Privacy Notice and Data Protection Policy

Evenmore Properties Ltd (trading as Evenmore Properties) is committed to protecting and respecting your privacy. We are registered with the Information Commissioners Office. Our registration number is Z2615569. The Data Protection Officer is Mr Wayne Broxson.

As an organisation, we abide by the eight data protection principles outlined within the General Data Protection Regulations 2018:

  • Your right to be informed
  • Your right of access
  • Your right to rectification
  • Your right to erasure
  • Your right to restrict processing
  • Your right to data portability
  • Your right to object
  • Your right not to be subject to automated decision-making including profiling

How we abide by these principles are detailed throughout this document.

We ensure that all third parties we work with adhere to the same principles when handling your data which has been shared by us.

How we protect personal information 
The security of your personal information is very important, and we are committed to protecting the information we collect. We maintain administrative, technical and physical safeguards designed to protect the personal information you provide, or we collect against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.

We store personal information only for as long as it is necessary for the fulfilment of the purpose for which the personal information was collected, unless otherwise required or authorised by applicable law. We take measures to destroy or permanently de-identify personal information if required by law or if the personal information is no longer required for the purpose for which we collected it. Further details are outlined within this privacy policy.

Types of information 
Types of information that may be collected by us or a third party (e.g. referencing provider – Van Mildert) on our behalf:

  • Age 
  • Title 
  • Full name 
  • Date of birth
  • Other name(s) may be known by
  • Marital status 
  • Current and previous addresses
  • Alternative contact address
  • Landline/mobile phone contact details
  • Email address
  • National insurance number
  • Nationality 
  • Immigration / residential status 
  • Employment status 
  • Housing history 
  • Household type 
  • Economic status 
  • Income details – wages and/or benefits 
  • Bank statements
  • Allowances, benefits and grants 
  • Unspent criminal convictions 
  • Third-party authority and information (name, address, date of birth, contact details, nature of relationship to tenant)
  • Photographic ID
  • Proof of address
  • Self Employment accounts 
  • Credit history 
  • Land Registry title deeds
  • Electronic money laundering checks

We may obtain information about you from a third party, which may include information from benefit services such as the local housing benefit service. Information obtained may include:

  • Housing benefit claim number
  • Housing benefit entitlement notification letters
  • Benefit entitlement information

Methods of collection
In the general conduct of business, we collect information relevant to the services being sought across the range of services we offer. Such information will generally be collected directly via the use of any of our standard forms, over the internet, via email, in our branch, or through a telephone conversation with you. In addition, you may choose to submit information directly to us via several methods including:

Through our website

In response to marketing or other communications

Through social media

By signing up to one of our products or services

Through participation in an offer, programme or promotion 

In connection with an actual or potential business or employment relationship with us

Purposes of collection
Generally, we will collect, process and hold your information for the purposes of: 

  • Granting a tenancy (pre-tenancy and tenancy agreement) (contractual necessity)
  • Entering into a letting contract with a Landlord (contractual necessity)
  • Entering into a sales contract with a Vendor (contractual necessity)
  • Assessing applications for and providing our products / services 
  • Conducting business, developing relationships with us and our affiliates 
  • Process payments / transactions including: accounting, authorisation, clearing, chargebacks, auditing, billing, reconciliation, collection, complaints,
  • enquiries, credit checks and related dispute resolution activities 
  • Protect against and prevent fraud, unauthorised transactions, money laundering, tax evasion, claims, other liabilities and manage risk exposure
  • and agent /franchise quality, integrity, compliance and security of business processes 
  • Create and manage any accounts you may have with us 
  • Provide, administer and communicate with you about our products, services, offers, programs and promotions, their issuers, acquirers, retailersand partners. 
  • Compile business directories, including business contact information (contractors)
  • Operate, monitor, evaluate and improve our products, services, websites, mobile applications, other digital assets and business. 
  • Developing new products and services 
  • Managing communications, assess effectiveness and optimisation of advertising 
  • Functionality of our websites, mobile applications and other digital assets 
  • Evaluate your interest in employment and contact you regarding possible employment opportunities 
  • Enforce our “Terms of Use”, other legal rights as may be required by applicable laws and regulations or requested by any judicial process or governmental agency having or claiming jurisdiction over us or our affiliates. 
  • Comply with industry standards and our policies

Lawful basis of processing
The General Data Protection Regulations 2018 state that we must have a valid lawful basis to process your personal data and inform you about which lawful basis we are using to process your personal data. The lawful basis we use is in italic text.

Where consent is required in order to process your data, you will either be specifically asked for this verbally during a phone call (your response will be recorded and stored on our software database), or as part of your contract (sales, letting, pre-tenancy). You can change your consent preferences at any time.

Lettings

Prospective Applicants
Storage of your personal data on our software database and electronic filing system – This processing is necessary for us to grant you a tenancy for the property and securing a tenancy on behalf of a landlord for their property (Contract). We can use this data to contact you within 12 months of your initial contact you with us to match you to any suitable properties that may become available, using your property preferences (Consent).


Your data will be erased from our software database 365 days after the date of your initial enquiry unless you apply for one of our properties.

Pre-Tenancy Applicants and Current Tenants
Storage of your personal data on our software database and electronic filing system – This processing is necessary for us to grant you a tenancy for the property and securing a tenancy on behalf of a landlord for their property (Contract)

Sharing your contact details with our referencing provider – This processing is necessary for us to grant you a tenancy for the property and securing a tenancy on behalf of a landlord for their property, protecting their legitimate interests in obtaining regular rental payments. (Contract)

Viewing your referencing application form and referencing outcome via Van Mildert’s online portal (Legitimate Interest)

Passing on information from your referencing application form and or your referencing outcome to the Landlord, if we consider this to be necessary, or if the Landlord requests it (Legitimate Interest)

Entering your contact details and deposit details with the deposit protection company to register your deposit – This processing is necessary for us to register your deposit under our legal obligations (Legal Obligation)

Taking a colour photocopy of your photographic ID and any other required supporting documents for the Right to Rent checks as required by law, as well as performing repeat checks during the tenancy, as so required by law (Legal Obligation)

Providing your contact details to any contractor instructed by us on behalf of the Landlord to arrange access to the property to carry out maintenance or repairs – This processing is necessary to enable the Landlord to perform required maintenance and repairs as per the obligations within your tenancy agreement (Legitimate Interest and Legal Obligation).

However, if you wish for us to arrange the maintenance and repairs direct with the contractor and notify you by your chosen communication preference (Consent).

If you enter a joint tenancy, to notify any other joint tenants of rent arrears owed by another tenant (Legitimate Interest)

Informing the guarantor where a tenant has failed to pay the rent (Legitimate Interest)

Providing your contact details and your opening and closing utility meter readings either directly to the utility suppliers or using a utility management provider – This processing is necessary to ensure that utility charges are directed to those responsible (Legitimate Interest).

However, if you do not wish for us to provide your contact details and readings to our utility management provider, we can contact the suppliers direct. This is covered within the tenancy agreement (Consent).

At the end of your tenancy, if required, disclosing your contact details to a tracing agent or debt collector, if you have vacated with rent arrears, to assist in recovering monies owed for the Landlord (Legitimate Interest)

At the end of your tenancy, passing on your forwarding address to utility companies, if required (Legitimate Interest)

From time to time, we may contact you by email to offer you the opportunity to participate in competitions administered by us. We will only do this if you state that you are happy for us to do so, and if you have indicated that you are happy to receive communications from us by email (Consent)

Your data will be erased from our database, electronic filing system, server, and any paper information we hold, six years from the date which your contract with us expires.

If your application fails for any reason, your data will be erased from our software database 365 days after the date of your application.

Prospective Landlords
Storage of your personal data on our software database and electronic filing system – This processing is necessary for us to prepare to manage your property and any financial transactions made through this account (Contract). We can use this data to contact you within 12 months of your initial contact you with us to ask if you are interested in using our services (Consent)

Your data will be erased from our software database 365 days after the date of your initial enquiry unless you apply for one of our properties.

Current Landlords
Storage of your personal data on our software database and electronic filing system – This processing is necessary for us to manage your property account (payments in and out) (Contract)

Sharing your contact details with our referencing provider so they can contact you by phone to discuss purchasing a rent guarantee – To process your personal data in this way, we must obtain your consent (Consent).

Entering your contact details and deposit details with the deposit protection company to register the tenancy deposit – This processing is necessary for us to register your tenant’s deposit under our legal obligations (Legal Obligation)

Providing your contact details to any contractor instructed by us to provide you with quotes for works required to the property to ensure it is of a rentable standard prior to the tenancy commencing (if required) – This processing is necessary to enable us to ensure that the property is meeting any required legal rental (Legal Obligation and Contract). Alternatively, we can arrange this directly with the contractor and notify you by your chosen communication preference. (Consent)

From time to time, we may contact you by email to offer you the opportunity to participate in competitions administered by us. We will only do this if you state that you are happy for us to do so, and if you have indicated that you are happy to receive communications from us by email (Consent)

Your data will be erased from our database, electronic filing system, server, and any paper information we hold, six years from the date which your contract with us expires.

Sales

Prospective viewers and purchasers
Storage of your personal data on our software database, electronic filing system and internal server – This processing is necessary for us to progress the purchase of a property advertised through us on behalf of our vendor client (Contract). We can use this data (should you consent to this) to contact you within 12 months of your initial contact you with us to match you to any suitable properties that may become available (Consent)

Share your contact details with an independent mortgage adviser, who will contact you to discuss your requirements, should you require this service and consent to us sharing your contact details. (Consent)

At the point of offer placement, we will need to take and retain a copy of your photographic identification to carry out electronic checks to fulfil our Money Laundering Regulations 2017 obligations (Legal Requirement). Details of your identification document will be entered onto the online portal operated by Etsos who will then perform the required checks.

Your data will be erased from our software database and server 365 days after the date of your initial enquiry unless you purchase one of our properties.

Vendors
Storage of your personal data on our software database, electronic filing system and internal server – This processing is necessary for us to progress the advertisement and sale of your property on your behalf (Contract)

Prior to marketing, we must take and retain a copy of your photographic identification to carry out electronic checks to fulfil our Money Laundering Regulations 2017 obligations (Legal Requirement).

Details of your identification document will be entered onto the online portal operated by Etsos who will then perform the required checks.

Prior to marketing, we must request and retain a copy of the ownership document (title deed) for the property you are selling to fulfil our Money Laundering Regulations 2017 obligations (Legal Requirement)

Providing your contact details to any contractor/surveyors instructed by us on behalf of the vendor(s) to arrange access to the property to carry out EPC assessments or surveys if requested– This processing is necessary to fulfil the legal obligations involved in marketing the property (Legitimate Interest). 
However, if you wish for us to arrange the appointments direct with the contractor/surveyor and notify you by your chosen communication preference (Consent)

Once an offer is agreed, we will ask you if you would like quotes for conveyancing services from one of our affiliated solicitors. If you agree to this, we pass over your email address and preferred contact number. We will not pass your details onto solicitors without prior consent. This consent will be requested when your offer is accepted by the vendor (Consent)

Your data will be erased from our software database, electronic filing system, internal server and any paper information we hold, six years from the date which your contract with us expires.

Purchasers
Storage of your personal data on our software database, electronic filing system and internal server – This processing is necessary for us to progress the purchase of a property advertised through us on behalf of our vendor client (Contract).

At the point of offer placement, we will need to take and retain a copy of your photographic identification to carry out electronic checks to fulfil our Money Laundering Regulations 2017 obligations (Legal Requirement). Details of your identification document will be entered onto the online portal operated by Etsos who will then perform the required checks.

At the point of offer placement, we must take steps to verify your source of funds being used to purchase the property. This covers proof of deposit, available funds within a bank account in your name or a mortgage in principle from the lender (Legal Requirement)

Once an offer is agreed, we will ask you if you would like quotes for conveyancing services from one of our affiliated solicitors. If you agree to this, we pass over your email address and preferred contact number. We will not pass your details onto solicitors without prior consent. This consent will be requested when your offer is accepted by the vendor (Consent)

Your data will be erased from our software database, electronic filing system, internal server and any paper information we hold, six years from the date which your contract with us expires.

Prospective vendors
Storage of your personal data on our software database, electronic filing system and internal server – This processing is necessary for us to progress the advertisement and sale of your property on your behalf, should you choose to proceed with our services following a sales valuation visit by our agent (Contract)

Prior to marketing, we must take and retain a copy of your photographic identification to carry out electronic checks to fulfil our Money Laundering Regulations 2017 obligations (Legal Requirement). Details of your identification document will be entered onto the online portal operated by Etsos who will then perform the required checks.

Prior to marketing, we must request and retain a copy of the ownership document (title deed) for the property you are selling (Legal Requirement)

Your data will be erased from our software database 365 days after the date of your initial enquiry unless you advertise your property with us and therefore sign a sales contract. If this is the case, your data will be erased six years from the date which your contract with us expires.

Information we share
We do not sell or otherwise disclose personal information we collect about you, except as described in this Privacy Notice or as indicated via the consent process at the time the data is collected. We share the information we collect with, but not limited to: 
Vetted affiliates and partners / financial Institutions / insurance companies for business facilitation to provide required services, such as mortgages, insurance cover etc. 
Formally contracted service providers to perform services on our behalf - Hosting Datacentres, Applications (Development / Support). 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 
Utility Providers and the Local Authority
Solicitors (buying and selling property)
Credit agencies, Land Registry Office, Her Majesty’s Revenue and Customs (HMRC), Financial Conduct Authority (FCA) and other relevant regulatory bodies 
Additionally, we may share information about you, if required legally, to prevent harm or financial / reputation loss, for investigation of suspected or actual fraudulent or illegal activities.

Technological Security

Our website
On our website, features can be accessed where we partner with other entities that are not affiliated with us. These include social networking, geo-location tools etc.

These are operated by third parties (indicated appropriately) who may use or share personal information in accordance with their own privacy policies. Such sites are not subject to our privacy policy. It is recommended that you review the third parties' privacy policies if you use the relevant features.

We do not use cookies on our website.

Our IT systems

We ensure that our IT systems and PC’s are always up to date with the latest software updates to enhance security.

We have Microsoft Windows Defender (anti-virus software) installed. Windows Defender Antivirus uses real-time protection to scan programs which we use. Updates for Windows Defender Antivirus are applied automatically by Microsoft to help keep our PC’s safe and protect them from security threats.

All staff have their own log-in credentials which are changed every 90 days. Staff are instructed to lock their PC screens when they are not at their desk

Our email operating system, Microsoft Office, provides us with enhanced security measures against hackers.

We use Microsoft Azure cloud computing platform. This platform adheres to EU data protection principles as well as the international cloud privacy standard ISO27018. Further information regarding Azure cloud storage can be accessed via this link (https://www.microsoft.com/en-us/trustcenter/cloudservices/azure)

Your rights and choices 
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

Access and correction 
You have the right to: 
Obtain confirmation that we hold and process 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. This will be free of charge. However, if we consider the request to be manifestly unfounded, excessive or repetitive or the request is for additional copies of information which you have already been provided, an administration charge of £30.00 inc VAT will be payable.
The right to access personal information may be limited in some circumstances by local law requirements.

To exercise these rights, please contact us in writing. We will respond within one calendar month from the date of your request. This may be extended to a total of three calendar months from the date of your request if we consider the request to be complex.

Update and correct inaccuracies in your personal information 
We regularly review, and quality check the information we store and process to ensure that it is accurate and adequate for the purposes of the processing for which it was collected.

If you feel that the information we hold about you is incorrect or inaccurate you can contact us outlining the information you feel is incorrect or inaccurate. We will respond within one calendar month from the date of your request. This may be extended to a total of three calendar months from the date of your request if we consider the request to be complex. If we refuse to correct your personal information, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint.

Object to the processing of your personal information 
If you would like to object to any processing of your information by us, you can contact us outlining what processing of information you would like to object to.

Right to erasure including retention and disposal
You have the right to be forgotten and can request the erasure of your personal data when:
It is no longer necessary in relation to the purpose for which it was originally collected/processed.
You withdraw consent
You object to the processing and there is no overriding legitimate interest for continuing the processing
It was unlawfully processed
It has to be erased in order to comply with a legal obligation

We can refuse to comply with your request for erasure where we process your personal data. We will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint.

We retain information in accordance with the minimum statutory requirements, depending on the type of information. Contact details entered on to our databases through will be 2 years after our last contact with you. Contract (pre-tenancy agreements, tenancy agreements, letting contracts, sales contracts) and financial information will be held for 6 years after expiry. We maintain clear and full written records of transactions for a period of six years. However, we reserve the right to keep information for longer if we feel that this is in our legitimate interests.

Right to restrict processing
You have the right to request that we block or restrict the processing of personal data in the following circumstances:
If you contest the accuracy of the personal data. We will restrict the processing until we have verified the accuracy of the personal data
If you object to the processing (where it is necessary for the purpose of a legitimate interest). We will restrict the processing whilst we consider whether our legitimate purpose overrides your objection.
If our processing was unlawful and you oppose erasure and request restriction instead.
If we no longer need the personal data but you require the data to be retained to allow you to establish, exercise or defend a legal claim
You will be informed of any decision to remove a restriction on processing.

Right to object
You have the right to object to processing based on legitimate interests. Your objection must be based on grounds relating to your situation. We will stop processing unless we can demonstrate that our legitimate grounds for processing override your objection or that the processing is for the establishment, exercise or defence of legal claims.

You have the right to object against processing at any time.

Opting out of processing 
You can at any time tell us not to send you marketing communications by e-mail info@evenmoreproperties.co.uk or contacting us by phone

Withdrawal of consent 
If we obtain your information by consent you have the right to withdraw any consent you previously provided to us, at any time, by letting us know either in writing or by phone. If we process your information under legitimate interest you can object at any time on legitimate grounds, to the processing of your personal information. We will apply your preferences going forward. Doing so may mean that you cannot take advantage of some of our and our affiliate products, services and promotions.

The right to consent removal may be limited in some circumstances by local law requirements and you will be informed appropriately.

 

Breach notification
A personal data breach means a breach of security leading to destruction, loss, alteration, unauthorised disclosure of, or access to, personal data. Where a breach is likely to result in a high risk to the rights and freedoms of individuals, you will be notified immediately. Records of any breaches will be maintained. The ICO will be notified if the breach falls under their definition of a notifiable breach.

Updating this privacy statement 
We will update this statement from time to time, so we suggest that you review this statement at regular intervals. Where we undergo substantial changes to our privacy statement we will endeavour to inform you directly about these changes.

How to complain
If you feel that your rights have not been adhered to or consider you have been unfairly affected by the processing of your personal data, you can write to us by email info@evenmoreproperties.co.uk or by post to 1 Newcastle Road, Crossgate Moor, Durham, DH1 4AG. Please provide as much detail as possible as to the nature of your complaint. We will provide you with a copy of our internal complaints procedure.

If your complaint has not been resolved to your satisfaction using our internal complaints process, you can contact the Information Commissioners Office (ICO) and request an investigation.