HOUGH GOULD

Privacy Notice

About this Privacy Notice

This Privacy Notice explains how Hough Gould collects, uses, stores and protects your personal information when providing professional surveying, estate agency, property management and related professional services.

Hough Gould is committed to protecting your privacy and handling your personal information fairly, lawfully and transparently in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and other applicable legislation.

Who We Are

Hough Gould is the data controller for the personal information we collect.

If you have any questions regarding this Privacy Notice or how we process your personal information, please contact:

Data Protection Lead

David Hough

Hough Gould

Starlings

Prospect Hill

Slapton

Kingsbridge

Devon

TQ7 2PT

Email: [email protected]

The Information We Collect

Depending upon the services we provide, we may collect:

• Name
• Address
• Email address
• Telephone numbers
• Date of birth
• Employment details
• Property ownership information
• Financial information
• Bank details
• Identification documents
• Proof of address
• Company information
• Director and shareholder information
• Ultimate Beneficial Owner (UBO) information
• Information required to comply with anti-money laundering legislation.

Where necessary, we may also process special category personal data or criminal offence data where required to provide our professional services or comply with legal obligations.

How We Use Your Information

We use your information to:

• provide the professional services you have instructed us to carry out;
• administer our client files;
• communicate with you regarding your instructions;
• comply with legal and regulatory obligations;
• undertake client due diligence;
• verify identity;
• undertake anti-money laundering checks;
• carry out sanctions screening;
• identify Politically Exposed Persons (PEPs);
• prevent fraud and financial crime;
• establish, exercise or defend legal claims;
• maintain professional standards;
• improve our services.

Our Lawful Basis for Processing

Depending upon the work we undertake, we process your personal information under one or more of the following lawful bases:

Performance of a Contract

Processing necessary to provide the services you have instructed us to carry out.

Legal Obligation

Processing necessary to comply with legal obligations including, but not limited to:

• Proceeds of Crime Act 2002
• Terrorism Act 2000
• Criminal Finances Act 2017
• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended)
• applicable financial sanctions legislation
• taxation legislation
• professional regulatory obligations.

Legitimate Interests

Where necessary for our legitimate business interests, provided these do not override your rights and freedoms.

Examples include:

• managing our business;
• recovering unpaid fees;
• maintaining professional records;
• preventing fraud;
• defending legal claims.

Consent

Where consent is required (for example marketing communications), you may withdraw your consent at any time.

Special Category Data

Where necessary, we may process special category personal data or criminal offence data where:

• required to provide our services;
• required by law;
• necessary to establish, exercise or defend legal claims; or
• another condition under Article 9 UK GDPR and Schedule 1 Data Protection Act 2018 applies.

Anti-Money Laundering Checks

As a RICS Regulated Firm we are legally required to carry out identity verification and anti-money laundering checks before acting for many clients.

This may include:

• verification of identity;
• verification of address;
• source of funds enquiries;
• source of wealth enquiries;
• sanctions screening;
• Politically Exposed Person (PEP) screening;
• beneficial ownership checks;
• electronic identity verification;
• ongoing monitoring where appropriate.

Where required by law we may report information to the appropriate authorities without notifying you.

 

Who We Share Your Information With

Where appropriate we may share information with:

• solicitors;
• barristers;
• accountants;
• lenders;
• banks;
• mortgage brokers;
• estate agents;
• letting agents;
• surveyors;
• managing agents;
• local authorities;
• HM Land Registry;
• HM Revenue & Customs;
• HM Courts & Tribunals Service;
• professional advisers;
• insurers;
• IT service providers;
• secure document storage providers;
• cloud software providers;
• electronic identity verification providers;
• anti-money laundering screening providers;
• payment providers;
• our professional regulators including RICS;
• the Information Commissioner’s Office;
• law enforcement agencies where required by law.

All organisations receiving your information are expected to process it securely and lawfully.

Marketing

Where we have your consent, or where otherwise permitted by law, we may send information regarding our services or properties which we believe may be of interest.

You may opt out at any time by:

• emailing [email protected]; or
• writing to our Data Protection Lead.

Website

When you visit our website we may collect technical information including:

• IP address;
• browser type;
• operating system;
• pages visited;
• dates and times of access;
• referring websites.

Some of this information may constitute personal data under UK GDPR.

We use cookies to improve your experience and analyse website usage.

Further information is available in our Cookie Policy.

CCTV

CCTV operates at certain Hough Gould offices and managed properties for the purposes of:

• crime prevention;
• public safety;
• protection of staff;
• protection of visitors;
• protection of property.

Recordings are normally retained for three months before being automatically overwritten unless required for the investigation of an incident, accident or criminal offence.

International Transfers

We do not routinely transfer your personal information outside the United Kingdom.

Where an international transfer is necessary, we will only do so where:

• the UK Government has made an adequacy decision;
• appropriate safeguards such as the UK International Data Transfer Agreement (IDTA) or approved Standard Contractual Clauses are in place; or
• another lawful exemption under UK GDPR applies.

How Long We Keep Information

We retain personal information only for as long as necessary.

For most client matters we retain files for a minimum of six years following completion or termination of our services.

Longer retention periods may apply where required by law, professional obligations, limitation periods or where necessary to establish, exercise or defend legal claims.

Information is securely destroyed when no longer required.

Your Rights

You have the right to:

• request access to your personal information;
• request correction of inaccurate information;
• request erasure where applicable;
• request restriction of processing;
• object to processing in certain circumstances;
• request data portability where applicable;
• withdraw consent where processing relies on consent;
• complain to the Information Commissioner’s Office.

Requests should be made to our Data Protection Lead.

Complaints

If you are unhappy with how we handle your personal information, please contact us first so we can try to resolve your concerns.

You also have the right to complain to the Information Commissioner’s Office:

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Website: https://ico.org.uk

Security

We maintain appropriate technical and organisational security measures to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

Access to personal information is restricted to those who require it for legitimate business purposes.

Information About Other People

If you provide us with personal information relating to another individual, you should ensure that you have their authority to do so and that they understand how their information will be used in accordance with this Privacy Notice.