Kevin Henry Privacy Notice (last updated on 04/11/2020)
1. Who we are
This Privacy Notice applies to the use and processing of personal information collected by Kevin Henry Ltd. which is a trading name of Sharman Quinney Holdings Ltd. The ICO Registration number of Kevin Henry Ltd is Z2564446.
The phrases “us”, “we” or “our” will mean those businesses which are part of on behalf of and in respect of whom this Privacy Notice is made.
For information concerning the collection, use and processing of personal information by any of our third party business partners or suppliers, please contact our representative with whom you usually deal.
2. Information covered by this Privacy Notice
1. Personal data. This is information, or any combination of separate pieces of information, that could be used to identify you
2. Special categories of personal data. This is information which is classified as sensitive (for example details of your health)
Please read this Privacy Notice carefully. If you have any questions about this notice or our use of your personal data, please contact the Connells Group Data Protection Officer by email to DPO@connellsgroup.co.uk or in writing to Cumbria House, 16-20 Hockliffe Street, Leighton Buzzard, Bedfordshire, LU7 1GN.
Kevin Henry Ltd. is part of the Connells Group, and all data protection matters are managed at Group level. Information concerning the make-up of the Connells Group can be found by visiting http://www.connellsgroup.co.uk/our-group
3. Where we get personal information from
When you enquire or register for products and services provided by Connells Group, we may collect personal information from a variety of sources, including:
· Information we collect directly from you, either through face to face contact, by telephone, email or electronic communications such as messaging or through the internet
· Information we collect when you visit or create an account on our websites
· Information provided to us by third parties
· Information from publically available sources, for example, Land Registry
4 What information we collect
4.1 Information we collect directly from you
Depending on the type of service or product we are discussing, the following are examples of information we may collect directly from you:
Where you ask us to help you with your life, critical illness or income protection insurances, and we collect personal information from you which is of a sensitive nature, we treat this ‘special category’ information in accordance with the additional protection it is given under data protection laws.
We may, during the course of your relationship with us, request additional information from you which is relevant to the provision of specific services.
Any telephone calls either to or from our customer service teams may be recorded for training, monitoring, compliance and security.
4.2 Information we collect when you visit or create an account on our websites
We may collect personal information in connection with your use of our website, such as:
- your name, email address, telephone number and property address when you register for an account or use an online form to arrange a viewing, register for property alerts, request a valuation or lettings consultation, book a mortgage appointment or submit an enquiry
- details included on any enquiry form you submit in relation to property insurance, life, critical illness or income protection, conveyancing or mortgages
- data sent from your browser to our server which may include:
o the time, date and duration of your visit
o the site from which you have come (the referral URL)
o the pages you have visited and
o your IP address
4.3 Information we obtain from other Connells Group companies
For activities related to providing advice on regulated mortgages and non-investment insurance contracts, Sharman Quinney Ltd are an appointed representative of Connells Limited and may share your information within the Group.
Connells Ltd is authorised and regulated by the Financial Conduct Authority; the Financial Services Register number is 302221.
4.4 Information we obtain from online portals
Where you contact by providing your details through online portals such as Rightmove or Zoopla, we will use the details contact you to provide the services you have requested.
4.5 Information we obtain from third parties
Where we are required by law, or for business needs, we will obtain information about you from third parties, but only after we have your agreement to do so. For example (but not limited to) the third parties we may need to contact our credit reference agencies, banks, employers, accountants and solicitors in order to obtain references, undertake identity verification and basic criminal record checks, and validate your income level and financial history.
4.6 Circumstances under which criminal disclosures will be collected
The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences. This is relevant to insurance related activities such as underwriting, claims and fraud management.
When we process any Criminal Disclosures we do so on the basis that it is in the substantial public interest to be able to provide vital insurance products as permitted by UK data protection-related laws and regulations from time to time. Information on Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as us and insurance providers, to enable customers to secure the important insurance protection that they require.
5. Who we share your information with
We may share your information both within the Connells Group of companies and also relevant third party business partners.
Where we engage third party service providers to provide products (such as mortgages, house and contents and family protection insurances) or other business services and operations, we provide them with only the personal information they need to perform the service we request. We contractually require them to securely protect information, and not to use it for any other purpose.
6. How we use your information
We will process the information you provide or we obtain from other sources to provide you with products and services and answer any questions you may have.
The following are examples of how we use the information we collect:
· To process your registration and confirm your identity
· To provide a full range of estate agency services for the sale and purchase of property
· To provide a full lettings service for tenants, prospective tenants and landlords
· To provide property management services
· To arrange survey and valuations
· To arrange mortgages
· To arrange protection insurances
· To provide conveyancing services
· To provide will writing and associated legal services
· To provide property auction services
· To create and manage your on line account
· To process payment for our services
· To protect against and prevent fraud, unauthorised transactions, money laundering, tax evasion, claims, other liabilities and manage risk exposure and agent or franchise quality, integrity, compliance and security of business processes
· To provide, administer and communicate with you about Connells Group products, services, offers, programs and promotions, their issuers, acquirers, retailers and partners
· To compile business directories, including business contact information
· To operate, monitor, evaluate and improve our products, services and websites
· To evaluate your interest in and suitability for employment
6.1 Customer Surveys
From time to time we may provide your information to our customer service agencies for research, survey and analysis purposes so that we can monitor and improve the services we provide. We or our agents and sub-contractors may occasionally contact you including by post, email or telephone to ask you for your feedback and comments on our services.
6.2 Third Party service providers
Where we engage third party service providers to provide products (such as mortgages, house and contents and family protection insurances and utility services) or other business services and operations, we provide them with only the personal information they need to perform the service or provide the product we request. We contractually require them to securely protect the information, and not to use it for any other purpose.
Indicatively - but not limited to - we may disclose your information to the third parties listed below for the purposes listed:
Why we share your personal information
To install for sale or to let boards, to appoint managing agents and building maintenance contractors, to arrange EPC visits, to arrange for contractors to provide safety & statutory tests and to take inventories
To undertake a structural or Homebuyers survey
Firms on our conveyancing panel
To provide home conveyancing services
Our panels of mortgage lenders
To progress your enquiry or application for a residential or buy to let mortgage application
Ageas Insurance Limited
To progress your enquiry or application for buildings and contents insurance
To progress your enquiry or application for a term insurance, critical illness cover and income protection
Rent and Legal insurance providers
To set up landlord insurances, and in the event of a claim
To pursue a claim for breach of tenancy p
To produce marketing packs for the sale of your home
To check your creditworthiness, obtain tenant references and to help prevent fraud and money laundering
TransUnion: To check credit worthiness and obtain references for tenants. For fraud prevention, anti-money laundering checks and identity verification. . Details regarding TransUnion can be found at https://www.transunion.co.uk/legal-information/bureau-privacy-notice).
Credas: For fraud prevention, anti-money laundering checks and identity verification
The Local Council
Payment/collection of Council Tax
Law enforcement bodies including the police, HMRC and local authorities
To comply with court orders or legal obligations
Landlord, tenant or Guarantor
To comply with our legal obligations where we are providing a lettings service
Spark Energy Supply Limited
Where a landlord of property has asked us to arrange the property’s gas and/or electricity supply to be provided by Spark Energy
The parties whose property you have viewed or on whose property you have submitted an offer
For the purposes of ascertaining in a potential fee payable for introduced parties (title, first initial, surname) or for other reasons relating to your viewing or offer on a property;
For payment of utility bills
Debt collection companies
To assist us in recovering any monies which are owed and overdue
Deposit Protection Scheme providers
To provide a Tenancy Deposit Protection Scheme
ARLA Propertymark, a professional body responsible for raising professional standards amongst letting agents
If information relating to you is requested by them in order to protect your interests
The Property Ombudsman
Where they are providing a dispute resolution service in connection with letting services
6.3 Credit scoring
Some of the services provided by third parties may involve an automated decision and/or credit scoring to determine whether we are able to provide a service or product.
Using third parties to undertake searches and collate information on our behalf helps make fair and responsible decisions. When coming to these decisions we and third parties will consider:
· the information provided on the application form
· information about previous account conduct , including any payment arrears and
· official public records information such as fraud record information and insolvency records
Any credit scoring methods used by third parties are regularly tested to ensure they remain fair, effective and unbiased.
For further information about automated decisions or credit scoring, please contact the Connells Group Data Protection Officer by e mail at DPO@connellsgroup.co.uk
7. Lawful basis of processing
Connells Group processes your information under any of the following lawful conditions:
1. Performance of a contract - this is where the collection and processing of your data is necessary for the performance of a contract with you, or in order to take steps at your request prior to entering into a contract
2. Legal obligation - this is where the collection and processing of your data is necessary for compliance with a legal obligation, for example verification of identity and fraud prevention
3. Consent - where we process information under consent we will seek your clear and unambiguous consent before processing your data, for example to receive marketing information from other Connells Group companies
4. Legitimate interests - some information is processed by Connells Group Companies as part of its legitimate interests which include network and information security, opting out of communications, direct marketing, web analytics, updating customer details, lettings, sales, and other core services provided
8. Other situations
We may transfer or otherwise process your personal information:
· As part of the sale of a Connells Group business to another company
· When we have received your instruction to pass the sale of your property to another agent
· To enforce our terms and conditions
· When required by law and/or government authorities
· When requested by the Property Ombudsman Service or any other consumer ombudsman or trade association
9. How long we keep your information for
We will keep your information for as long as is reasonably necessary for the purposes set out in this privacy notice, and to fulfil our legal and regulatory obligations.
For further information about how long we will keep your information, please contact the Connells Group Data Protection Officer by email at DPO@connellsgroup.co.uk
10. When we communicate with you
We will send you service related communications
We may also contact you in order to provide you with information about our products and services which we believe may be of interest to you, and which relate to your needs.
11. How we communicate with you
For service related communications, we will contact you either by e mail or through the post. We may also telephone you or send you SMS messages, which may include automated SMS reminders for viewings.
We give you choices about how we communicate promotions and offers to you.
11.1 By e mail
We only send you promotional e mails if you explicitly select to receive these (you opt in). You can stop receiving promotional email messages from Kevin Henry Ltd. by following the opt-out or unsubscribe instructions provided in any e mail you receive.
11.2 By post
We only send you promotional postal mail if you explicitly select to receive these (you opt in). You can stop receiving promotional postal mail from Kevin Henry Ltd. by following the opt-out or unsubscribe instructions included in those communications.
11.3 Mobile Text Messages
We will only send you promotional text messages if you explicitly select to receive these (you opt in). You can stop receiving promotional text messages from Kevin Henry Ltd. by following the opt-out instructions provided in the text message.
We will only contact you by phone for promotional reasons if you explicitly select to receive these (you opt in). You can opt out of receiving promotional telephone calls from Kevin Henry Ltd. by informing our telephone agents.
12. Your statutory rights
You have a number of rights concerning the personal information we use. These include the right to:
· ask us for access to a copy of your personal information we hold about you
· ask us to correct your personal information
· ask us to delete your personal information
You can delete your online account at any time. This will delete any personal information in your account that we have about you, and it will mean any data about how you’ve used the online account will be made anonymous.
However, deleting your online account will not delete any data you’ve shared with us for reasons that are not connected with your online account. If you wish us to delete your data which is unconnected with your online account, please contact us as described below
· withdraw your consent to use your personal information
Where you have provided consent for our processing of your personal data, you may withdraw that consent at any time. If you withdraw your consent, your previous consent will remain valid in respect of our use of your data in relation to good or service we are still contracted to provide
If you would prefer not to receive information from Connells Group or carefully selected third parties you can opt out by contacting your local Estate Agency Branch.
We will act to respond to your request to stop receiving promotional email, phone, text or postal messages from Connells Group as quickly as is practicable (around 10 working days). We will keep information for record keeping purposes to ensure we fulfil your request not to send particular types of messages.
· ask us to restrict the use of your personal data, including direct marketing
· object to our use of your personal data
· object to an automated decision, including profiling (for example, in terms of credit risk)
· lodge a complaint with the Information Commissioner’s Office, if you object to the way we use your personal information. For more information please go to www.ico.org.uk
If you wish to make a request for access to a copy of your personal data, please write to the Connells Group at Group Legal Services, Bridgegate House, 5 Bridge Place, Lower Bridge Street, Chester CH1 1SA or email DSAR@connellsgroup.co.uk
If you wish to exercise any of your other rights, please write to the Connells Group Data Protection Officer at Connells Group, Cumbria House, 16-20 Hockliffe Street, Leighton Buzzard, Bedfordshire, LU7 1GN or e mail DPO@connellsgroup.co.uk
We will acknowledge your request and let you know what we will need from you to carry out your request. Every effort will be made to respond to or comply with your request as quickly as possible, and we will ensure our systems are updated as soon as is practicable in response to your request.
A cookie is a small file placed on your device when you visit a website that can be understood by the site that issued the cookie. We use the information collected by cookies to remember who you are to log you in and to store your preferences when using a particular site. It may contain a unique identifier to ensure that you are not shown the same information and/or are only shown information you have stated that you are interested in.
A cookie records your preferences when using a particular site, ensuring that you are not shown the same information and/or are only shown information you have stated that you are interested in. In order to use the Site you agree to let cookies be saved as they are an important part of navigation of the Site.
The following are examples of information we may collect:
· Information about your device browser and operating system
· Your internet protocol (IP) address assigned to your internet service
· The web pages you visit on our websites
· Any embedded links you view
We also use the cookie to allow you to log into the MyAccount part of the site. This will store some personal information (e.g. first name, last name, email address, phone number) that may be used should you need to fill out an enquiry form. This information is removed when you log out of MyAccount, or when your session expires.
13.1 Third party cookies used on the site
We use Google Analytics to provide us with information about your visit to our website. We do this in order to help improve our website service to customers.
Their cookies typically store anonymous aggregated information such as whether a visitor has been to the site before, and the time of the current visit.
13.2 Other Technologies
Our security software may use your IP address and browser version to help protect our systems and provide diagnostic information in the case of an issue.
14. How we protect your information
We store your personal information on our computer systems and in our paper records.
We have implemented strict security procedures to ensure that personal information is not damaged, destroyed or misused, and to prevent unauthorised access to your information.
The information that we collect is stored in a secure facility with restricted physical access.
We also use a number of security measures to prevent electronic access.
Where - in line with this Privacy Notice - information is shared with third parties, similar security measures are used to protect your information.
15. Data Transfers
We ourselves do not currently transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information.
If in the future we or our partners need to transfer your information to recipients in other countries we will:
1. perform those transfers in accordance with the requirements of applicable law and subject to appropriate safeguards, and
2. protect the transferred personal information in accordance with this Privacy Notice
16. Children’s privacy
We do not offer any products or services to children. In certain circumstances (for example a mortgage application) we may need to collect the name and date of birth of children from mortgage applicants, and share this with the selected mortgage provider.
17. Links to other websites
Our websites, other electronic portals and documentation may provide links to other websites for your convenience and information. These may operate independently from us and have their own privacy notices or policies, which we strongly suggest you review.
Where linked websites are not owned or controlled by us, we are not responsible for their content or data privacy practices.
18. Our Promise to you
When you provide us with this information, you agree to the collection, use and sharing of your information in accordance with this data privacy notice. Our promise to you is that
· We’ll work with other businesses to put together offers we think you might like
· You are in control of your data
· You can change your privacy settings at any time
· If you don’t think the data is correct tell us and well put it right
· We will keep your data secure
· We also promise to collect, process store and share your data safely and securely and to make sure the businesses we work with do the same
19. Updates to our Privacy Notice
We will occasionally update our Privacy Notice, so we suggest that you review this Notice from time to time. If we make substantial changes to our Privacy Notice, we will endeavour to inform you directly about these changes.
Last Updated: 04/11/2020