1. Andrew Creighton Ltd is committed to protecting and respecting your privacy.
The General Data Protection Regulation (GDPR) provides new rights to individuals regarding the collection, storage and use of their personal data. This Privacy Policy has been updated to take account of any new requirements under GDPR. Also covered in this Privacy Policy are the requirements of the Privacy and Electronic Communications Regulations 2003 updated 2004 and 2011 (PECR). The revised Data Protection Act and the ePrivacy Directive will be enacted into UK law and any changes will be adopted in a revised Privacy Policy.
It is your responsibility to review this privacy statement and be aware of any such change. Your continued use of the services provided by Andrew Creighton Ltd will indicate your agreement to any such change. We will always comply with the General Data Protection Regulations (GDPR) 2018. Please read the following carefully to understand our practices regarding your personal data and the care in which it will be handled.
2. About Andrew Creighton Ltd
Andrew Creighton Ltd are a firm of Chartered Surveyors and commercial property agents. The registered address is 21A Aylmer Parade, Aylmer Road, London N2 0AT and the company number is 06765565. Andrew Creighton are fully compliant with the requirements as set out in the General Data Protection Regulations (GDPR) 2018 and are registered as a business with the Information Commissioners Office (ICO).
For the purposes of the General Data Protection Regulation (GDPR), we are both a data controller and data processor in respect of the personal information that we collect and process about you as described in this Privacy Policy.
3. What type of personal data do we collect?
We need certain personal information to be able to offer our services. You provide some of this data directly, for instance when you instruct us or contact us. Additionally, we receive some of your personal data indirectly through solicitors, property managers or other third parties.
When you contact Andrew Creighton or a third-party contacts us on your behalf, to provide our services, we may process the following details:
1) First and Last Name;
2) Title (Mr, Mrs etc.);
3) Your property address;
4) Email address;
5) Your telephone number;
6) Payment and billing information, e.g. bank account (if applicable);
7) Company name (if applicable);
8) Business registration number (if applicable)
In the course of the management of a property where Andrew Creighton are the appointed agents, we may also collect the following personal information when you provide it to us:
1) Mortgagee details
2) Financial information relating to your service charges/bank details etc
3) If you are a Client, Director of the Freehold or a Management Company of your Residential Block, your passport or Driving Licence.
We also receive information from third parties we work with. While the partners we work with may change, these mainly include solicitors, property managers or building contractors, who, if you have chosen to make use of our services, may provide us with the details of the instruction and contact information or property address (as above).
Where appropriate and in accordance with regulatory or legal requirements, we may also collect information related to your immigration status, sources of funds or details of any misconduct our clients may need to know about. We also collect your bank details to process payment of fees for other services which you contract from Andrew Creighton Chartered Surveyors. We may use your email address and property requirement to send you relevant properties throughout your search, but you are free to opt-out and close your property search at any time, or ask to be removed from our database.
4. How we get the information and why we do we have it?
We only use your data for the purposes for which it was collected and, where relevant, to meet local legal obligations. We use your personal data for the following purposes:
Performance of agreements with users - To provide you with the services of your choice; we process your information for example to communicate with you.
Customer support - We use your information to support you in your use of our products and services. This includes the use of personal information to discuss matters with third-parties that you have asked us to engage with.
Customer engagement and communication - We use your information to communicate with you via email, SMS text or other electronic media for instance on service‐related matters, such as invoices or reports. Other instances where we engage with you include confirming the opening of a file, providing our surveying services, updating you of significant developments and resolving complaints, if applicable.
Marketing - We may occasionally send you information about our products and services that may be of interest to you. We communicate with you via email, SMS text or other electronic media. You have the right at any time to stop us from contacting you for marketing related purposes. You can ask us not to contact you for marketing purposes if you wish.
Safety, security and dispute settlement - We may like to send you information which may be of interest to you, about our products and services and those of other companies (in so far as you have consented to this) that may be of interest to you. We communicate with you via email, SMS text or other electronic media. You have the right at any time to stop us from contacting you for marketing related purposes.
Legal obligations - We may process your information in relation to a legal obligation. This includes cases where we must comply with requests from competent authorities, administrative obligations and in cases involving legal disputes.
Improving and personalising our products and services - We use your personal information to improve our products and services.
Maintenance, development and incident management - If you experience issues with one of our products or services, we may need to process some of your personal information, such as your name and the nature of our instructions, to resolve the respective issue. We may also use your personal information in relation to certain system development processes, for instance if we move customer data to a new database.
General business process execution, internal management and management reporting - To be able to run our business, we also use your personal information for general business processes. This includes processing your information for archiving, insurance and other administration related purposes, management reporting or processing in relation to audits.
For Property Management for the performance of a contract we have with the management company or freeholder for your building/premises and pursuant to which we are appointed as their agent.
5. Who we share your personal information with?
We may share the following categories of personal data:
• Name
• Address
• Telephone numbers
• Unpaid service charges
This personal information may be shared with the following categories of recipients:
• Contractors
• Solicitors
• Accountants
• Debt Collectors
• New Managing agents
This data sharing enables us to perform our contract as managing agent.
We may disclose your personal information to third parties for reasons including the following:
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or other statutory regulations
• In order to enforce or apply any agreements
• To protect the rights, property, or safety of Andrew Creighton Ltd or others
If at any time you do not wish to receive further information about us and our services, all communications will provide an easy opt-out and opportunity to update preferences. If you want to be removed from all databases, please contact us: info@andrewcreighton.co.uk .
6. How do we protect your personal data?
We have put in place appropriate measures designed to prevent unauthorised access to and misuse of your personal data, and we are continually working to improve them. Information may be held at our offices and those of our group companies, and third-party agencies, service providers, representatives and agents as described above.
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
7. How long do we keep your personal data?
We will retain your personal information only for as long as is necessary for the purposes for which the information was collected, or as long as is required pursuant to law.
Given the nature of most instructions, such as surveys or valuations, when the file is no longer active we will archive the information, so that it can be easily retrieved should you wish to use our services again in the future. After a period, of normally six years, any paper files will be securely destroyed.
In case you wish us to remove your data, please contact us. We will remove your personal information without undue delay except for information that we are obliged to keep pursuant to law. For instance, in order to meet statutory administrative retention obligations, we need to keep some of your account related information (e.g. copies of invoices/receipts), for six years.
Data may be retained longer in cases where it is used in relation to a legal claim or is used in relation to a valid legal process.
8. Your personal data rights
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
• Fair processing of information and transparency over how we use your use personal information
• Access to your personal information and to certain other supplementary information that this privacy notice is already designed to address
• Require us to correct any mistakes in your information which we hold
• Require the erasure of personal information concerning you in certain situations
• Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• Object at any time to processing of personal information concerning you for direct marketing
• Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• Object in certain other situations to our continued processing of your personal information
• Otherwise restrict our processing of your personal information in certain circumstances
• Claim compensation for damages caused by our breach of any data protection laws
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
9. Cookies
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity.
Andrew Creighton’s website uses cookies to monitor use and experience for visitors to our website. This helps Andrew Creighton improve the site where necessary and produce resources that interest our visitors. Our cookies cannot identify you as an individual.
You can set your browser to not accept cookies and the above websites tell you how to remove cookies from your browser. However, some of our website features may not function as a result.
10. Changes to Andrew Creighton’s privacy policy
This Privacy Policy was last updated on 21st May 2018. Andrew Creighton reserves the right to review and update this Privacy Policy as needed, to help keep you informed. Your subsequent use of this website or submission of personal information to Andrew Creighton will be deemed to signify your acceptance to the variations.
11. Contact
If you are not happy with the way we have managed your personal data, you can contact the ICO:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
www.ico.org.uk
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.