PRIVACY POLICY 

1. INTRODUCTION

This document sets out the privacy policy of Goshawk (Real Estate) Limited (“Goshawk”, “we”, “us”, or “our”). The new General Data Protection Regulation (GDPR), which comes into effect on 25 May 2018, empowers members of the public to control their personal data to a significant degree. Personal data is any information relating to an identified or identifiable living person.

Goshawk is primarily a business-to-business professional services company. As a consequence, we collect personal data to a limited degree only, and this data is generally not sensitive in nature. Notwithstanding, Goshawk is committed to protecting and respecting the personal data that we do hold and our policy is to be transparent about why and how we process personal data.

This privacy statement describes why and how we might collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others on behalf of individuals. We may use personal data provided to us for the purposes described in this privacy statement or as made clear in another form before collecting personal data.

The personal data that is provided to us is provided either directly from the individual concerned, from a third party acting on behalf of an individual, or from publicly available sources (such as internet searches, and Companies House). We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose differ, and are set out in the relevant sections below.

2. SECURITY

We take the security of all the data we hold seriously. Staff members are trained on data protection, confidentiality and security, and we maintain a culture of confidentiality.

All information you provide to us is stored on hosted secure servers in the UK or EU. In the event that we have provided (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask that you do not share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.

3. DATA THAT WE HOLD

3.1 PROFESSIONAL SERVICES

We provide services to businesses primarily, non-profits, and other organisations, as well as to individuals. The exact data held will depend on the services to be provided.

Where we engage with clients for professional services, we may collect and process personal data in order to satisfy a contractual obligation. We request that clients only provide the personal data that is required for us to fulfil our contractual obligation.

Where we are legally permitted to do so, we shall notify our clients if we receive a request for a data subject to exercise their rights under GDPR, or if we are served with information from a supervisory authority.

Why do we process data?

Where data is collected for professional services, it is used for a number of purposes, such as;

  • Providing services to clients: data is processed in order to provide the service detailed in our letter of engagement between our clients and us, and may sometimes be further clarified in written documentation supplied before any data processing may occur;
  • Client management: when communicating with and assessing the needs of clients, personal data may be processed in order to ensure that their needs are appropriately satisfied. This may include assessing whether the right collection of services is being provided to our clients.
  • Administration: in order to manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing client relationships, hosting events, administering client facing applications, and maintaining internal operating processes.
  • Regulatory: in order to undertake professional services, we may from time to time be required to collect and process personal data in order to fulfil regulatory, legal or ethical requirements. This may include the verification of identity of individuals.

 

What data is processed?

The data that is processed is dependent on the service that is being provided and on the recipient of this service.

  • Services to businesses, non-profits, and other organisations: we process the personal data of individuals associated with our clients. Personal data may include any relevant financial or non-financial information necessary for us to provide our services. As an example, this may include contact details, payroll data, employee information (including details about dismissal), lists of shareholders, customers and suppliers and any other specifically relevant data.
  • Services to individuals: personal data may include contact details and tax identifiers, information about business activities, investments, and other financial interests, payroll and other income, and any other specifically relevant data.

How long do we hold data for?

We retain the personal data processed by us in a “live” environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years). We may keep data for longer in order to establish, exercise, or defend our legal rights and the legal rights of our clients.

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it, for example a legitimate business purpose.

3.2 BUSINESS CONTACTS

Personal data from our contacts, which covers both potential and prior clients, as well as potential and prior employees, are held in a client relationship management tool (CRM tool).

This information is entered into the CRM tool after contact is made between a partner or staff member of Goshawk and a business contact.

We may use technology to profile our business contacts, so that we can assess the health of our relationship with them. Where we process the data of business contacts, we rely on legitimate interests or consent, depending on the situation.

Why do we process data?

Where personal data on business contacts is held, it is used for a number of purposes, such as;

  • promotion and development of our services;
  • communication of technical or market updates;
  • hosting and facilitating of events;
  • managing of our relationships; and
  • administration and management.

What data do we hold?

Personal data that may be stored in the CRM tool includes, but is not limited to, name, e-mail address, phone numbers, physical address, job title, and details of the initial meeting.

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose(s) for which it was collected. The personal data of business contacts shall not be retained where there is no evidence that a business contact is engaged, or is likely to be engaged, with us or our communications.

3.3 OUR PEOPLE

We collect personal data for our people as part of the administration, management and promotion of our business activities.

Our Head of Data Privacy will respond to all enquiries and explain further how personal data is held for our staff and partners.

Applicants

Where an individual is applying to work for Goshawk, personal data is collected through the application process. Where we receive personal data from a third party that relates to an individual, we request that this third party informs the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.

Data collected on applicants will be used for the purposes detailed below.

Why do we process data?

There are a number of purposes that personal data for applicants are collected.

  • Employment: we process an applicant’s personal data in order to assess their potential employment at Goshawk.
  • Administration and management: we may also use this personal data in order to make informed management decisions and for administration purposes.

How long do we hold data for?

Personal data collected for applicants is held for as long as necessary in order to fulfil the purpose for which it was collected, or for a maximum of two years where those purposes no longer become necessary.

3.4 SUPPLIERS

We collect and process personal data about our suppliers, subcontractors, and the individuals associated with them. The data is held to manage our relationship, to contract and receive services from them, and in some cases to provide professional services to our clients.

Why do we process data?

  • Receiving goods and services: we process personal data in relation to our suppliers and their staff as necessary to receive the services.
  • Providing services to our clients: where a supplier is helping us to deliver professional services to our clients, we process personal data about the individuals involved in providing the services in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our clients.
  • Administering, managing and developing our businesses and services: we process personal data in order to run our business, including:
  • managing our relationship with suppliers;
  • developing our businesses and services, such as identifying client needs and improvements in service delivery;
  • maintaining and using IT systems;
  • hosting or facilitating the hosting of events; and
  • administering and managing our website, systems and applications.
  • Security, quality and risk management activities: we have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers. We collect and hold personal data as part of our supplier contracting procedures. We monitor the services provided for quality purposes, which may involve processing personal data.
  • Promoting our services: we may use business contact details to provide information that we think will be of interest about us and our services. For example, industry updates and insights, other services that may be relevant and invites to events.
  • Complying with any requirement of law, regulation or a professional body of which Goshawk is a member: we are subject to legal, regulatory and professional obligations. We need to keep certain records to show we comply with those obligations and those records may contain personal data.

What data do we hold?

We hold the data that is necessary for the purposes listed above. As an example, we will typically hold supplier’s names, contacts names, and contact details of suppliers.

How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). Data may be held for longer periods where required by law or regulation and in order to establish, exercise or defend our legal rights.

3.5 PEOPLE WHO VISIT OUR OFFICES

Goshawk itself does not collect personal data when individuals visit our offices, neither via CCTV nor a visitors’ sign-in book. Where we receive personal data from a third party which manages our offices that relates to an individual, we request that this third party informs the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.

Third parties have security in place at our offices, for the physical security of client information and for the benefit of our staff. Signs in our office reception would confirm if CCTV is in operation. The images would be held securely by the third party and only accessed when needed when investigating an incident.

In order to hold and process the visitor details and CCTV, we believe it is a legitimate business interest that visitors may be captured and managed in this way.

Why would we process data?

CCTV and building access controls may require visitors to our offices to sign in at reception and keep a record of visitors. This is retained in case of theft or other incident and to protect the staff and information in the office.

What data would we hold?

Personal data that may be stored on CCTV would be footage of those visiting our offices. Our visitor book may include name, business, times and car registration.

How long would we hold data for?

Visitor records are accessed on a need-to-know basis only. CCTV recordings are typically overwritten after a short period of time unless an issue requiring investigation is brought to our attention.

3.6 PEOPLE WHO USE OUR WEBSITE, E-MAIL ADDRESSES OR PHONE NUMBERS

When people visit our website, personal data is collected both through automated tracking and interactions with various forms on the website or apps (collectively referred to as the websites).

Personal data may also be collected when individuals correspond with us by phone, e-mail or otherwise. This includes information provided when an individual registers to use our websites, subscribes to our services, makes an enquiry, comments on publications, enters a competition, promotion or survey, applies to work or reports a problem with our websites.

When individuals visit our websites, certain personal data may be automatically collected. We work with third parties who may collect data on our behalf (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).

Often, individuals who visit our website additionally fall into another category as listed by this privacy statement. For instance, users of our websites may be current clients, business contacts or become clients in the future. Where this is the case, data held and processed for individuals who use our website may also become data that is held and processed for another purpose.

Why do we process data?

There are a number of reasons why we will process the personal data that an individual may provide to us when visiting our websites. As examples, these include;

  • Administration: in to administer our site and to improve internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. For example, we use this data to ensure that the website is presented well for individuals and is optimised appropriately.
  • Functionality: in order to allow individuals to use some functionality of our website, certain personal data must be entered in order for features to work as intended.
  • Security: in order to keep our site safe and secure, we may sometimes collect personal data, for instance login information and other data that can be used to vouch an individual’s identity.
  • Promotion and development of our offerings: some personal data may be used in order to measure or understand the effectiveness of marketing to individuals.

What data do we hold?

The data that we hold depends on what data was entered and for what purpose.

Where data was entered in order to engage with functionality of our website, that personal data may typically include: their name, address, e-mail address and phone number, but is unlikely to include financial and credit card information, personal description and photograph.

Where data is collected automatically, the data that we may collect includes technical information, including the Internet protocol (IP) address used to connect an individual’s computer to the internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

Other data about an individual’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call us.

Our website uses cookies to distinguish individuals from one another. This helps us to provide a better experience when individuals browse our website and also allows us to improve our site.

How long do we hold data for?

We retain the personal data processed by us in a “live” environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years).

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

4. SHARING PERSONAL DATA

We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

Personal data held by us may be transferred to:

  • third party organisations that provide applications/functionality, data processing or IT services to us. We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services.
  • third party organisations that otherwise assist us in providing goods, services or information.
  • auditors and other professional advisers.
  • law enforcement or regulatory agencies or those required by law or regulations.

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

5. LOCATIONS OF PROCESSING

Where possible, personal data resides within the UK or EU but may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff members operating outside the EEA who work for us or for one of our suppliers. We will take all reasonable steps to ensure that your data is treated securely, in accordance with this privacy statement.

We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EEA are done lawfully. Where we transfer personal data outside of the EEA to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU.

6. INDIVIDUAL’S RIGHTS

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights as follows:

  • individuals may request access to their personal data held by us as a data controller.
  • individuals may request us to rectify personal data submitted to us or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which they registered.
  • individuals may request that we erase their personal data
  • where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us or clicking on the unsubscribe link in an email received from us.
  • individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.
  • individuals may request information about, or for human intervention into, any automated data processing that we may undertake.

If you wish to exercise any of these rights, please contact our Head of Data Privacy at this e-mail address: charles.gardner@goshawk.co.uk.

7. COMPLAINTS

If you do want to complain about our use of personal data, which we hope not, please send an e-mail with the details of your complaint to our Head of Data Privacy

at this address: charles.gardner@goshawk.co.uk. We will look into and respond to any complaints we receive within 28 days.

You also have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner’s Office (“ICO”). For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns

8. DATA CONTROLLER AND CONTACT INFORMATION

The data controller for Goshawk (Real Estate) Limited is Goshawk (Real Estate) Limited, whose Company Registration Number is 8483259. The company’s registered office address is The Old Chapel, Union Way, Witney, Oxfordshire, OX28 6HD.

If you have any questions about this privacy statement, or how and why we process personal data, please contact us at:

Head of Data Privacy Goshawk (Real Estate) Limited 42 Brook Street London W1K 5DB Email: charles.gardner@goshawk.co.uk Phone: 020 3174 2304

Website: http://goshawk.co.uk/

9. CHANGES TO OUR PRIVACY STATEMENT

This privacy statement was last updated on 23rd May 2018.