Sworders Privacy Notice
Sworders is registered with the Information Commissioner’s Office under reference Z8719263.
In this document we provide detail on how and why we collect and use your personal information. It also tells you about your privacy and legal rights and how to make a complaint in relation to our processing of your personal data.
The phrase ‘Sworders’, ‘us’ or ‘we’ when used in this Privacy Notice, means those members of Sworders on behlaf of and in respect of whom this statement is made.
In summary, this Privacy Notice will explain the following:
• What personal information is
• How we collect your personal information
• The types of personal information we collect
• How we use your personal information
• The legal basis for processing your personal information
• How we share your personal information
• How long we keep your personal information
• How we keep your personal information secure
• Your rights in relation to your personal information
• How to make a complaint and how to contact us
As a controller for the personal information that it collects and uses about you, Sworders is committed to ensuring that your privacy is protected. We treat your personal information as confidential and in accordance with applicable data protection legislation. Your personal information will only be shared with others in accordance with this Privacy Notice. If there are any changes to the way in which your personal information is used, this Privacy Notice will be updated.
2. What is personal data?
Personal data is any information that tells us something about you and from which you could be identified. Examples could include:
• your full name
• contact details
• date of birth
• bank account details.
Some personal data is classified as “special” under data protection legislation. Types of information that fall under this category relate to health records, racial or ethnic origin, religious beliefs or political opinions and sexual orientation. Information falling under this category is deemed in law to be more sensitive and requires further justifications for its collection, storage and processing.
Any references to personal information in this Privacy Notice will include personal data, and where relevant, special categories of personal data.
3. What personal information do we collect?
Whenever you engage Sworders, we will collect from you your full name and contact details (such as phone number, email address and postal address).
In addition, if we are providing a service to you or on your behalf, where we are required to do so by law, we will collect information relating to your identity (such as a passport, a driving licence or an identification card) and one form of documentation with proof of your place of residence (such as a recent utility bill).
Additional types of personal information that we will collect will vary according to the nature of the instruction that we are engaged by you to undertake. In each instance where we collect personal information, this will be done where there is a legal basis for doing so. More information about this is set out in the section that follows.
4. How we use your personal information
What is the legal basis of our data processing?
Under data protection legislation we are only permitted to use your personal information if we have a legal basis for doing so. We rely on the following legal bases to use your information;
• For employment-related purposes
• Where we need information to perform the contract we have entered into with you
• Where we need to comply with a legal obligation.
In more limited circumstances we may also rely on the following legal bases:
• Where we need to protect your interests (or someone else’s interests), and/or
• Where it is needed in the public interest or for official purposes
We may process special categories of personal information and criminal conviction information in the following limited circumstances:
• With your explicit consent, in which case we will explain the purpose for which the information will be used at the point where we ask for your consent.
Other uses of your personal information
• We will share personal information with our regulators, governmental or quasi-governmental organizations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our regulatory and legal obligations.
• Where we use third party services providers who process personal information on our behalf in order to provide services to us. This includes IT systems providers and IT contractors as well as third party referencing or screening agencies for the purposes of the prevention and detection of crime.
• We will hold your personal information on our client management systems and occasionally use this to provide you with marketing information about our services and newsletters which we feel you might find useful. You have the opportunity to opt out of receiving this information at any time.
What happens if you do not provide information that we request?
We need some of your personal information to perform the services you have requested from us. For example:
• in a situation where we are selling a property on your behalf, we will need to know your contact information in order to provide you with updates, information on viewings, offers and the progress of the sale
• where you have engaged us to find you a property which meets certain access requirements, we may need to know some further details about your particular circumstances so that we can find you a suitable property
We also need some information so that we can comply with our legal obligations. For example, we may need identity documents from you to meet our obligations to prevent fraud and money laundering.
If you do not provide the information required for these purposes, we will not be able to perform our contract with you and may not be able to provide services to you or continue to provide certain services to you. We will explain when this is the case at the point where we collect information from you.
5. How we keep your information secure
Sworders takes the security of information very seriously. We have measures in place which are designed to prevent unauthorized access to your personal information including but not limited to:
• Our client files are stored on our secure client management systems. Access is restricted on our client systems to those within the business who are required to have access to your information for legitimate business purposes.
• Hard copy documentation is stored in locked cabinets.
We ensure access to personal information is restricted to Sworders on a need to know basis and we provide our staff with training on access and the handling of personal information.
6. How long do we keep personal information?
The period for which we will keep your personal information will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in case of a legal claim.
7. Your rights in relation to your personal information
You have a number of rights in relation to your personal information, these include the right to:
• Be informed about how we use your personal information
• Obtain access to your personal information that we hold
• Request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate
• Request that we erase your personal information in certain circumstances.
• Ask us to restrict our data processing activities where you consider that personal information is inaccurate; our processing of your personal information is unlawful; where we no longer need the personal information but you require us to keep it to enable you to establish, exercise or defend a legal claim; where you have raised an objection to our use of your personal information
• Request a copy of certain personal information that you have provided to us in a commonly used electronic format.
• Object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal information; and
If you would like to exercise any of your rights please contact us on the contact details provided below.
8. Information gathered on our website
• technical information, such as the internet protocol (IP) address used to connect your device to the internet
• whereabouts you connected to our service
• your internet service provider (ISP)
• Links you click
• the type of device you are using to access our service
9. Updates to our Privacy Statement
We will post changes to this Privacy Notice and indicate the effective date when this Privacy Notice is updated. If we make any material changes to this Privacy Statement, we will notify you by sending an e-mail to the e-mail address you most recently provided us or by posting notice of the changes on this site.
10. Contact details
Questions, comments and requests and complaints regarding this Privacy Notice should be addressed to Data Controller, Sworders, Gatehouse, Little Hadham, Hertfordshire, SG11 2EB or firstname.lastname@example.org
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