Privacy Notice and Policy – Using Your Personal Information                                     

Intended purposes for processing

In order to provide you with our services, for the administration of our files and records and if you agree, to enable us to send you information about other services Hough Gould offers, we will be processing (using and storing) your personal data, which includes information that identifies you, such as your name, address, job title and contact information. In some cases we may also process special categories of personal data, such as your health records, racial or ethnic origins, political or religious beliefs and/or criminal conviction and offence records.

Lawful bases for processing

We may be required to process your personal data in order to comply with our obligations under legislation such as the Proceeds of Crime Act 2002, the Money Laundering Regulations 2017, the Criminal Finances Act 2017, the Foreign Account Tax Compliance Act 2010 (for clients with US ‘person’ status) and under common law. We may, on occasion, be required to share your personal data with the relevant authorities. This processing of your personal data is to comply with the law and we would be unable to act for you without doing so.

In addition, we may process your personal data on the basis that we have a contract with you. Alternatively, in some instances we may have a legitimate interest in processing your personal data.

Whenever we are processing special categories of personal data and/or criminal conviction and offence records, we will only use that data to deliver the services you have instructed us to provide.

All your personal data will be processed and erased, in accordance with this Privacy Policy.  Our Data Protection Officer David Hough who is based at Hough Gould The Estate Office Park Farm Oddingley Droitwich WR9 7ND.

Recipients of your personal data

In addition to our firm we may, when required and necessary, share your personal data with other organisations. Depending on the work we are undertaking for you the other organisations may include:

• Our firm’s ‘data processors’ who are contractors from whom we obtain operational services including IT services and support, secure document storage and shredding, case and practice management software.
• Other ‘data controllers’ that provide professional or commercial services, such as legal counsel, solicitors, accountants, medical practitioners, other surveyors and estate and letting agents, financial advisors and actuaries.
• Experts that you and we agree are necessary to assist us to progress your matter.

• Providers of insurance, financial and banking services to you and/or to our firm.
• HMRC, HM Courts & Tribunals Service, HM Land Registry, Councils and other national and local government bodies.
• The RICS, the Information Commissioner’s Office (ICO) and organisations involved with the preparation, assessment and certification of quality standards for which our firm is seeking or maintaining accreditation.
• If you agree, to organisations providing marketing services to our firm.

All of the above are located in the UK.

Marketing

We should like to send you information about our services or properties listed which we believe may be of interest to you. We may contact you by mail, telephone, email or text. If you wish to opt-out of receiving marketing information from us, in which case please either write to our Data Protection Officer, whose name and address are above, or send an email to [email protected].

Website data

Similar to many other websites, our website utilises log files. These log files record data from visitors to our website.  The data collected can include things such as your: internet protocol (IP) address, internet service provider (ISP), entry and exit pages, platform type, date/time stamp, browser type, and number of clicks.  Please note that this data is non-personal and cannot be used to personally identify you. It is used to analyse trends, track user’s movements on our website (to see which pages are getting most clicks) and gather broad demographic information.

The Hough Gould website uses ‘cookies’, in the same way as most other websites. These cookies can save data including website visitors’ preferences, and the pages on our website that you access. Visitors’ experience on the website can be optimised, by employing cookies, that can customise our website content based on each visitor’s browser type and any other relevant information.

CCTV

We may use Closed Circuit Television at any of our offices or managed estates for the express purposes of crime prevention and monitoring the safety and security of employees, clients, visitors and any vehicles using car parks or accessing any of our buildings. Recordings will be retained for three months days then recorded over unless required as evidence following any alleged crime or accident.

Your rights in relation to your personal data

You have the right of access to your personal data and to verify the lawfulness of the processing. If you would like a copy of your personal data that we are processing please contact our Data Protection Officer, whose name and address are above. Kindly note, we will need to verify your identity before responding to your request. Normally we make no charge for doing this and will endeavour to send it to you within 1 month of receipt of your request. If you notice that any of the information we send you is inaccurate or incomplete, please tell us and we will rectify it promptly.

If you are dissatisfied with our response you may complain to a supervisory authority which, in the UK, is the ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. The ICO’s website is at https://ico.org.uk/. We would, however, appreciate the chance to deal with any concerns before you approach the ICO so, in the first instance, please contact our Data Protection Officer using the contact details above. If you are based outside the UK you may also have the right to submit a complaint to the supervisory authority in your jurisdiction. There may be judicial remedies available to you, as well.

Erasure of personal data

We will not erase or restrict the processing of your personal data during the period in which we have a legal obligation to retain that data under the applicable Act, Regulations or in common law.

Where we obtained your personal data to fulfil our contractual obligations to you, or if we have a legitimate interest for processing your personal data for the exercise or defence of legal claims, we will erase that data as soon as is reasonably practicable after it is no longer necessary to retain it in relation to the purpose for which it was originally collected.

Due to our RICS Regulated status, for clients who have entered into a contract with Hough Gould, we will retain all files and documents archived for a reasonable period, which will, in any event, be not less than 6 years after completion or termination of the service(s). After this period all personal data is destroyed or deleted.

Security

We are committed to ensuring that all information we hold about you is secure. In order to prevent unauthorised access or disclosure we have implemented appropriate physical, electronic and managerial procedures to safeguard and protect that information.

Other data controller recipients of your personal data are each responsible for implementing appropriate physical, electronic and managerial procedures to safeguard and protect that information and to keep it secure.

Data processor recipients of your personal data have provided sufficient guarantees that they have implemented measures to ensure compliance with the UK GDPR and to protect your rights.

Transferring your personal data

We will not transfer your personal data overseas unless it is to a country covered by UK adequacy regulations, or an appropriate safeguard is in place between the parties to the transfer, or the transfer is covered by one of the exceptions in Article 49 of the UK GDPR.

Personal data concerning a third party

You should only give us personal data about someone else with their permission. Where you provide us with personal data about someone else, or someone discloses to us personal data about you, it may be added to the personal data we already hold and may be used in the ways described in this Privacy Policy.