONAL INFORMATION?
Personal information is any information that tells us something about you. This could include information such as name, contact details, date of birth, bank account details or any information about your needs or circumstances which would allow us to identify you.
Some personal information is classified as special data under data protection legislation. This includes information relating to health, racial or ethnic origin, religious beliefs or political opinions and sexual orientation. This information is more sensitive and we need to have further justifications for collecting, storing and using this type of personal information. There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data.
Any references to personal information in this privacy notice will include personal data, and where relevant, special categories of personal data.
2. HOW DO WE COLLECT PERSONAL INFORMATION ABOUT YOU?
We obtain personal information about you that you provide to us through our website, emails, phone conversations, documents you provide to us or when you visit our office, for example when you:
We also obtain personal information relating to you using automated technical means when you visit our website.
3. WHAT PERSONAL INFORMATION DO WE COLLECT?
We will collect your full name and contact details (such as phone number, email address and postal address) from you whenever you engage with us.
In addition, if we are providing a service to you, or on your behalf, where we are required to do so by law, we will collect information relating to your identity, which will be at least one form of photographic identification (such as a passport, a driving licence or an identification card) and one form of documentation with proof of your place of residence (such as a recent utility bill).
We will also confirm whether you have any relatives or close connections working at Anderson Rose so that we can consider potential conflict of interests and if identified how to manage these, in accordance with our statutory and regulatory obligations.
Depending on the service that we provide to you (or on your behalf) we may also collect additional personal information as detailed below;
Buying, Selling, Lettings & Renting
If you are selling or letting a property through us;
If you wish to rent a property we are listing;
If you wish to purchase a property we are listing;
Where you have specifically provided us with these, we will collect personal information relating to any specific access requirements you may have in relation to a property so that we can find a property that is suitable for your needs. We will also collect personal information required to source a property for you and, where required, negotiate the purchase of a property on your behalf.
Where we engage with you to manage property on your behalf we will ask for additional emergency contact information in case we need to get in touch with you outside of working hours or in the event there is a matter requiring your urgent attention.
The information we collect through our website using automated technical means includes: the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, identification number, online identifier and location data. We also collect information about your website visit including which website pages are accessed, page response times and length of visits to pages.
If you subscribe to receive research, news or other market updates from us, then in addition to the above we will collect details about the sector in which you work and the type of content that you would like to receive.
4. HOW WE USE AND SHARE YOUR PERSONAL INFORMATION?
For specific information on how your personal information will be used for the services you have requested from us, please select from any of the options below;
Buying, Selling, Letting, Renting
We may pass your personal data to SPF Private Clients Limited, an independent company with which Anderson Rose has a preferred supplier relationship, on a referral basis in relation to the arrangement of financing to allow you to acquire a property and/or the provision of the following services:
Other uses of your personal information:-
What happens if you do not provide information that we request?
We need some of your personal information to perform the services you have requested from us. For example:
We also need some information so that we can comply with our legal obligations. For example, we may need identity documents from you to meet our obligations to prevent fraud and money laundering.
If you do not provide the information required for these purposes, we will not be able to perform our contract with you and may not be able to provide services to you or continue to provide certain services to you. We will explain when this is the case at the point where we collect information from you.
5. THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
What is the legal basis of our data processing?
Under data protection legislation we are only permitted to use your personal information if we have a legal basis for doing so. We rely on the following legal bases to use your information;
In more limited circumstances we may also rely on the following legal bases:
We may process special categories of personal information and criminal conviction information in the following limited circumstances:
6. FOR HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SECURE?
All data is hosted in datacentres which have systems and protections in place to protect against both unauthorised access, and other external factors that could cause damage to, your personal data. There are strict access requirements in place and access is restricted to those absolutely necessary.
We ensure access to personal information is restricted to Anderson Rose employees and workers or other persons working within the Anderson Rose Limited on a need to know basis. Training is provided to any of those Anderson Rose employees and workers who need access to personal information.
8. OVERSEAS TRANSFERS OF YOUR PERSONAL INFORMATION
We may transfer, store, or process your personal information in locations outside the UK and the European Economic Area (EEA). Where the countries to which your personal information is transferred do not offer an equivalent level of protection for personal information to the laws of the UK, we will ensure that appropriate safeguards are put in place.
We’ll use one of these safeguards:
You have a number of rights in relation to your personal information, these include the right to:
9. YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION
o If Anderson Rose is continuing to process personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected
o If Anderson Rose is relying on consent as the legal basis for processing and you withdraw consent
o If Anderson Rose is relying on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us continue with the processing
o If the personal information has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation)
o If it is necessary to delete the personal information to comply with a legal obligation
o personal information is inaccurate
o our processing of your personal information is unlawful
o where we no longer need the personal information but you require us to keep it to enable you to establish, exercise or defend a legal claim
o where you have raised an objection to our use of your personal information
If you would like to exercise any of your rights please contact firstname.lastname@example.org or write to us to at Data Protection, Anderson Rose, Cardamom Building, 31f Shad Thames, London, SE1 2YR.
In addition, you can exercise your right to object to direct marketing at any time by clicking the ‘Opt out’ button at the bottom of all our emails or email ‘No’ to email@example.com.
10. COMPLAINTS AND CONTACT DETAILS
If you have any complaints about the way we use your personal information please contact Customer Care by emailing firstname.lastname@example.org, FAO Customer Care who will try to resolve the issue. If we cannot resolve any issue, you have the right to complain to the data protection authority in your country (the Information Commissioner in the UK). If you need more information about how to contact your local data protection authority please let us know by contacting email@example.com
If you have any questions, comments or requests regarding any aspect of this Privacy Statement, please do not hesitate to contact us by sending an email to firstname.lastname@example.org or writing to Anderson Rose, Cardamom Building, 31f Shad Thames, London, SE1 2YR.
11. WEBSITE AND COOKIES
Cookies allow us to provide important site functionality so you don’t have to re-enter lots of information. They also allow us to remember what links and pages you have been or viewed during a session. This helps us deliver a better, more personalised service to you.
Our website may contain links to other websites run by other organisations. We are not responsible for the privacy practices of those organisations or the content of their websites. You should read the privacy policies of these organisations before providing them with any personal information.
Please refer to our full Website Policy Anderson Rose Website Policy
12. REVIEW OF THIS POLICY
We keep this Policy under regular review. This Policy was last updated on 24th May 2018.
You can obtain further information about data protection laws by visiting the Information Commissioner's Office website at www.ico.org.uk.