Table of contents.
Who is covered by this policy?
This policy covers anyone who enters into an agreement with Grace Miller & Co as a buyer, seller, landlord or tenant of a residential property that we have been instructed to handle.
What personal information will we collect?
- Your name, address and title.
- Contact information, including telephone number, postal address and email address.
- Financial information such as your bank details, payment details and information obtained as a result of our credit checks such as bankruptcy orders, individual voluntary arrangements or county court judgments where you are a landlord or tenant.
- Documents provided to evidence proof of name (such as your passport, birth certificate and driving licence) and proof of address (such as utility bill, bank statement, local authority bill, NHS medical letter or GP letter of confirmation).
- Where you are a tenant and we have introduced you to a referencing company, any information collected as part of a reference request.
- In respect of reservation new home sales under the Help to Buy Scheme, any information provided on your reservation form including details of the property, any special conditions and financials.
- Where you are a tenant, information about your job such as your job title, employment history and employment records (including information on your salary, benefits and earnings).
- Additional information which is relevant to the property you are buying, selling, letting or renting for example:
- your current home status and living circumstances; and
- your family circumstances.
- Information which we have gathered from publicly available sources such as the HM Land Registry.
How will we collect your personal information?
We will collect information directly from you when:
- you visit our offices or we visit you at your property;
- you complete documentation including terms and conditions of business, landlord management information, application for tenancy and reference requests;
- you use our website;
- you contact us to make a complaint;
- you contact us by email, telephone, WhatsApp and through other written and verbal communications; and
- you request information about our services or subscribe to a newsletter or property alerts.
As well as obtaining information directly from you, we will also collect information from:
- third parties involved in the sale/letting process such as solicitors, estate agents, third party referencing companies (where you are a tenant) and other property management companies;
- publicly available sources such as Companies House and the HM Land Registry;
- credit reference agencies where you are a tenant.
What will we use your personal information for?
We may use your personal information for a number of different purposes. In each case, we must have a "legal ground" to do so. We will rely on the following “legal grounds” when we process your "personal information":
- We need to use your personal information to enter into or perform the contract that we hold with you. For example, we need to use your personal information to arrange and administer the letting or sale of your property and to keep you updated on progress.
- We have a legal or regulatory obligation to use your personal information. For example, our regulators and governing bodies require us to hold certain records of our dealings with you and the HMRC require us to keep certain records.
- We need to use your personal information for a legitimate business purpose (e.g. to keep a record of all properties that we have been involved with, to assist with the buying or letting process, to keep all stakeholders updated, to keep business and accounting records, manage our business operations and to develop and to improve our products and services). When using your personal information for these purposes, we will always assess our need to use your personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
- If none of the above apply, then we will ensure we have your consent in any other case.
Who do we share your personal information with?
We will keep your personal information confidential and will only share it where necessary for the purposes set out above with the following parties:
- Other third parties involved in the sale or letting process such as contractors, solicitors, estate agents, property developers, mortgage and financial advisers and other property management companies.
- A referencing company and landlords where you are a tenant and we have introduced you to a particular referencing company.
- In respect of reservation of new home sales under the Help to Buy Scheme: the Homes and Communities Agency and clients.
- Insurers who provide our insurance and companies who arrange such insurance.
- Regulatory bodies including the Royal Institution of Chartered Surveyors, the Association of Residential Managing Agents, Association of Residential Letting Agents, Financial Conduct Authority, Tenancy Deposit Scheme and the Ombudsman Services.
- The police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime.
- Debt collection agencies.
- Credit reference agencies.
- Our third party service providers such as IT suppliers, auditors, solicitors, document management providers, outsourced business process management providers, our subcontractors and tax advisers.
- Third parties such as review websites who we use to gather feedback about our services and client testimonials.
- Third parties who undertake analysis for the purposes of product improvement.
- Selected third parties in connection with any sale, transfer or disposal of our business.