In this document “The Company” or “The Landlord” or “The Agent” or “Earnest” or “Us” or “We” or “Our” refers to Earnest Property Investments Ltd and Earnest Holdings Ltd and Earnest Lettings Ltd (and any other private limited company or business venture involving the directors and any other persons employed under the directors).
The purpose is to maintain policy and records on data control pertaining to processing and controlling purposes, data sharing and retention/consent. The Company must comply with GDPR because it provides accommodation and services in exchange for payment.
In More Detail
Our responsibility as ‘controllers’ and sometimes ‘processors’ of data means that we must document all applicable information under Article 30(1) and 30(2) of the GDPR.
Our organisation deals directly with, but not limited to, the following types of client base; high net worth investors, property buyers, property sellers, private home owners, tenants, guarantors, prospective tenants, and prospective guarantors.
Examples of personal information and sensitive personal information that our organisation might control or process:
Bank/building society statements and account details
Copies of photographic identification, e.g. passport/passport number, driving license/car registration, showing home address, date of birth, marital status, national insurance number, IP address, email address,
Documentation relating to the circumstances surrounding a client’s financial position, political opinion, sexual orientation, philosophical belief, health, ethnic origin, and that might be detrimental to their reputation or the general public
Criminal conviction and offence data
We may keep data for up to 5 years to assist, where absolutely necessary, with the company’s accounting. The company is completely transparent to customers with whom we collect data from and the purpose we retain it.
The lawful basis for processing or controlling the data and information we acquire is dictated in accordance with the professional responsibilities the company must abide to when vetting, for example; right to rent (tenants), money laundering (buyers/investors).
We regularly conduct 12 monthly reviews and auditing of the personal data we process. For example, for investor/buyer clients we require an up to date financial statement to ensure that the buyer is still in the financial position to purchase the property opportunity or service. Once information is updated, old data is deleted. Data older than 5 years is deleted, unless there is significant reasoning to retain this information and/or we have consent from the individual/client.
As part of our record of processing we review our policies and procedures regularly that addresses in particular; retention, security, and data sharing (as mentioned already earlier in this document).
Earnest Property Investments ltd Client Engagement Letter (For Landlords)
What do we do with personal data?
We use personal data to enable us to provide customers with a great service, as well as for us to make informed commercial decisions.
How long will we keep personal data?
We keep information while they are our customer and after they have left us. We use this information to provide the customer with the products and services they have selected and for a variety of other reasons. In each case, the length of time that we need to keep the information may be different, but we will only keep the information for as long as we need it.
We will share customer information in the following situations:
With partners, suppliers, agents and subcontractors who help us deliver the products and services they have chosen to use;
When they have provided consent;
When we have legal or regulatory requirements such as a request from the competition authority, law enforcement agency or a credit reference agency.
We collect information in three ways:
Directly from customers, such as information filled in within application or registration forms, surveys and community posts;
From the products and services they use, such as the calls they make to us;
From 3rd parties, such as information from credit reference agencies.
Customers have the following rights:
To be informed about how we use their personal data;
To update their personal data. This can be done by formal written request to the Managing Director (contact details below);
To ask us to delete their personal data. However, there may be circumstances where we are legally entitled to retain it;
To get a free copy of their personal data;
To object to the processing of their data and have it restricted. There may be circumstances where they need ask us to restrict the processing of their information, but we are legally entitled to refuse that request;
The right to make a complaint to the Information Commissioner (www.ico.org.uk)
How can customers change their marketing preferences? - They can also opt out of marketing communications by following unsubscribe links at the bottom of any marketing emails or text messages received from us.
We will never give your personal data to a third party for marketing unless you have expressly given us your permission.
How do we ensure that customer data is secure? - Earnest is committed to keeping data secure. We have procedures to help protect personal data from unauthorized access, use or disclosure.
Our contact details
If a customer would like to raise any queries with us in relation to the information we may hold, they can contact us by writing to:
Earnest Property Investments Ltd.
Resolving Privacy Issues
We will always try our best to resolve any data privacy issue. Customers and persons whom we hold data on have the right to refer any data privacy issue to the Information Commissioner's Office at any time.