Orchard Lettings understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us
Registered address: 32 Tandragee Road, Portadown, Co. Armagh, BT62 3BQ
We are a member of the Property Redress Scheme and The Tenancy Deposit Scheme (NI)
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us):
· Date of birth;
· Email address;
· Telephone number;
· Employment details;
· Credit history;
· Benefits / Pension / Income details.
· Next of Kin details
· Mortgage details
· Insurance details
Your personal data is obtained from the following third parties:
6. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes:
· Providing and managing your account.
· Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.
· To conduct searches about your identity, your current and past residency addresses, and credit history to meet applicable laws and to provide a recommendation to landlord clients, on your suitability as a tenant
· Communicating with you. This may include responding to emails or calls from you.
· Supplying you with information by email or post that you have opted-in to (you may unsubscribe or opt-out at any time by contacting us at firstname.lastname@example.org).
· To send you information about properties and property related services you may request of us or that we think will be of interest to you.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We use the following automated system for carrying out certain kinds of decision-making. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 11.
· The following automated decision-making method(s) may be used:
o We use Experian to conduct searches about your identity, your current and past residency addresses, and your right to live in the UK and credit history to meet applicable laws and to provide a recommendation to landlord clients, on your suitability as a tenant.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
· Where we process personal data in connection with performing a contract, we keep the data for 7 years from your last interaction with us;
· Where we process registration data, we do this for as long as you are an active user of our sites and for 7 years after this.
· Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.
8. How and Where Do You Store or Transfer My Personal Data?
We will only store your personal data in the UK. This means that it will be fully protected under the GDPR.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
· Electronic data is store on password protected computer systems and is held on encrypted servers.
· All paper-based data is held in locked cabinets
9. Do You Share My Personal Data?
We may share your personal data with other companies in our group for the purpose of providing a service to you and understanding your use of our products and services.
We may sometimes contract with the following third parties to supply products / services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
· Mortgage brokers we are partnered with for mortgage services and advice;
· Independent financial advisors for advice relating to your property;
· Solicitors and conveyancing agents for legal advice relating to your property;
· Any other named party to a signed contract, such as your landlord or tenant;
· Third parties who provide services to the property for maintenance and repairs including plumbers/electricians/builders/carpenters-);
· Surveying companies for surveying services required for the sale/purchase of your property;
· Utilities companies where we are required to do so to adhere to a tenancy agreement;
· Referencing companies to obtain references for letting a property;
· Block managers where a let property is a leasehold property;
· Inventory companies who conduct check ins and check outs; and
· Insurance and warranty companies where you have decided to buy a product or service through us.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
We may sometimes contract with third parties (as described above) that are located outside of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If any personal data is transferred to a third party outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: email@example.com
Telephone number: 02838 355100
Postal Address: 32 Tandragee Road, Portadown, Co. Armagh, BT62 3BQ
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes we may make to this policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our policy.