Types of information collected

• Given names (including first, middle, surname and any previous names)
• Date of birth
• Present and previous address details
• Telephone numbers
• Email addresses
• Gender
• Ethnicity
• Nationality
• NI Number
• Marital status
• Residential status
• Bank details
• Names of dependants
• Dependants dates of birth
• Personal credit/debt details
• Bank details
• Bank/credit card statements
• Prior/current Landlord details
• Prior/current employer details
• Accounts details
• Salary details/payslips
• Insurance details
• Proof of Identity
• Proof of residency
• IP Addresses

Methods of collection

Such information will generally be collected directly via the use of any of our standard forms, over the internet, via email, in branch or through telephone conversations with you. We may also collect information though our affiliates and suppliers. In addition you may choose to submit information directly to us via several other methods including;

• through our website and those of our affiliates
• in response to marketing and other communications
• through social media
• by signing up for a product or service
• through participation in an offer, programme or promotion
• in connection with an actual or potential business or employment relationship with us

You may also agree to third parties disclosing information about you to us that those third parties have collected.

Purposes of collection

Generally we collect, use and hold your information for the purposes of;

• Provide, administer and communicate about products, services, offers, programmes and promotions and those of our affiliates
• Operate, monitor, evaluate and improve our products, services, website and business policies
• Assessing applications for and the provision of products and services
• Conducting business; enquiries, processing payments/transactions, credit checks, referencing, complaints, auditing, compliance, dispute resolution, quality control and meeting contractual obligations
• Protect against and prevent fraud, money laundering, tax evasion and manage risk exposure
• Evaluate your interest in employment and contact you regarding possible employment opportunities, monitoring and managing staff, training and development, administration and assessment
• Compliance with our policies, industry standards, legal and regulatory obligations and good practise
• Other legal rights as may be required by applicable laws and regulations or requested by judicial process or governmental agency having or claiming jurisdiction over Platinum Properties or its affiliates

Lawful basis of processing

We must process personal data fairly and lawfully in accordance with individuals’ rights under the first Principal. If we cannot apply a lawful basis our processing does not conform to the first principal and will be unlawful. Data subjects have the right to have any data unlawfully processed erased. Platinum Properties process your information under the following lawful basis; Contract: The processing of the data is necessarily to fulfil or prepare a contract Legal Obligation: We have a legal obligation to process the data Legitimate Interest: The processing of data is necessary for our legitimate interests such as due diligence, marketing, monitoring, updating and maintaining details Consent: We hold recent, clear, explicit and defined consent to process your data Public Interest: Processing necessary to carry out a public function, a task of public interest or the function has a clear basis in law

Information we share

We do not sell or otherwise disclose personal information we collect about you, except as described in this policy or as indicated via the consent process at the time the data is collected. We share the information we collect, but do not limit it to;

• vetted affiliates and partners for business facilitation to provide required services
• formally contracted service providers to perform services on our behalf (Saffron Insurance, NWBIB, PayProp, Acquaint, Rightmove, On The Market, Voipfone, Tenant Shop and data hosting applications and other service providers)
• referencing and credit checking organisations (UK Tenant Data)
• insurance companies
• landlords

We contractually require these service providers to safeguard the privacy and security of personal information they process on our behalf and authorise them to use or disclose the information only as necessary to perform services on our behalf or comply with legal requirements

• local authorities
• utility providers
• regulatory bodies (HMRC, TPO, etc.)
• prospective employers/landlords and others requesting references via your written consent

Additionally we may share information about you if require legally, to prevent harm or financial/reputation loss, investigation of fraudulent or illegal activities. On websites features can be accessed where we partner with other entities that are not affiliated with Platinum Properties. These include social networking, geo-location tools, etc. These are operated by third parties who may use or share personal information in accordance with their own privacy policies. It is recommended that you review the third parties privacy policies if you use the relevant features. Platinum Properties reserve the right to transfer your information in the event of a sale or transfer (wholly or partially) of our business or assets, with reasonable efforts for the acquirer to protect/use your information. You can exercise your rights to contact the acquiring entity with any questions concerning the protection and processing of your information.

How long do we keep your information for

We will keep information for a reasonable amount of time in order to perform the purposes listed above, but not for longer than is necessary. What is necessary will depend upon the circumstances of each case taking into account the reasons that the personal data was obtained. We generally keep personal information for 7 years after last contact with you. However Platinum Properties reserves the right to keep information for longer if we feel that this is in the legitimate interest of Platinum Properties.

Your rights and choices

We will ensure that the persona data we process is accurate, adequate, relevant and not excessive given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purposes unless we have sought your agreement or it would be reasonably expected. Your rights regarding the personal information we maintain about you enable you to exercise choices about what personal information we collect from you, how we use that information and how we communicate with you. Right of access You may have the right to;

• obtain confirmation that we hold personal information about you
• request access to and receive information about the personal information we maintain about you
• receive copies of the personal information we maintain about you

The right to access personal information may be legally limited in some circumstances. Right to rectification If you feel that the information we hold about you is incorrect or inaccurate you can log into your personal portal to update your information and preferences or contact us outlining what information you feel requires rectification. Where possible information will be corrected within one month of your request. If we are unable to correct your personal information, we will provide you with written notice that sets out those reasons. Right to erasure If you would like us to delete or anonymise information we hold about you, you can contact us outlining what information you would like deleted or anonymised. Right to restrict If you would like us to restrict, block or otherwise suppress the processing of personal data, you can contact us outlining how you wish us to restrict this. Please note that we are permitted to store personal data that has been restricted, but cannot process it further, we must retain enough data to ensure the right to restriction is respected. Right to object If you would like to object to any processing of your information by Platinum Properties please contact us to outline your objections. We must cease processing unless we have legitimate grounds for processing which override the interests, rights and freedoms of the individual or the processing relates to the establishment, exercise or defence of legal claims. Rights in relation to automated decision making and profiling We may only carry out automated profiling or decision making that has a legal or similarly significant effect on an individual when it is necessary for the entry into of performance of a contract, based on your consent or otherwise authorised by law. You retain your right to object to automated processing and profiling of your information, have the rationale behind automated decision making explained to you and request human intervention. To update your preferences, access, update or correct your information please log in to your online portal or to remove your information from our mailing lists or submit a request to access, update, correct or delete your personal information please contact as specified in the ‘How to contact us’ section of this policy. Withdrawal of consent If we obtain your information via your consent you have the right to withdraw any consent you previously provided to us. The right to consent removal may be legally limited in some circumstances and you will be informed appropriately.

How to Contact Us, Complaints and Feedback

If we fall short of your expectations in processing your personal information, you wish to contact us to make a complaint about a breach of your personal information, applicable privacy laws/principals or raise a concern about Platinum Properties privacy practices, would like access to and/or to update information or preferences you provided to us you can contact Maria Morgan-Geen, the Data Protection Administrator, as follows; Email: maria@platinumpropertiesely.co.uk Or write to us as follows; Maria Morgan-Geen, Platinum Properties, First Floor, Unit 111 Lancaster Way Business Park, Witchford CB6 3NX. To assist us in responding to your request please give full details of the issue. We attempt to review and respond to all complaints within a reasonable time. If we cannot, for lawful reasons, complete your request we will explain this to you to the extent that we lawfully can.

How We Protect Your Personal Information

The security of your personal information is important and Platinum Properties and our employees are committed to protecting the information we collect. We maintain administrative, technical and physical safeguards that are designed to protect the personal information you provide or we collect, against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use. We use SSL encryption on our website from which we can transfer certain personal information.

• Where data is stored on printed medium it will be kept in a secure place where unauthorised personnel cannot access it. Printed data will be shredded once no longer required.
• Data stored on a computer will be password protected and passwords changed regularly.
• Data stored on memory sticks or other portable devices must be encrypted or password protected and locked away securely when not in use.
• Servers containing personal data must be kept in a secure location, away from general office space.
• All portable devices will have a remote shutdown and data removal facility.
• All servers containing sensitive data are password protected and protected by security software.
• Personal devices must not be used for downloading and storing of data.