2. WHO ARE WE
HNF Property Ltd (The Company) holds personal data about clients, suppliers and employees for a variety of business purposes. This policy sets out how we seek to protect personal data and ensure that officers of The Company understand the rules governing their use of personal data to which they have access in the course of their work.
Data Controller Officer (DCO): Peter Friend
Telephone: 020 8769 0161
Post: HNF Property, Raworth House, 36 Sydenham Road, Croydon, Surrey CR0 2EF
ICO Registration No:
3. WHAT PERSONAL DATA DO WE COLLECT
HNF Property Ltd may collect, use, store and transfer different kinds of personal data about you which are:
- Identity Data includes first name, last name, employment status, marital status, title.
- Contact Data includes home address (previous, current and forwarding), email address and telephone numbers.
- Property Data includes type, number of rooms, locks, energy usage, easements, keys, utility meter information, services records, insurance documents and mortgage documents.
- Financial Data includes bank account details.
- Transaction Data includes card payment details & details about payments to and from you.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Depending on the service that we provide to you we may also collect additional personal data as detailed below:
Purchasing a property we are listing we will collect personal data in order that we can source a property to fit your needs and negotiate the purchase on your behalf.
Renting a property we are listing we will collect personal data in order that we can source a property to fit your needs and negotiate the tenancy on your behalf. Your bank, building society or similar account details in order that we can manage an approved tenancy deposit account for you and to set up your rental payments.
Selling or letting a property we will collect contact telephone numbers in order that we can contact you to organise viewings, update you on offers received or rental applications for your property. Where you are not the legal owner of the property we will request information in support of your authority to sell or let the property (e.g. Power of Attorney, Guardianship Order, Grant of Probate). Your bank, building society or similar account details in order that we can arrange onward payment of rent due to you.
Managing a property on your behalf we will ask for additional emergency contact data in case we need to contact you outside of working hours or in the event there is a matter requiring your urgent attention.
You must take reasonable steps to ensure that personal data we hold about you is accurate and updated as required. If your personal circumstances change, please inform the DCO so that the data can be updated in the records.
4. WHAT ARE WE GOING TO DO WITH YOUR DATA
Personal data will generally be collected directly via the use of standard forms, over the internet, via email, face to face while in our office or during a telephone call with you.
- In order to fulfil our obligations to you when providing you with our property services.
- To share your information with others where necessary to fulfil our property services for you or where acting as agent for a third party on your behalf.
- To comply with our statutory and regulatory obligations, including verifying your identity, prevention of fraud and money laundering and to assess your credit worthiness.
- To communicate with you during the course of providing our services, for example with your enquiries and requests.
- Statistical purposes so we can analyse figures to help us manage our business and plan strategically for the future.
- To provide you additional property related services from third party providers, only where you have provided permission for us to do so. These may include:
- Mortgage brokers
- Photographer/Floor planner/EPC engineer
- For Sale/To Let Board Companies
- Other Estate Agents for the purposes of progressing a sale or tenancy
- We will source information which is in the public domain (Land Registry) regarding potential sites/land suitable for development.
- To provide you with information about goods or services we feel may be of interest to you, where you have provided permission for us to do so or, if you are an existing customer, where we choose to contact you by electronic means with information about our own goods and services similar to those which you have already obtained from us or you have negotiated to obtain from us. For those marketing messages you can unsubscribe at any time.
- To notify you about changes to our services.
- To ensure that content from our site is presented in the most effective manner for you and for your device.
5. LAWFUL BASIS OF PROCESSING YOUR DATA
HNF Property Ltd take your privacy seriously and will only ever use data which is personal to you where it is necessary, fair and lawful to do so. We rely on the following legal basis to use your data:
- In order to perform the contract we have entered into with you.
- Where processing is necessary as part of our legitimate interest and providing that your interests and fundamental rights do not override those interests.
- Processing that is necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaign, including sending you marketing information from time to time after you have engaged us to provide services or received services from us, either which may be similar and of interest to you or where you have expressly indicated that you would like to receive such information. You have the right to opt-out of receiving this information at any time.
- If you engage our services we may send you information we think you may be interested in, from time to time.
- Processing that is necessary to improve our knowledge of the property sector, including undertaking market analysis and research so that we better understand trends and ensure that we are equipped with the knowledge to enable us to provide more tailored and relevant services for our customers.
- Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively, including verifying the accuracy of information that we hold about you and create a better understanding of you as a customer; processing for network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access or to comply with a request from you in connection with the exercise of any of your rights outlined below.
- Where we need to comply with a legal obligation.
- Where it is needed in the public interest or for official purposes.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us
6. WHO WE SHARE YOUR PERSONAL DATA WITH
HNF Property Ltd may also disclose your personal data between our employees, agents, brokers and contractors. We will not share your personal data with or sell it to third party marketers. No information is transferred to a foreign country.
HNF Property Ltd may disclose your personal data to third parties in connection with our functions and activities, including:
- To the other parties in the transaction for sale and leasing, including developers, vendors, landlords, purchasers and tenants, and their authorised representative.
- To guarantors, other mortgage intermediaries, lenders, financial institutions, insurers, valuers and credit reporting bodies and providers.
- To your authorised representatives (lawyers, mortgage brokers, accountants and financial advisors).
- To regulatory bodies, government agencies and law enforcement bodies in any jurisdiction.
- To the relevant government agency for verification of attendance at conferences and training sessions for continuing professional development requirements.
- To debt collectors and utility companies.
- When we may be required by law from time to time.
HNF Property Ltd may also disclose personal data to our suppliers and service providers that provide products and services to us in connection with our functions and activities, including third parties who:
- Deliver marketing and digital marketing services to us.
- Mailing, courier and print service providers for us.
- Provide event registration and management services.
- Conduct market research, surveys and analysis.
- Provide a broker database.
- Host our servers and websites.
- Provide IT services.
- Data processing, storage and back-up.
- Process payments.
- Provide recruitment consultant services.
- Manage HR information such as payroll and superannuation.
7. HOW WE STORE YOUR PERSONAL DATA
Your data will be stored electronically with all reasonable technological and operational measures put in place to safeguard it from unauthorised access and any identifiable data will be encrypted or minimised. Where necessary your data will be stored securely, in hard copy format, within the premises of HNF Property Ltd. Access to such data will be limited to HNF Property Ltd employees only.
8. HOW LONG DO WE KEEP YOUR DATA
We will retain your personal data for different periods depending upon the service you have asked us to provide, which may be a longer period than that for which we need to hold your data to provide those services, i.e. where we are under regulatory or statutory duties to hold your data for a longer period or need to retain it in the event of a legal claim or complaint.
9. PERSONAL DATA ACCESS REQUEST, RECTIFICATION AND DELETION
You have the right to request at any time, confirmation of the actual personal data we hold for you, and how this has been processed. Such a request can be sent to the above address or email which will be actioned within 14 working days of receipt.
You have the right to request that we amend any personal data we hold for you if you believe it is incorrect. Such a request can be sent to the above address or email, where we will confirm rectification or if not possible, explain the legitimate or lawful reasons why such a request cannot be actioned within 14 working days of receipt.
You have the right to request that all your personal data we hold is deleted. Such a request can be sent to the above address or email, where we will confirm deletion or if not possible, explain the legitimate or lawful reasons why such a request cannot be actioned within 14 working days of receipt.
10. WEBSITE DATA COLLECTION
HNF Property Ltd collect data via the enquiry forms (name and email address) and the user/administrator/contributor login (name and email address). In relation to the enquiry form the data is only being transferred to a designated email address, it isn’t being stored on the site. For the user login the data is being used to either facilitate information to that person or to identify them. All data is obtained by being submitted through a form. No data will be obtained without notification that it is being stored or without permission to do so. In relation to the enquiry form the data is being stored in the designated email’s mailbox. For the user login section the data is being stored in the website database.
11. QUERIES ABOUT THE USE OF YOUR PERSONAL DATA
In the first instance, if you have any query about how we hold or process your personal data, then please contact the DCO at the above address or email.
If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can complain to the UK data protection regulator, the Information Commissioner’s Office. Further details can be found at www.ico.org.uk or 0303 123 1113.