INTRODUCTION AND DEFINITIONS
Southcott Homes (Fareham) Limited (“we“, “our” and “us“) is committed to protecting and respecting your privacy.
This notice (and any other documents referred to in it) set out the basis on which any personal data, which we collect about you, that you provide to us or that we have received from a third party source, will be processed by us.
Our site may, from time to time, contain links to and from partners’, advertisers’, affiliates’ and social network sites. If you follow a link to any of these websites, please note that these sites have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check their privacy policies before you submit any personal data to those websites as they may not be on the same terms as ours.
If you have questions about correcting or deleting your personal data please refer to sections 3 and 8 below.
References in this notice to “data protection law” mean (as applicable) the Data Protection Act 1998 (and subsequent legislation), the General Data Protection Regulation (Regulation (EU) 2016/679) and all related data protection legislation having effect in the United Kingdom from time to time.
References in this notice to “data or “information” include “sensitive personal data” and “special categories of data” (as defined under data protection law) where applicable.
1. Our details
1.1 The data controller with conduct of your personal information is Southcott Homes (Fareham) Limited, of THE BARN CALCOT LANE
Company No. 08993556.
1.2 We are not obliged to have a data protection officer but any enquiries can be directed to Jane Carpenter at Southcott Homes and she can be contacted at the above address or on email@example.com.
2 How we use your information
2.1 The following sections explain what information we hold about you, why we are processing that information, the legal basis for the processing, the duration for which we keep your information and (if applicable) who your information will be shared with and where those recipients are based.
Which information do we process and for what purpose?
2.2 We process the following information from you:
2.2.1 Information you give us.
As a user of our website: This is information about you that you give us by filling in forms on our site. It includes information you provide when you register to use our site, request marketing information and when you report a problem with our site. The personal data within this information you give us may include your name, email address, phone number.
As a client or tenant ( or a potential client or tenant) making enquiries
2.2.2 This is information that you give us when you become a client or tenant of Southcott Homes or when you make an enquiry. It will include name, email address, phone number and home address. In our client ID verification processes we will take details of your driving licence or passport and a utility bill.
2.2.3 We do not process any sensitive categories of personal information relating to our clients, tenants or any other third party.
As any other third party
2.2.4 In respect of other third parties whose personal data we might collect, this may usually be your name, email address, phone number and possibly your home address or work address.
As an employee or Job applicant of Southcott Estates Limited
2.2.5 If you are an employee of ours or are applying for a job, please refer to our employee privacy notice or our candidate privacy notice.
2.2.6 In respect of all categories of data subjects above, we process information you give to us for the following purposes:
22.214.171.124 to supply you with the goods and/or services you have purchased/requested from us;
126.96.36.199 to manage your account with us;
188.8.131.52 to instruct you to carry out services on our behalf;
184.108.40.206 to carry out your employment with us; and
220.127.116.11 to notify you about changes to our products and services.
2.2.7 Non-personal Information we collect about you. Like most other website operators, we collect non-personally identifying information of the sort that web browsers and servers typically make available. This includes technical information, such as your IP address and your login information and information about your visit, such as records of how you navigate the pages on our site and how you interact with the pages.
2.2.8 We process information we collect about you for the following purposes:
18.104.22.168 to allow us to administer the account you hold with us;
22.214.171.124 to improve our services;
126.96.36.199 to ensure that content from our site is presented in the most effective manner for you and for your device; and
188.8.131.52 to measure or understand the effectiveness of advertising we serve to you and others, and possibly to deliver relevant advertising to you on our site.
What are the grounds for processing your information?
2.3 We are processing your data on the following grounds:
2.3.1 Where you are a private individual, the processing is necessary for the performance of the contract between you and us. This includes where you have instructed us to take some pre-contractual steps (such as providing you with a quotation) prior to us formalising the contract;
2.3.2 where you are a named contact for a corporate client, supplier or contractor or other third party contact, because we have a legitimate interest in communicating with you to arrange and/or administer the performance of the contract between us and your employer or principal. In accordance with our obligations under data protection law, we have carefully weighed up your interests and fundamental rights and freedoms against our interest to process your information and we are satisfied that we are justified in processing your information for this purpose;
2.3.3 the processing is necessary for us to comply with our legal obligations;
2.3.4 the processing is necessary to protect your vital interests or the vital interests of another person.
Duration and further processing
2.4 We only keep your information for so long as it is reasonably necessary. When setting our data retention periods, we consider the amount, nature, and sensitivity of the information we hold, the potential risk of harm from unauthorised use or disclosure of the information and the purposes for which we process the information (including whether we can achieve those purposes by other means). We also take into account our other legal obligations to keep or securely dispose of personal information.
2.5 Generally speaking, we retain your information for the following periods of time:
2.5.1 In respect of information collected through our website and from any potential clients or tenants making enquiries – 5 years;
2.5.2 Personal Data relating to customer care – 2 years;
2.5.3 Personal Data relating to new and existing customers – 5 years;
2.5.4 Personal Data relating to suppliers, sub-contractors, consultants and agents or other third parties – as required taking into account the considerations above.
2.6 There may be instances where we need to keep your information for a longer period then we will notify you of the reason and grounds for doing so. This may be the case, for example where for example, a dispute arises in respect of the contractual relationship between us.
Who is your information shared with?
2.7 Your personal information is not shared with anyone except where we are required to do so to comply with the law, to protect our rights and operate our usual business practices, or to improve and expand our products and services. Further details are given in the rest of this clause.
2.8 We may share non-personal information with sub-contractors engaged by us to help us operate our site, or to advertisers who we permit to place relevant adverts on the site, and to analytics and search engine providers that assist us in the improvement and optimisation of our site.
2.9 In order to achieve the purpose(s) set out in section 2.3 above, we may share your data with the following people or group of people:
2.9.1 installation service providers or other contractors so that they can provide installation services requested by you.
2.9.2 Surveyors and architects, land agents, solicitors acting on any particular purchase or project.
2.9.3 Our outsourced IT providers may have access to your personal data on our IT systems if such access is required to enable them to resolve problems with our systems. In certain circumstances they may require access to unencrypted data, for example when we need to troubleshoot an issue with your account on our computer system. Our IT providers are subject to strict contractual obligations to treat your personal information with the utmost sensitivity, to keep it confidential and to comply with data protection law at all times.
2.9.4 our legal advisers, our insurers or other professional advisers, if necessary to defend claims, protect our rights, or receive advice on compliance with the law. Such transfers will be protected by confidentiality obligations owed by our advisers.
2.9.5 Regulatory or other statutory or other government body with whom we are required to share personal data.
2.9.6 potential purchasers of our business, subject to those persons entering into strict confidentiality obligations with us and only to the extent permissible under data protection law.
2.10 To the best of our knowledge, understanding and belief, your information will not be transferred outside of the European Economic Area or to any country which is not approved by the European Commission. If this changes then we will let you know.
2.11 Automated decision making
2.12 We do not make automated decisions about you based on your information.
3 Your rights
3.1 Under data protection law you have the following rights:
3.1.1 the right to access a copy of your information which we hold. This is called a ‘subject access request’. Additional details on how to exercise this right are set out in section 5, below;
3.1.2 the right to prevent us processing your information for direct marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by contacting us using the details set out in section 8, below;
3.1.3 the right to object to us processing your personal information in certain other situations;
3.1.4 the right, in certain circumstances, to have your information rectified, blocked, erased or destroyed if it is inaccurate; and
3.1.5 the right, in certain circumstances, to claim compensation for damages caused by us breaching data protection law.
3.2 From 25 May 2018 you will have the following additional rights under data protection law:
3.2.1 enhanced rights to request that we erase, rectify, cease processing and/or delete your information; and
3.2.2 in certain circumstances, the right to request the information we hold on you in a machine readable format so that you can transfer it to other services. This right is called ‘data portability’. Additional details on how to exercise this right are set out in section 5, below.
3.3 You also have the general right to complain to us (in the first instance) and to the Information Commissioner’s Office (if you are not satisfied by our response) if you have any concerns about how we hold and process your information. Our contact details are set out in section 8, below. The Information Commissioner’s Office website is ico.org.uk.
3.4 For further information on your rights under data protection law and how to exercise them, you can contact Citizens Advice Bureau (citizensadvice.org.uk) or the Information Commissioner’s Office (www.ico.org.uk).
5 ACCESS TO INFORMATION
5.1 Under data protection law you can exercise your right of access by making a written request to receive copies of some of the information we hold on you. You must send us proof of your identity, or proof of authority if making the request on behalf of someone else, before we can supply the information to you. Requests should be sent to us using the contact details in section 8 below.
5.2 From 25 May 2018 you will:
5.2.1 no longer have to pay a £10 fee unless you are requesting copies of documents you already possess, in which case we may charge our reasonable administrative costs. We will also be allowed to charge you for our reasonable administrative costs in collating and providing you with details of the requested information which we hold about you if your request is clearly unfounded or excessive. In very limited circumstances, we are also entitled to refuse to comply with your request if it is particularly onerous; and
5.2.2 in certain circumstances, be entitled to receive the information in a structured, commonly used and machine readable form.
6 Data security
We will always store your digital information on secure servers. Unfortunately, however, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of your information transmitted to our site or otherwise to our servers (such as by email). Any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7 Changes to our privacy notice
This notice was last updated on 21 May 2018. Any material changes we may make to our privacy notice in the future will be uploaded to our website. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to Jane Carpenter by email to jane.carpenter@Southcotthomes.co.uk