This privacy notice has been issued to comply with the General Data Protection Regulation (GDPR) which comes into effect on 25 May 2018.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
Who are we?
Harwin Property Consultants Limited are an independent niche commercial agency. We specialise in providing expert agency and development advice for our clients across all sectors for both private investors / institutional landlords and occupiers across the South East.
What do we collect?
Information you provide voluntarily
When you contact us, we may collect personal information about you to allow us to undertake our business, such as:
- Name, address, telephone number and email address
- Proof of identity, such as proof of address and photographic identification (passport/Driving licence) information to carry out any necessary anti-money laundering and credit checks to comply with HMRC Money Laundering Legislation.
We will ask your permission to store your personal data.
Information that we collect automatically
In order to comply with various regulations, or to conduct background checks in accordance with our internal requirements (where permissible and in accordance with applicable law), sometimes we may receive personal information about you from third party sources such as credit check databases and professionally managed databases.
We will only obtain this information where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. The types of information we collect from third parties include, for example, information about whether you have been subject to any particular regulatory action or legal proceedings. We use the information we receive to maintain and improve the accuracy of the records we hold about you and assess any risks arising from any relationship or prospective relationship with you and/or your organisation.
How do we use the information we collect?
It is in our legitimate interests to collect this information to understand your needs and provide you with a better service for the following reasons:
- Internal record keeping;
- We may use the information to improve our services;
- We may periodically send promotional emails or other information which we think you may find interesting using the email address which you have provided; and
- For due diligence purposes, in accordance with applicable law, to assess financial, reputational, credit or insurance risks arising from any relationship or prospective relationship with you/your organisation and/or to carry out any necessary anti-money laundering checks on behalf of us or our landlord clients.
Sharing of information collected
Harwin Property Consultants Limited will never pass your data to third parties without your consent, except to prevent fraud or if required to do so by law.
We also reserve the right under our legitimate interests to provide personal information to third parties such as landlord clients and their legal advisors for the purposes of agreeing Head of Terms and creating leases. We will always ask your permission before we share your personal information.
Legal basis for processing personal information
We rely on the following legal bases to use your personal information:
- Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party (unless there is reason to protect the individual’s personal data which overrides those legitimate interests). This applies to all stages and activities relevant to the provision of services including enquiry and administration, marketing, processing of invoices, and IT security.
- To comply with our legal obligations: fraud prevention and disclosure of information to the relevant authority, for example possible criminal acts or security threats.
- With your consent or explicit consent: where you have given us explicit consent to process your personal data (or explicit consent in respect of sensitive personal data) for a specific purpose or it is necessary for us to meet our legal obligations.
Given the business-to-business context in which we undertake the processing of your personal information, and the safeguards that we take to protect your personal information, our legitimate interests are not outweighed by any prejudice to your individual rights and freedoms. We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are.
We retain personal information we collect from you where we have an ongoing legitimate business need to do so. We will retain this personal information for a period of time to allow us to provide our services and to comply with applicable legal requirements.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect.
All contact information is stored within a secure password protected database. This database is stored on our secure Cloud server, provided by a third party. This information is only accessible to employees of Harwin Property Consultants Limited and all of our devices are password protected.
All anti-money laundering information and credit check information is also stored on our secure & encrypted cloud storage system.
We may from time to time transfer your personal data to a county outside of the EEA. For example, when we store personal data on a cloud server.
Our website may invite you to contact us or to provide information about yourself. We use the information you provide to personalise your online experience and to deliver the content most suited to your needs.
In addition, “cookies” (small text files placed on your computer when you first visit the site) are used on our websites. Most browsers now recognise when a cookie is offered and permit you to refuse or accept it. If you are not sure whether your browser has this capability, you should check with the software manufacturer, technology help desk or your Internet service provider.
Cookies are primarily used to enhance your online experience and are not used to track the navigational habits of identified visitors, unless we obtain your permission to do so. If you visit our site to read or download information, such as news stories or articles, much of the information we do collect is statistical only (for example, the domain from which you access the Internet, the date and time you access our site, or the Internet address of the website from which you linked directly to our site) and not personally identifiable. We use this information in aggregate form to enhance our website. Some of the cookies we use are provided by Google Analytics to collect information in an anonymous form, including numbers of visitors to the site, the pages visited and where visitors have come to the site from.
An overview of privacy at Google can be seen at http://www.google.com/analytics/learn/privacy.html
To opt out of being tracked by Google Analytics visit http://tools.google.com/dlpage/gaoptout
Your rights in relation to your data
The purpose of this Privacy Notice is to fulfil your right to be informed about the use of your personal data, in addition:
- You have the right to access your personal data. If you wish to request copies of your personal data, please contact us at firstname.lastname@example.org
- You have the right to have your personal data rectified if it is inaccurate or incomplete
- You have the right to have your personal data deleted or removed if there is no reason for its continued storage and processing
- You have the right to object to your personal data being processed and to restrict the processing of your personal data in certain circumstances.
- You have the right to opt-out of any marketing communications we send you at any time. You can exercise this right by clicking on the ‘unsubscribe’ link in any e-mails we send you or by e-mailing us at email@example.com
- You have the right to lodge a complaint about Harwin Property Consultants Limited with the Information Commissioner’s Office ico.org.uk
Harwin Property Consultants Limited reserve the right to change this data protection information at any time with effect for the future. The revised policy will be posted to this page so that you are always aware of the information we collect, how we use it and under what circumstances we disclose it. We therefore recommend you read the current data protection information again from time to time.
Last updated: 24 May 2018
Date of Next Review: December 2018