Privacy Notice

Background

First Property Group plc understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us

First Property Group plc a company registered in England under number 02967020, whose registered office is at 32 St James’s Street, London, SW1A 1HD (“the Company”), (this Privacy Notice includes the Company’s subsidiaries, associates and funds) regarding data protection and the rights of individuals (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

Data Protection Officer: Jill Aubrey.
Email address: jill.aubrey@fprop.com.
Telephone number: 0207 340 0276.
Postal Address: 32 St James’s Street, London, SW1A 1HD

2. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

4. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.

b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

5. What Personal Data Do You Collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us):

• Name;
• Date of birth;
• Gender;
• Address;
• Email address;
• Telephone number;
• Business name;
• Job title;
• Profession;
• Bank account information;
• Personal financial data;
• Information about your preferences and interests; and
• Tax details.

Your personal data is obtained from the following third party:

• Link Market Services Limited.

6. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:

• Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.
• Personalising and tailoring our services for you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information by email and post that you have opted-in to (you may unsubscribe or opt-out at any time by contacting the Data Protection Officer).
• To fulfil our regulatory obligations.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone and post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

7. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept), please refer to Appendix 1 for these details.

8. How and Where Do You Store or Transfer My Personal Data?

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.

We share your data with external third parties, as detailed below in Part 9, that are based outside of the EEA. The following safeguards are applied to such transfers:

We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR. More information is available from the European Commission.

Please contact us using the details below in Part 11 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• All emails containing personal data must be encrypted using TLS Version 1.2 or V1.1 or V1.0 and all email attachments encrypted and password protected;
• All emails containing personal data must be marked “confidential”;
• Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
• Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
• Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
• Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using courier or special delivery;
• All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”;
• All electronic copies of personal data should be stored securely using passwords and Word, Excel, PDF AES 256 bit data encryption;
• All personal data stored electronically should be backed up daily with backups stored onsite and offsite. All backups should be encrypted using AES 256 bit;
• No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of the Data Protection Officer and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary; and
• No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of our Data Protection Policy and of the GDPR (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).

9. Do You Share My Personal Data?

We may sometimes contract with following types of third parties to supply services to you on our behalf. These may include payment processing and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.

• The Group’s registrar.
• The Group’s nomad.
• Banks.
• Government Agencies such as HMRC.
• The Financial Conduct Authority.
• Providers of services so that we comply with regulatory obligations.
• Third party property managing agents for the properties owned or managed by the Group.
• Lawyers and legal counsel.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

10. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Jill Aubrey):

Email address: jill.aubrey@fprop.com.
Telephone number: 0207 340 0276.
Postal Address: 32 St James’s Street, London, SW1A 1HD.

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available via our website.

Appendix 1

Type of Data	Purpose of Data	Retention Period orCriteria
Name, address, mobile, phone, email, health details, CV, references, CRB checks, identification details, work permit, appraisals, annual leave, sickness record, training record, disciplinary records, Tax/NI, bank account details, pension details.	Legal compliance: compliance with our legal and regulatory obligations under applicable law.	For so long as the employee is employed or a member of the Group’s pension scheme, plus ten years, after which data will become anonymised.Applicants for roles within the Group who are not successful, data will be held for three months.
Name, address, email, mobile, phone.	Emergency contact details for the protection of vital interests of employee.	For so long as the employee is employed, data will be deleted within three months of the employee leaving the Group.
Name, address and proof of address, email, mobile, phone, identification documents, bank account details, Tax/NI details, source of funds evidence.	Anti-Money Laundering/KYC: fulfilling our regulatory compliance obligations, including ‘Know Your Client’ checks; and confirming and verifying your identity; and screening against government, supranational bodies (including but not limited to the European Union and the United Nations Security Council) and/ or law enforcement agency sanctions lists as well as internal sanctions lists and other legal restrictions.	For so long as the client is a client, plus ten years, after which data will become anonymised.
Name, address and proof of address, email, mobile, phone, identification documents, bank account details, Tax/NI details, source of funds evidence.	Client on-boarding: on-boarding new clients; and compliance with our internal compliance requirements, policies and procedures.	For so long as the client is a client, plus ten years, after which data will become anonymised. If for whatever reason they do not become a client, data will be kept for
Name, address and proof of address, email, mobile, phone, identification documents, bank account details, Tax/NI details, source of funds evidence.	Conducting financial due diligence.	For so long as the client is a client, plus ten years, after which data will become anonymised. If for whatever reason they do not become a client, data will be kept for three months.
Name, address, email, mobile, phone, bank account details, tax details, with regards to tenants for properties owned or managed by the Company types of data may include in addition to those mentioned, proof of address and identification documents.	Provision of services to you: administering relationships and related services; performance of tasks necessary for the provision of the requested services; communicating with you in relation to those services.	For so long as the client is a client, plus ten years, after which data will become anonymised.
Name, address, email, mobile, phone.	Marketing: communicating with you via any means (including via email, telephone, social media, post or in person) subject to ensuring that such communications are provided to you in compliance with applicable law; and maintaining and updating your contact information where appropriate.	Kept until person unsubscribes/ requests to be removed.
Name, address, email, mobile, phone.	Health and safety: health and safety assessments and record keeping; and compliance with related legal obligations.	For so long as the property is a property occupied, owned or managed by the Group, plus ten years, after which data will become anonymised.
Images, name, address, mobile, phone.	Security: physical security of our premises either owned or managed by us (including records of visits to our premises and CCTV recordings); and electronic security (including login records and access details, where you access our electronic systems).	Please refer to the security and CCTV log for premises and properties owned, occupied and managed by the Group for further details.