We will ensure personal data is processed lawfully and fairly in a transparent way, which ensures its security, and no further than the legitimate purposes for which that data was collected. We will ensure that data collected is limited to what is necessary in relation to the processing purpose, is accurate and kept up to date and that it is kept in a form which permits identification of the data subject for no longer than is necessary. We will ensure that the information is held for no longer than is necessary and that it is not transferred outside the EU, to other countries or international organisations without an adequate level of protection.
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 letting or managing property, or sourcing property to let or manage, or when you apply for any related services to our lettings and property management business
- Automated technologies or interactions with our website and property portals, including using a web enquiry form.
- Publicly available sources processing Identity, Contact and Financial categories of personal data
The personal data we collect about you
Personal data collected, used, stored and transferred by us may include some or all of the following:
Contact Data – Your name, address, email and telephone numbers, and where you engage with us in a business context, your job title and company contact details
Identity Data – Date of birth, proof of identity and address documents, and signature.
Financial Data– Employment information, bank statements, source of funds / income, financial history to confirm rental ability /suitability, Bank account details & insurance details.
Transaction Data – Price offered or paid for property let or rented through us.
Profile and Usage Data– including feedback and survey responses, and how you use our website, products and services
Marketing and Communications Data– your communication preferences in relation to any marketing and sales 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||Data type collected||Lawful basis of processing|
|Property Search, Landlord or general enquiry||Contact||Consent and Legitimate Interest|
|Tenants and Potential Tenants, Guarantors||Identity, Contact, Financial, Transactional, Technical||Legitimate Interest and Performance of a Contract. To comply with regulatory and legislative requirements|
|Landlords||Identity, Contact, Financial, Transactional, Technical||Legitimate Interest and Performance of a Contract. To comply with regulatory and legislative requirements|
|Freeholders, Leasees||Identity, Contact, Financial, Transactional, Technical||Legitimate Interest and Performance of a Contract. To comply with regulatory and legislative requirements|
|Contractors / Suppliers||Contact, Financial|
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.
You will always have the option not to receive marketing communications from us. We will never send you unsolicited ‘junk’ email or communications or share your personal data with anyone else who might do so.
You can opt-out of receiving these types of communications by amending the preferences on the relevant email communication or by contacting us at email@example.com
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, contractors and suppliers 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 JW&Co website may 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 do not control these third-party websites and are not responsible for their privacy statements.
Sharing of personal data outside of the European Economic Area
Due to the international nature of modern business technology, there may be some instances where your data is processed or stored outside of the European Economic Area. In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law.
Who we disclose personal data to
Your personal data may be shared with third parties for the following purposes:
|Purpose / Activity||Who Data may be shared with|
|Property Search, Landlord or general enquiry||Regulating authorities|
|Potential buyers and/or Tenants||Regulating authorities, Financial Services providers, Surveyors, Solicitors, Referencing agencies, Landlords|
|Sellers and Landlords||Regulating authorities, Financial Services providers, Surveyors, Solicitors, Debt collection agencies, Professional service providers (ie: photographer/videographer, EPC and floor plan) Local Authorities, Referencing agencies, Contractors, Suppliers|
|Managed Tenants||Regulating authorities, Financial Services providers, Debt collection agencies, Local Authorities, Referencing agencies, Contractors, Suppliers|
|Freeholders, Leasees||Regulating authorities, Financial Services providers, Surveyors, Solicitors, Referencing agencies, Contractors, Suppliers|
Contractors and suppliers, we deal with 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.
Where you have given consent for us to contact you with prospective properties we will hold that information for one year.
Where you have given consent for us to contact you with prospective tenants we will hold that information for six years.
Where we have a client or business relationship with you we hold your personal data for six years from the date our relationship ends. We hold your personal data for this period for regulatory and accounting purposes, and to establish, bring or defend legal claims.
The only exceptions to the periods mentioned above are where:
- The law requires us to hold your personal data for a longer period, or delete it sooner
- If there are outstanding balances due to us at the end of our relationship, we will retain your data for a period of six years following the collection of all amounts owed to us
- You have raised a complaint or concern regarding our services, in which case we will retain your data for a period of six years following the conclusion date of that complaint
- You exercise your right to have the data erased and we do not need to hold it in connection with any of the reasons permitted or required under the law
How can you manage the data we hold about you.
You have a number of rights in relation to your personal data under data protection law. Except in rare cases, we will respond to you within one month after we have received any request.
You have the right to:
- Ask for a copy of the personal data that we hold about you
- Ask for the personal data we hold about you to be corrected or updated.
- Withdraw your consent to us holding your personal data (where we rely on that consent).
- Object to our use of your personal data (where we rely on the public interest or our legitimate interests to use it) provided we do not have any continuing lawful reason to continue to use and process the data.
- Request that we erase your personal data (or restrict the use of it), when we do not have any continuing lawful reason to continue to use it.
- Receive copies of the data you have provided to us in a structured data file (in a commonly used and machine readable format) to transfer to another provider.
Questions relating to this policy
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 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 JW&Co 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.
Changes to our Privacy Notice
We keep our Privacy Notice under review and we will place any updates on this web page. This Privacy Notice was last updated on 25thMay 2018.