Who holds your personal data
Thornsett Group plc (and its subsidiary companies) is the data controller that holds and processes any personal data we may have about you. Some third parties may process some of your personal data on our instructions as explained below.
Thornsett Group plc and its subsidiary companies are committed to protecting and respecting the privacy of individuals, and to ensure that personal information held is appropriate to our business activities and secure. This document applies to all Thornsett Group plc’s subsidiary companies.
This policy describes the management of personal information which may be provided by clients and contacts during the course of these business activities.
In accordance with the General Data Protection Regulations, we have systems in place to ensure that personal data we have collected on you is:
- Fairly and lawfully processed
- Processed for and limited to the purpose required
- Held secure
- Relevant and up to date
- Held only for as long as we need it
- Disclosed to the data subject upon request
When you browse our website(s)
If you register your interest in any one of the properties on our website, your information is automatically shared with the marketing agent responsible for that property, and a copy of that information is relayed to us for our records. The marketing agent will then use this information to contact you with regard to the specific development you have expressed an interest in.
When you contact us in relation to a property enquiry, we may process the following information about you:
- Information provided by you (or a joint buyer/tenant) either collected face to face, or by filling in a form, or by corresponding with us by email or telephone or otherwise. We will assume that if you have provided information about a joint buyer or someone living with you, you have obtained the permission of that person to share their data with us.
- The information collected includes, but is not restricted to, name, address, email address, contact telephone number, bank account information, social media, etc.
- We also store information received directly from you by telephone (notes made), letter, email, or fax.
- When you call the office, we use CLI (caller line identification), so your telephone number will be available to us. This is sometime stored for a short period on our telephone system as a recent call, or in some cases, stored as a regular contact.
Why we collect your data
We rely on the following legal bases to use your personal data:
- Consent – where you have given us explicit consent to process your personal data for a specific purpose, or if it is necessary for Thornsett Group plc to meet our legal obligations
- Contract – we may process your personal data to fulfil our contractual obligations, or if you have asked us to do something before entering into a contract with us
- Legal obligations - we have certain legal obligations where we may be required to disclose information to the relevant authority, for example to prevent fraud, money laundering, or possible criminal acts or security threats.
- Legitimate interests – where the processing is necessary for the legitimate interests of Thornsett Group plc or a Third Party (unless there is reason to protect the individual’s personal data). This would apply to all stages and activities relevant to the provision of services including enquiry and administration, marketing, internal communication, processing of accounts, job applications and IT security.
What we do with the information we gather
During the ‘life cycle’ of personal data, several different processing operations can be carried out in relation to this data, from its initial collection, to its eventual erasure and removal from records.
Marketing – as a potential customer, if you have expressed an interest in one of our properties, we will process the information you have provided to keep in touch with you regarding this, or our other products and services you may be interested in. We may also get in touch with you to invite you to corporate events that we hold. You have the right to rescind or withdraw your permission for us to process this data at any time.
Contractual obligations - Once you are a customer, we will use the information you have provided for the purpose of servicing our contract with you, for example, routine defect management and access requests, and generally to manage our relationship with you. During this time, your data may be shared with third parties to ensure that we meet our obligations. For example, sharing contact information with contractors who are required to attend defects, or managing agents to ensure that services are provided as required.
We hold the personal data that is required to perform our contractual obligation to you in electronic and hard copy form, and process it as necessary to provide those services and/or as you instruct us. We use Cloud-based technology to store some of this data, for example, emails and record keeping.
The personal information you provide will be retained only for as long as we have a reasonable business need, such as managing our relationship with you and administering our services. We will retain such information to meet our contractual and administrative obligations and in line with legal and regulatory guidelines. For example, if you purchase a property from us, we will retain your data for the duration of the warranty period of the property.
Sharing your data
We may share your personal information with anyone in our group, which means our ultimate holding company and its subsidiaries as defined in section 1159 of the UK Companies Act 2006.
As part of our contractual obligation to you, we may also be required to share your data with third parties such as contractors or managing agents, in order to provide a service to you. All our contractors enter into appropriate contractual confidentiality obligations and/or contractual data processing clauses with us.
We may also process and share information in connection with the sale of your property with third parties we work closely with (including sub-contractors, NHBC, Warranty providers, utility suppliers, local authorities, and legal advisors, etc).
Your rights to your personal data
You have the legal right to request copies of the personal data we hold about you, and have the right to request a correction or amendment to your data if required. In certain circumstances, you also have the right to request deletion or erasure of your records, but we are not obliged to do so if your request is overridden by our ongoing contractual commitments to you. You can request that we restrict processing of your data.
You also have the right to complain to the Information Commissioner’s Office as our supervisory authority if you have any concerns regarding our processing of your personal data.
Controlling your data and security
We use encrypted Cloud services to store your data, and ensure that access to this data is restricted to only those in our company with the appropriate rights. The data that we collect from you may be transferred to, or stored at a destination outside the European Economic Area (EEA). For example, our data may be stored on a server located in a country outside the EEA. We will take all steps reasonably necessary to ensure that you data is treated securely and in accordance with this policy.
We will not sell, distribute, or lease your personal information to third parties unless we have your permission, or are required by law to do so.
Contacting us about your personal data
You may choose to restrict the collection or use of your information by clicking the appropriate box on the webpage you have accessed, to indicate that you do not want the information to be used by anybody for direct marketing purposes. If you have previously agreed to us using your details for direct marketing, you can change your mind at any time by writing or emailing us at firstname.lastname@example.org
You may request details of the personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you, please write to:
Thornsett Group plc
C/o Data Protection
34 Margery Street
If you believe that any information we are holding on you is incorrect or incomplete, please write to us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.