Your information will be held electronically and on documentation by Bloxham and Barlow Limited, which is a processor of information.
1. Introduction
This Privacy Policy forms part of Bloxham and Barlow Limited obligation to be open and fair with all individuals whose personal data we process and to provide details around how we process such personal data and what we do with it.
Bloxham and Barlow Limited is committed to safeguarding the privacy of personal data and complying with the European General Data Protection Regulation (2016/679) and the UK Data Protection Bill 2017, and any future changes in data protection legislation with which Bloxham and Barlow Limited will be required to comply.
When selling, purchasing, renting or financing a property (including surveying services) through our company we process your personal data such as name, address, contact details, email address and passport amongst other things. Processing of this data implies collecting, storing, using or disclosing your personal data.
This Privacy Policy relates to the processing of personal data by Bloxham and Barlow Limited.
None of the lists or examples provided in this Privacy Policy is intended to be exhaustive or fully representative of every individual.
2. Scope
The scope of this Privacy Policy covers client personal data in respect of the following:
• Ways we use your Personal Data
• Definitions of Personal Data types
• Collecting Personal Data
• Using Personal Data
• Fraud Protection Agencies (FPAs)
• Disclosing Personal Da ta
• Retaining Personal Data
• Securing Personal Data
• Sharing Personal Data
• Data Subject Rights
• Updates/Amendments
• Consents (“Opt-in”)
• Withdrawal of Consent (“Opt-out”)
• Our Details
3. Ways we use your Personal Data
We’ll process your personal data:
a) as necessary to perform and fulfil our contracts with you:
• to take steps at your request prior to entering into it;
• to exercise rights set out in agreements or contracts;
• to deliver our products and services;
• to update our records;
• to make and manage customer payments;
• to manage fees and charges due on customer transactions;
• to collect and recover money that is owed to us.
b) as necessary to comply with legal obligation, e.g.:
• when you exercise your rights under data protection law and make requests;
• for compliance and to obey laws and regulations that apply to us
• to verify your identify, make credit, fraud protection and anti-money laundering checks;
• to manage risk for us and our customers
• to detect, investigate, report and seek to prevent financial crime;
• to run our business in an efficient and property way;
• to manage how we work with other companies that provide products and services to us and our customers.
c) As necessary for our own legitimate interests, or those or other persons and organisations, e.g.:
• for good governance, accounting and managing and auditing our business operations;
• to respond to complaints and seek to resolve them;
• to run our business in an efficient and proper way;
• to manage how we work with other companies that provide products and services to us and our customers;
• to provide advice or guidance about relayed products and services.
d) based on your consent, e.g.:
• to manage our relationship with you;
• to develop new ways to meet our customers’ needs and to grow our business;
• to provide advice or guidance about related products and services.
You are free at any time to change your mind and withdraw your consent.
4. Definitions of Personal Data types
We use various kinds of personal information, and group them together like this.
| Type of Personal Information | Description |
| Contact | Where you live and how to contact you. |
| Consent | Any permissions, consents or preferences that you give us, including how you would like us to contact you. |
| Financial | Your financial position, status and history. |
| Contractual | Details about the products and services we provide to you. |
| Behavioural | Details about how you use our products and services. |
| Communications | What we learn about you from conversations, emails and letters between us. |
| Social Relationships | Your Family, friends and other relationships. |
| Open Data and Public Records | Details about you that are in public records such as the Electoral Register and information about you that is openly available on the internet. |
| Usage Data | Other data about how you use our products and services. |
| Documentary Data | Details about you are stored in documents in different formats, including copies. This could also include things like your passport, driving licence, birth certificate or utility bill. |
| Socio-demographic | This includes details about your work or profession, nationality. |
| National Identifier | A number or code given to you by a government to identify who you are, such as a National Insurance number or Passport Number. |
5. Collecting Personal Data
We may collect and store the following kinds of personal data:
| i. | Information that you provided to us when applying through our website, during visits to branch offices, in emails or over the phone. |
| ii. | Information contained in or relating to any communication that you send to us through our website, email, in writing or over the phone. |
| iii. | Information that you provide to us for the purpose of subscribing to our marketing communications. |
| iv. | Information that you provide to us when using any services we provide, or that is generated during the use of those services. |
| v. | Information that you provide as part of electronically signing agreements with us. |
| vi. | Information that you provide in performing anti-money laundering, financial and credit checks as well as for fraud and crime prevention and detection purposes. |
| vii. | Information related to the security and access or our systems and applications. |
| viii. | Information to help us comply with our legal and regulatory obligations, including reporting to and being audited by regulators and external auditors. |
| ix. | Information to help us comply with court orders and to exercise and defend our legal rights. |
| x. | Any other personal information that may be sent to us and which we use for legitimate business purposes. |
| xi. | Information shared as part of our competitions and promotions. |
Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this Privacy Policy.
Data from third parties we work with:
• Companies that introduce you to us (property portals for example)
• Financial Advisors
• Comparison websites
• Social networks
We may need to collect personal information by law, or under the terms of a contract we have with you. If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform the services needed to progress the sale, purchase or letting of a property.
Any data collection that is optional would be made clear at the point of collection.
6. Using Personal Data
We may use your personal information to:
| i) | Enable your use of any services that we may provide through our websites or third-party websites. |
| ii) | Supply you with our products and services. |
| iii) | Send statements, invoices and payment reminders to you, your lawyers who you use for conveyancing, or to collect payments from you. |
| iv) | Send you marketing communications. |
| v) | Deal with enquiries and complaints. |
| vi) | Perform money laundering, financial and credit checks. |
| vii) | Use tracing services to obtain onward contact details and collect any unpaid debts for any default by you. |
| viii) | Ensure appropriate access to systems and applications. |
| ix) | ix)Comply with our legal and regulatory obligations. |
7. Fraud Prevention Agencies (FPAs)
We may need to confirm your identity before we provide products or services to you or your business.
8. Disclosing Personal Data
We only disclose your personal data in the ways set out in this Privacy Policy or subject to any agreements in place between us. The following circumstances may apply:
| i) | To third parties who process personal data on our behalf. |
| ii) | To third parties who process personal data on their own behalf but provide us, or you, with a service on behalf of us. |
| iii) | To third parties with whom information is sharing for anti-money laundering checks, credit risk reduction, debt collection and other fraud and crime prevention purposes. |
| iv) | To any regulator, external auditor or applicable body or court where we are required to do so by law or regulation or as part of any investigation. |
| v) | To any central or local government department and other statutory or public bodies, such as HMRC. |
| vi) | If the law or a public authority says we must share the personal data; |
| vii) | If we need to share personal data in order to establish, exercise or defund our legal rights (this includes providing personal data to others for the purposes or preventing fraud or reducing credit risk); |
| viii) | To any other successors in title to our business; |
| We do not sell, rent or trade any of your personal data. | |
| We will not, without your consent, disclose or supply your personal data to any third party for the purpose of their or any other third party’s direct marketing. |
9. Retaining Personal Data
The following criteria are used to determine data retention periods for your personal data (whether or not you become a customer);
• Retention in case of queries – we will retain your personal data as long as necessary to deal with your queries (e.g. if your potential transaction is unsuccessful);
• Retention in case of claims – we will retain your personal data for as long as you might legally bring claims against us; and
• Retention in accordance with legal and regulatory requirements – we will retain your personal data after your contract or service with us has come to an end based on legal and regulatory requirements.
10. Securing Personal Data
Where Bloxham and Barlow Limited acts as the controller of personal data, it will ensure that necessary and adequate safeguards (e.g. encryption) are in place to prevent unauthorised access, loss, misuse or alteration of your personal data.
Where data is stored electronically we store all personal information on secure servers with relevant access and firewall controls.
Where data is stored on paper or forms all personal data is locked away when not in use, and disposed of securely after use either using document shredder or third-party disposal organisations who have been contracted to dispose of documents appropriately.
Any personal data sent to us, either in writing or email, may be insecure transit and we cannot guarantee its delivery.
11. Data Subject Rights
Your rights are as follows (noting that these rights don’t apply in all circumstances):
• The right to be informed about our processing of your personal data;
• The right to have your personal data corrected if it’s inaccurate and to have incomplete personal data completed;
• The right to object to processing of personal data;
• The right to restrict processing of your personal data;
• The right to have your personal data erased (the “right to be forgotten”);
• The right to request access to your personal data and information about how we process it;
• The right to move, copy or transfer your personal data (“data portability”); and
• Rights in relation to automated decision making including profiling.
12. Updates/Amendments
To remain compliant with any legal and regulatory obligations, or as part of our evolving business practices, we may update this Privacy Policy from time to time by publishing a new version.
13. Consents (“Opt-in”)
Your personal data is provided for the purpose of selling or purchasing a property, letting or being a tenant of a property, conveyancing or surveying services as agreed under the terms of an Agreement we have agreed between you and us.
14. Withdrawal of Consent (“Opt-out”)
You have the right, at any time, to ask us not to process your personal data for marketing purposes and any additional services that you have consented to receive.
You can opt-out of receiving any of these services and communications simply by clicking the unsubscribe link on any emails you receive, or contact our office.
15. Data Protection Registration
We are registered as a data controller with the UK Information Commissioner’s Office and our data protection registration number is ZA222106.
16. Our Details
Bloxham and Barlow is registered in England and Wales under company number 6376473 its registered office is at Greystones House, 198-200 High Street, Worle, Weston-super-Mare, North Somerset, BS22 6JD.
You can contact us as follows:
Email: mail@bloxham-barlow.co.uk
Web: www.bloxham-barlow.co.uk
Telephone: 01934 513050/518503
In writing: Data Protection Officer, Bloxham and Barlow Limited, Greystones House, 198-200 High Street, Worle, Weston-super-Mare, North Somerset, BS22 6JD
