This document refers to personal data, this is defined as information concerning any living person (a natural person who hereafter will be called the Data subject) that is not already in the public domain.
The data protection act (DPA) Privacy and Electronic communications regulations (PECR) and the general Data Protection Regulation (GDPR) which is EU wide and far more extensive, seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain such as companies house data.
Focus Residential Ltd is pleased to provide the following GDPR information:
Who we are
Focus Residential Ltd is a residential estate agent, commercial estate agent and letting agent.
Typically Focus Residential Ltd collect.
First Name, Middle Name, Surname, previous Name, Date of birth, present address, previous address, landlords details, nationality, NI Number, passport details, how many dependents, dependents date of birth, primary ID, address ID, bank statements, mortgage info, details of adverse credit, email address, phone numbers, solicitor details, estate agents details, insurance details, IP address, cookies, marital status, salary, accountant, employer, previous employer, bank details, personal and business reference information
1.1 Methods of collection
In the general conduct of business, Focus Residential collects information relevant to the services being sought across the range of services it offers (listed previously) from:
Yourself, next of kin, spouse/partner/family member, business associates, employers, ‘Trusted sources’ including government, land registry, credit/default agencies, financial institutions, loan agencies and insurance companies.
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. We may also collect personal information through our affiliates or suppliers.
You may also agree to third parties disclosing information about you to us that those third parties have collected.
We, our service providers and partners collect certain information by using automated means, such as cookies and web beacons, when you interact with our advertisements, mobile applications, or visit our websites, pages or other digital assets. The information we collect in this manner may include: IP address, browser type, operating system, referring URLs and information on actions taken or interaction with our digital assets.
We may use third party web analytics services on our websites and mobile apps the analytics providers that administer these services use technologies such as cookies and web beacons to help us analyse how visitors use our websites and apps.
“Your rights and choices” section of this privacy notice specifies your ability, to opt out of limit the usage of the information collected.
1.2 Purposes of collection
Generally we collect, use and hold your information for the purposes of:
Assessing applications for and providing Focus Residential products/services, conducting business, developing relationships with Focus Residential and its affiliates, process payments, accounting, authorisation, auditing, billing, reconciliation, collection, complaints, enquiries, credit checks and related dispute resolution activies, protecting against and preventing fraud and unauthorised transactions, compyling with anti-money laundering regulations, compliance and security of business processes, communicating with you about Focus Residential products, services, offers, programs and promotions, monitoring, evaluating and improving our products, services, websites and mobile applications,
Improving the functionality of our websites, mobile applications other digital assets, enforcing Focus Residential “Terms of Business” and 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 Focus Residential or its affiliates, complying with industry standards and Focus Residential policies.
We reserve the right to employ third party electronic verification for verifying identity.
1.3 Lawful basis of processing
Focus Residential processes your information under the following:
Performance of a contract; where you enter into a contract with Focus Residential and we need to process your information as part of this contract.
Legitimate interests: Some information is processed by Focus Residential as part of its legitimate interests which include: Fraud, risk assessment, due diligence, direct marketing, monitoring, web analytics, updating customer details, lettings, sales and other products and services provided by the data controller. Consent: Where we process information under consent we will seek your clear and unambiguous consent prior to processing your data
2. 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, insurance companies for business facilitation to provide required services, insurance cover etc.
Formally contracted service providers to perform services on our behalf:
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 necessary to perform services on our behalf or comply with legal requirements.
We may also share information with councils, utility companies, law firms, credit agencies, Land registry office, HMRC, the tenancy deposit scheme 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
Perspective employers requesting references via your written consent
On websites, features can be accessed where we partner with other entities that are not Affiliated with Focus Residential. These include social networking etc. Which 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.
Focus Residential 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 protect/use your information consistent with our privacy notice. You can Exercise your rights to contact the acquiring entity with questions concerning the protection And processing of your information.
2.1 How Long do we keep your information for
We will keep information for a reasonable amount of time to perform the purposes listed above. We only keep your information for as long as necessary. We generally keep personal Information for 7 years after last contact with you. After this period all data no longer Required in the legitimate interests of Focus Residential will be deleted/destroyed.
2.2 Your rights and choices
Your rights regarding the sensitive/ 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
At any point whilst Focus Residential is in possession of or processing your personal data, all Data subjects have the following rights:
- Right of access- you have the right to request a copy of the information that we hold about You.
- Right of rectification– you have a right to correct data that we hold about you that is Inaccurate or incomplete
- Right to be forgotten– in certain circumstances you can ask for the data we hold about You to be erased from our records.
- Right to restriction of processing– Where certain conditions apply you have a right To restrict the processing
- Right of portability– you have the right to have the data we hold about you transferred To another organisation.
- Right to object– You have the right to object to certain types of processing such as direct Marketing.
- Right to object to automated processing, including profiling- you also have the right not to Be subject to the legal effects of automated processing or profiling.
If Focus Residential refuses your request under rights of access, we will provide you with A reason as to why, which you have the right to legally challenge.
Focus Residential, at your request can confirm what information it holds about you and how It is processed.
You can request the following information
Identity and the contact details of the person or organisation (Focus Residential) that has determined how and why to process your data Contact details of the data protection officer, where applicable
The purpose of the processing as well as the legal basis for processing
If the processing is based on the legitimate interests of Focus Residential or a third party such as one of its clients, information about those interests.
The categories of personal data collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
How long the data will be stored
Details of your rights to correct, erase, restrict or object to such processing.
Information about your right to withdraw consent at any time.
How to lodge a complaint with the supervisory authority (ICO)
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
The source of personal data if it wasn’t collected directly from you.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
Right to consent removal may be limited in some circumstances by local law requirements and you will be informed appropriately.
To access what personal data is held, identification will be required
Focus Residential will accept the following forms of ID when information on your personal data is requested: A copy of your driving licence, passport, birth certificate and a utility bill not older than 3 months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Focus are dissatisfied with the quality, then further information may be sought before personal data can be released.
All requests should be made to [email protected], by phoning us on 01753 770090 or by writing to us at the address below.
Any data held outside the European union is only held with organisations that are expressly GDPR ready and compliant.
If we fall short of your expectations in processing your personal information or you wish to make a complaint about our privacy practices, please contact us at the above email or telephone number or at the address below. If you do not get a response within 30 days, you can complain to the ICO
Focus Residential Ltd
16 Windsor Road
Information Commissioner’s Office