Who we are – Thoroughbred Property who we refer to as TP hereafter.
We, TP act to ensure your privacy is protected and this document aims to describe how, when and what personal data is collected and how we may use this information.
1. Outline information
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 complaints and how to contact us
This is any information that identifies you, personally e.g. Your name, address, contact details (phone, email etc.) that would enable anyone to identify you personally.
There are other types of information considered to be ‘Special Data’ e.g. Ethnic origin, religious beliefs, sexual orientation. TP does not collect or store any data in this category.
Information TP may collect
We will regularly collect your full name and contact details (such as phone number, email address and postal address) usually from the point of first contact with us.
If you are a client and we are providing a service to you, we may legally be required to collect information relating to your identity, which will be at least one form of photographic identification (such as a passport) and documentation with proof of your place of residence (such as a recent utility bill).
Depending on the service that we provide to you (or on your behalf) we may also collect additional personal information as detailed below;
Renting Through Thoroughbred Property
Information of your requirements, so that we can find a property that is suitable for your needs.
All legally required information that may be required to allow TP to carry out ‘Right to Rent’ checks.
Further information reasonably required to allow referencing procedures.
Further information as may be required to be able to act in an emergency on your behalf.
TP will only use your personal information to fulfil our contract to you as a client in managing the rented property.
For TP legitimate business interests. This may include sending you marketing information to promote our brand or services, sending you details of properties that may meet your requirements, sharing of property market news/information that you may find of interest, contacting you to ensure our information is accurate and up to date. You have the right to opt out of any or all communication at any time unless our actions are necessary to fulfil our contractual obligations to you, as a client.
Processing your information to ensure our legal compliance e.g. Anti money laundering checks and right to rent checks.
Processing that is necessary to maintain the security of your data.
When renting through Thoroughbred Property your information may be shared with third party referencing agencies.
With any governmental enforcement body where disclosure of such information is a legal requirement i.e. To comply with Anti Money Laundering requirements, the avoidance of fraud and assessment of ‘Right to Rent’.
Other uses of your personal information
If we sell any part of our business your details may be disclosed to our advisers and to our prospective purchasers and their advisers. If this occurs the new owners of the business will only be permitted to use your information in the same or similar way as set out in this privacy notice.
We will share personal information with our regulators, governmental or quasi-governmental organisations, 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 Control Esc – IT systems providers and IT contractors as well as third party referencing agencies for the purposes of the prevention and detection of crime and protection of our client(s) interests. This currently includes Microsoft for the purpose of email services and WordPress for website provision.
We may share your personal information with any person working with TP on a need to know basis to ensure we are able to perform our obligations to you.
We will hold your personal information on our client management systems.
Keeping your information secure
The security of information is very important to us and we have measures in place which are designed to prevent unauthorised access to your personal information including but not limited to:
Our client files are stored on our secure client management systems (currently Control Esc). 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. Data is stored on Control Esc’s cloud based servers located within the EU.
Hard copy documentation is stored in places which are locked outside of usual business hours.
All data is hosted in EU datacentres which have systems and protections in place to protect against both unauthorised access, and other external factors that could cause damage to your personal data. There are strict access requirements in place and access is restricted to those absolutely necessary.
How long do we keep your 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. Also, where we have legitimate business interest in marketing our services to potential future clients, your data will be retained unless you choose to opt out of receiving such marketing.
Your personal information rights
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 the following circumstances:
If TP is continuing to process personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected
If TP is relying on consent as the legal basis for processing and you withdraw consent
If TP is relying on legitimate business interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us continue with the processing
If the personal information has been processed unlawfully (i.e. in breach of the requirements of prevailing data protection legislation)
If it is necessary to delete the personal information to comply with a legal obligation
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. This right relates to personal information that you have provided to us that we need in order to perform our agreement with you and personal information where we are relying on consent to process your personal information
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 firstname.lastname@example.org
Complaints and who to contact
If you have any complaints about the way we use your personal information please contact the Data Protection Officer at email@example.com who will try to resolve the issue. If we cannot resolve any issue, you have the right to complain to the data protection authority in your country (the Information Commissioner in the UK). If you need more information about how to contact your local data protection authority please let us know by contacting firstname.lastname@example.org