GDPR – Dedman Gray Privcay Policy

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Dedman Gray Privacy Policy
Information Commissioner’s Office
Registration Reference: ZA085325

Privacy Policy

This Privacy Policy describes the way in which we deal with the information and data you provide to us to enable us to manage our relationship.

We will process any personal information provided to us or otherwise held by us relating to you in the manner set out in this Privacy Policy. Information may be provided via the Dedman Gray website (the “Website”), telephone calls, emails or any other means.

By accepting this Privacy Policy you agree that you understand and accept the use of your personal information as set out in this policy. If you do not agree with the terms of this Privacy Policy please do not provide us with your personal information.

Who we are

References in this Privacy Policy to “Dedman Gray”, “we”, “us” or “our” relate to Dedman Gray Property Consultants Limited (company number 06723624). We control the ways your Personal Data is collected and the purposes for which your Personal Data is used by Dedman Gray, acting as the “data controller” for the purposes of applicable European data protection legislation.

Contacting us

If you have any concerns, or would like more detail about how we process your Personal Data, you can contact us using gdpr@dedmangray.co.uk.

Protecting Your Personal Data

Your Personal Data isn’t just protected by the quality, commitment and high standards of Dedman Gray, it’s also protected by law. The law states that we can only process your Personal Data when there is a genuine reason to do so and it must be one of the following:

• To fulfil any contract that we have with you
• We have a legal obligation
• Where you have consented to the processing
• When it is in our legitimate interest
• When it is in the public interest
• When it is in your vital interests

Legitimate Interests

When we have a business or commercial reason to process your Personal Data this is referred to as a legitimate interest. Your Personal Data is still protected and we must not process it in a way that would be unfair to you or your interests.

If we do use legitimate interests as a reason to process your Personal Data we will tell you that we are doing so, what our legitimate interests are and provide you with a method to raise any questions or objections you may have. However, compelling grounds for processing such information may over-ride your right to object.

How we store your Personal Data

We currently use a system known as RPS (Reapit), for the purposes of data protection law they act as a Data Processor on our behalf, and we act as a Data Controller. We collect personal data, enter it into RPS and we decide how to use it further. Reapit processes this data solely under the instructions of our use and in accordance with their Terms & Conditions (which are updated from time to time). Reapit have implemented the following:

  • To have a written agreement in place with their clients and suppliers
  • To ensure their employees with access to our data are subject to a duty of confidence
  • To ensure the security of processing activities.
  • To notify you of any sub-processing relevant to our business
  • To assist us in fulfilling our duties with respect to the exercise of our customers’ privacy rights.
  • To assist us in our obligations relating to security, data breaches and data protection impact assessments
  • To assist us with inspections by the Information Commissioner’s Office
  • To return to us all our data upon expiry of our contract. A copy of RPS’s privacy policy, GDPR standards and agreement with Dedman Gray are available upon request.

How long we keep your Personal Data

Whenever your data is kept by Dedman Gray we will ensure that it is appropriately protected and only used for acceptable purposes.

We will keep your data for the period that you are a customer or applicant of Dedman Gray.

If you are no longer a customer or applicant of Dedman Gray, we will keep your data for the minimum length of time required to comply with the purposes set out in this policy and relevant legal or regulatory obligations. Your Personal Data may be kept longer if we cannot delete it for technical reasons.

Provided we do not have a legitimate interest to retain your details, you have the right to be forgotten and removed from our marketing material. You can contact us by telephone, email or in person to confirm this.

Why we process your Personal Data

We process your data to ensure you receive the best service levels from Dedman Gray. We will keep your details on our secure system and will contact you by email or telephone with details of properties that could be of interest.

If you choose not to provide your Personal Data it may prevent us from meeting legal obligations, fulfilling a contract, or performing services you expect from Dedman Gray. Not providing your Personal Data may mean we are unable to provide you with our services.

Information Collected

The information and data about you which we may collect, use and process includes the following:

• Information that you provide to us by filling in forms on the Website or any other information you submit to us via the Website or email
• Records of correspondence, whether via the Website, email, telephone or other means
• Details of the enquiries made with us, whether via the Website, telephone or other means

Where it is reasonable for us to do so and not detrimental to your rights and freedoms, we also collect Personal Data from publicly available sources such as internet searches, Companies House, HM Land Registry and broadcast media.

Telephone Calls

Telephone calls to and from our staff are not recorded. Notes are made and recorded on our secure system.

Use of Cookies

We do not currently use cookies. If this changes our privacy policy will be updated and you will be notified.

Personal Data we share with others

We may share your Personal Data within the Dedman Gray Property Consultants Ltd branches and Dedman Gray Auctions Ltd and with these other organisations:

• Law enforcement agencies, regulators and other authorities
• Credit reference agencies (subject to your prior consent)
• Fraud prevention agencies
• Identity verification agencies
• Organisations that introduce you to us
• Third parties you ask us (or permit us) to share your data with
• Third parties necessary to provide products or services which you have requested

Depending on the products you choose to use we may need to share your Personal Data with the third parties that provide those services, however your explicit consent will first be obtained. Where your Personal Data are transferred outside of the European Economic Area (“EEA”), we require that appropriate safeguards are in place.

Data Transfer Outside the EEA

We will only transfer your Personal Data outside of the EEA where:

• You have given your explicit consent, or
• It is necessary for us to set up or fulfil a contract you have entered into with us; or
• To comply with a legal duty or obligation

If we do transfer your Personal Data outside of the EEA, we will take measures to ensure it is protected to the same standards as it would be within the EEA by relying on one of the following:

• The country that is receiving your Personal Data has been found by the European Commission to offer the same level of protection as the EEA. More information can be found on the European Commission Justice website.
• We will use contracts that require the recipient to protect your Personal Data to the same standards as it would be within the EEA
• Where the transfer is to the USA and the recipient is registered with Privacy Shield. Privacy Shield is a framework that ensures Personal Data is protected to a level approved by the EU. Read more about Privacy Shield on the European Commission Justice website.

In some instances we may be compelled by law to disclose your Personal Data to a third party and may have limited control over how it is protected by that party.

Your rights over your Personal Data

We will assist you if you choose to exercise any of your rights over your Personal Data, including:

• Withdrawing your previously granted consent; however, this will not invalidate any previously consented processing
• Lodging a complaint with any relevant Data Protection Authority
• Access to your Personal Data that we hold or process
• Correction of any Personal Data that is incorrect or out of date
• Erasure of any Personal Data that we process
• Restrict processing of your Personal Data in certain circumstances
• Asking us to provide you or another company you nominate with certain aspects of your Personal Data, often referred to as ‘the right to portability’
• The ability to object to any processing data where we are doing it for our legitimate interests
• The ability to contest a decision made entirely by automated processing, to express your point of view and to request that a human review the decision

For more information on these rights you can contact gdpr@dedmangray.co.uk

Changes to our Privacy Statement

We may update this policy from time to time, so please review it frequently.

If any material changes are made to this Privacy Policy we will use reasonable endeavors to inform you in advance by email, notice on the Website or other agreed communications channels. We will communicate the changes to you in advance, giving an appropriate amount of time for you to consider and understand the changes before they become effective.

We will not enforce material changes to the Privacy Policy without your express consent. If you decline to accept the changes to the Privacy Policy, or otherwise do not accept the changes within the time period, we may not be able to continue to provide some or all products and services.