Welcome to SafetyLet Ltd’s privacy notice. SafetyLet (also referred to in this notice as “we”, “us”, or “our”) means SafetyLet Ltd, 8 Highview, High Street, Bordon, Hampshire GU35 0AX

In accordance with the General Data Protection Regulation and related UK data protected regulation, SafetyLet is committed to ensuring your personal data is protected, and your privacy is respected.

This privacy notice will advise you as to how we collect, use, handle and disclose your personal data, and tell you about you privacy rights and the protection the law provides. If you require any further information about our data protection practices, please contact us using the details provided below

This version was last updated on 12th June 2018 – This privacy policy is regularly reviewed and it may be amended from time to time, please check back to view the latest version. You may request a hard copy of this privacy notice.

  1. Important information and who we are

Privacy notice purpose

This privacy notice is designed to help you understand how SafetyLet collects and processes your personal data, which includes any data you may provide through your use of this website. For example, when you provide information in connection with a reference, purchase or use a product or service, obtain a quote or make an enquiry. The information that is collected about you will depend on whether you are a tenant, guarantor, agent, private landlord or referee.

It is important that you read this privacy notice, along with any other privacy notice or fair processing notice that we may provide on specific occasions when we collect or process personal data about you, so you are aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

SafetyLet is the controller and responsible for your personal data.

A data compliance manager, who is responsible for overseeing questions in relation to this privacy notice, has been appointed. Should you have any questions regarding this privacy notice, including any requests to exercise your legal rights (see paragraph 9 below), please contact the data compliance manager using the details below:

Name of data compliance manager: Nicholas Grange-Bennett

Email address: Nick@safetylet.co.uk

How to contact us

For any questions or concerns relating to this Privacy Policy or our data protection practices, please contact:

SafetyLet Ltd (company number: 07483716)

8 Highview,

High Street,

Bordon,

Hampshire GU35 0AX

Tel: 01420 475057; email: nick@safetylet.co.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Third-party links

This website may include links to third-party websites, and clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements, as such, we encourage you to read the privacy notice of every website you visit.

  1. The data we collect about you

“Personal data”, or “personal information”, refers to any information about an individual from which that person can be identified (not including anonymous data, where the identity has been removed).

We may collect, use, store and transfer different kinds of personal data about you. In the first instance, this will depend on whether you are a tenant, guarantor, agent, private landlord, or a referee. We have categorised the personal data as follows:

  • Identity Data – Refers primarily to tenants and includes your first name, maiden name, last name, marital status, title, date of birth, gender, job title, income and employment details, references from employers and landlords, details of any County Court Judgments and Individual Voluntary Arrangements or bankruptcies or insolvencies, National Insurance number, and bank details. This may also include whether you smoke, and whether you have any pets.
  • Contact Data – Residential address, previous addresses, email address and telephone numbers.
  • Financial Data – Bank account details.
  • Technical Data – Internet Protocol (IP) address, browser type and version, time zone setting and location, operating system, browser plug-in types and versions.
  • Usage Data – How you use our website, products and services.
  • Marketing and Communications Data – Your marketing preferences and communication preferences.

Aggregated Data – We also collect use and share Aggregated Data (statistical or demographic data for any purpose). This data may be derived from your personal data, but in law it is not considered as personal data. The reason for this is that it does not directly or indirectly reveal your identity. However, if we choose to combine aggregated data with your personal data (meaning it can directly or indirectly identify you), we treat this combined data as personal data which will be used in accordance with this privacy notice.

We do not knowingly or actively collect any Special Categories of Personal Data about you (this includes details about your religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we knowingly or actively collect any information about criminal convictions and offences.

It should be noted, that whilst we do not knowingly or actively collect such data. that letting agents and landlords do have the ability to request additional, bespoke information through dynamic forms, over which we have no control. As such, whilst we endeavour to prevent collection of Special Categories of Personal Data or criminal convictions, there is a possibility that letting agents or landlords will request this type of information about a tenant or guarantor without our knowledge. In these circumstances, we will take all reasonable steps to delete the Special Categories of Personal Data or information about criminal convictions, where possible.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you or, in the case of tenants, our contract with the agent of private landlord and you fail to provide that data when requested, we may not be able to perform the services or contract we have or are trying to enter into with you. For example, we will not be able to produce a reference report if a tenant or guarantor fails to provide the information required to carry out the reference. This will likely mean that you cannot rent the property.

Please note that if you are a referee, there is no requirement for you to provide a reference if you do not wish to do so.  However, please note that if you refuse, this may be noted on the final reference report.

  1. How your personal data is collected

There are different methods that we use to collect data from and about you. These include:

  • Direct interaction – Through filling in forms on this website or by corresponding with us by post, phone, email or otherwise, you may give us you identity, contact and financial data. This includes personal data you provide when you:
    • Submit information for referencing;
    • Apply for/purchase our products or services;
    • Request marketing to be sent to you;
    • Make an enquiry/request a quote;
    • Provide us with feedback
  • Automated technology or interaction – Whilst interacting with our website we may collect technical data about your equipment, browsing actions and patterns. This personal data is collected by using cookies, server logs and other similar technologies.
  • Third party or publicly available sources – We may receive personal data about you from various third parties, such as:
    • Technical Data from analytics providers; advertising networks; and search information providers.
    • Contact, Financial and Transaction Data from providers of technical and payment services.
    • Identity and Contact Data from data brokers.
    • Identity and Contact Data from publicly available sources (i.e. Companies House and the Electoral Register).
    • Identity and Contact Data on tenants/guarantors from referees (i.e. Employers or former landlords).
    • Identity, Contact and Financial Data from credit referencing agencies.
  1. How we use your personal data

We will only use your personal data when law allows us to, most commonly in the following circumstances:

  • Performance of the contract we have entered into with you, or are about to enter into.
  • Where necessary for our legitimate interests or those of a third party (i.e. the agent or private landlord) and your interests and fundamental rights do not override those interests.
  • To comply with a legal or regulatory obligation.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Please note that we may process your personal data for more than one lawful ground, and this depends on the specific purpose for which we are using your data and whether you are a tenant, guarantor, letting agent, private landlord or referee. If you require further details about the specific legal ground we are relying on to process your personal data, please contact us.

Purpose/Activity Type of data Lawful basis for processing (including basis of legitimate interest)
To undertake a credit check and/or a full reference.

To produce a reference report which includes using your personal data to contact, where applicable, your current and former landlords, your current and former employer, other referees and credit reference agencies)

(This applies to tenants and guarantors only)

–       Identity

–       Contact

Necessary for the legitimate interests of the agent or private landlord who instructs us (or such other lawful basis as the agent or private landlord shall determine).
To register you as a new client

(This applies to agents and private landlords only)

–       Identity

–       Contact

Performance of a contract with you, and necessary for our legitimate interests.
To contact you to obtain a reference or other information about an applicant tenant or guarantor to compile our reference report

(This only applies to referees)

–       Identity

–       Contact

Necessary for our legitimate interests and the legitimate interests of the agent or private landlord who instructs us (or such other lawful basis as the agent or private landlord shall determine)
To process your order and provide the services including: managing payments, fees and charges, and collecting and recovering money owed to us.

 

–       Identity

–       Contact

–       Financial

–       Transaction

–       Marketing and Communications

Performance of a contract with you

Necessary for our legitimate interests, i.e. recovering debts due to us.

To manage our relationship with you which will include:

–       Notifying you about any changes to our terms or privacy policy.

–       Asking you to leave a review

–       Responding to an enquiry or request for a quote.

 

–       Identity

–       Contact

–       Marketing and Communications

Performance of a contract with you

Necessary to comply with a legal obligation

Necessary for our legitimate interests – Keeping our records up to date and to study how customers use our products/services.

To administer and protect our business and this website. Including: troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data. –       Identity

–       Contact

–       Financial

–       Transaction

–       Technical

–       Usage

–       Marketing and Communications

Necessary to comply with a legal obligation

Necessary for our legitimate interests – running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise.

To use data analytics to improve our website, products and services, marketing, customer relationships and experiences –       Identity

–       Contact

–       Financial

–       Transaction

–       Technical

–       Usage

–       Marketing and Communications

Necessary for our legitimate interests – defining types of customers for our products and services, keeping our website updated and relevant, to developing our business and informing our marketing strategy.
To make suggestions and recommendations to you about goods and/or services that may be of interest to you (including third party goods and/or services) –       Identity

–       Contact

–       Technical

–       Usage

 

Necessary for our legitimate interests – developing our products and services to grow our business.

Consent

 

 

Marketing

We aim to provide you with choices regarding certain personal data uses, especially around marketing and advertising.

Therefore, we may use your Identity, Contact, Transaction, Technical and Usage Data to form a view on what we think you may want/need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

Letting agents and private landlords: From time to time we may contact you regarding other products and services that we offer, along with updates and news on SafetyLet. We have a legitimate interest in doing so, namely for the commercial benefit of developing and expanding our business. In these circumstances, we will not ask for your consent, but you have the right to opt-out of marketing messages at any time.

Referees: We will not use your details for marketing purposes unless with your express prior opt-in consent.

Opting out

Regardless of whether you are a tenant, guarantor, agent, private landlord or referee, you can ask us or third parties to stop sending you marketing messages by contacting us at any time.

Where you opt-out of receiving these marketing messages, this will not apply to any personal data that has been provided to us as a result of a product/service purchase or other transactions with us. For instance, we will continue to contact agents and private landlords regarding the reference report that we have been instructed to prepare.

Change of purpose

Your personal data will only be used for the purpose for which we collected it, unless we reasonably consider that we need to use it for another reason (as long as this is compatible with the original purpose). If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. Sharing of personal data

We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above:

Tenants and guarantors

  • Current and former employers and landlords, and other third parties, for the purpose of obtaining information to compile a reference report.
  • Letting agents and private landlords, for the purpose of sending a final reference report on you.
  • Credit referencing agents who act as processors or joint controllers, who provide credit referencing services.

Referees

  • If you have provided a reference and this is included in the final report, this may be shared with the letting agent or private landlord.
  • If we receive a subject access request from the applicant tenant or guarantor, we are required to disclose both the final report and the reference you have provided.

Agents and private landlords

  • If we receive a subject access request from applicant tenants or guarantors, and we are required to disclose the final reference report and full copies of any references provided by the referees (i.e. employers and landlords). Please note that we will not disclose credit references. We may also share your contact details with the applicant tenant or guarantor during the course of obtaining necessary information them in order to produce the final reference report.

All

  • Service providers acting as processers who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including – bankers, lawyers, auditors and insurers who provide consultancy, legal, accounting, banking and insurance services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
  • The police or other governmental bodies where we are required to disclose information under any applicable data protection legislation.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change does happen to our business, the new owners may use your personal data in the same way as set out in this privacy notice.

All third parties are required to respect the security of your personal data, and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1. International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

  1. How long we keep information about you

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purpose of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data. Along with, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we are able to achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available on request by contacting us.

  1. Data security

Appropriate security measures are in place to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Furthermore, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They are subject to a duty of confidentiality, and will only process your personal data upon our request.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data: You have the right of access to personal data we hold about you to check that we are lawfully processing it. To request a copy of this, you must make a subject access request to us in writing.

Request correction of your personal data: This enables you to have any incomplete or inaccurate data we hold about you corrected, although, we may need to verify the accuracy of the new data provided.

Request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. However, please note that we may not always be able to comply with your request of erasure for specific legal reasons. If applicable, these will be notified to you at the time of your request.

Object to processing of your personal data: You may object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. If we are processing your data for direct marketing purposes, you also have the right to object. In some cases, we may determine that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

Request restriction of processing your personal data: This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • (a) if you require us to establish the data’s accuracy;
  • (b) where our use of the data is unlawful, but you do not wish for us to erase it;
  • (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal data: If requested, we will provide to you, or a third party you have chosen, your personal data. This will be in a structured, commonly used, machine readable format. Please note that this right is only afforded to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent: You may withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing which has been carried out before you withdraw your consent. We may not be able to provide certain products or services to you if you withdraw your consent, we will advise you if this is the case at the time you withdraw.

If you wish to exercise any of the rights set out above, please contact your letting agent or landlord in the first instance.