Stratton Creber Commercial is committed to ensuring that your privacy is protected, and our use of your personal information is governed by this Privacy Notice. On this site, “Stratton Creber Commercial”, “our” and “we” each mean all SCC (South West) Ltd SCC (Cornwall Ltd) & SCC (Exeter) Ltd in the manner set out in this Privacy Notice. Any reference to “you” or “your” refers to anyone whose personal information we process.
Our use of your personal data will be governed by this Privacy Notice.
Stratton Creber Commercial is a controller for the personal information that it collects and uses about you. We will treat your personal information as confidential in accordance with applicable data protection legislation and your personal information will only be shared with others in accordance with this Privacy Notice.
This Privacy Notice explains:
- Who we are
- What personal information is
- What personal information we collect
- How we use your personal information
- The legal basis for processing your personal information
- How we keep your personal information secure
- How long we keep your personal information
- Your rights in relation to your personal information
- How to make complaints and how to contact us
If there are any changes to the way in which your personal information is used, this Privacy Notice will be updated.
2. Who we are
We are Stratton Creber Commercial, a UK based firm of property consultants providing a variety of property services and advice.
3. What is personal information
Personal information is any information that tells us something about you. This could include information such as name, contact details, date of birth, bank account details or any information about your needs or circumstances which would allow us to identify you.
4. What personal information do we collect?
We will collect your full name and contact details (such as phone number(s), email address and postal address) from you whenever you engage with us. Depending on the service that we provide to you (on your behalf) we may also have to collect additional personal information.
In addition, if we are providing a service to you, or on your behalf, where we are required to do so by law, we will collect information relating to your identity, which will be at least one form of photographic identification (such as a passport, a driving licence or an identification card) and one form of documentation with proof of your place of residence (such as a recent utility bill).
We will also confirm whether you have any relatives or close connections working at Stratton Creber Commercial so that we can consider potential conflict of interests and if identified how to manage these, in accordance with our statutory and regulatory obligations.
5. How we use your personal information
What is the legal basis of our data processing?
Under data protection legislation we are only permitted to use your personal information if we have a legal basis for doing so. We rely on the following legal bases to use your information:
- For employment-related purposes
- Where we need information to perform the contract we have entered into with you
- Where we need to comply with legal or regulatory obligations
- To use in the investigation and/or defence of potential complaints, disciplinary proceedings and legal proceedings
- To enable us to invoice you for our services, for rent, service charge and other costs that you are contractually obliged to pay
- To maintain and administer our software systems and IT infrastructure
- To notify you of changes to our services and answer requests
- Where the processing is necessary for us to carry out activities for which it is in Stratton Creber Commercial’s legitimate interests (or those of a third party) to do so and provided that your interests and fundamental rights do not override those interests, including:
- Processing that is necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaign. – this will include sending you marketing information from time to time after you have engaged us to provide services or received services from us either which may be similar and of interest to you or where you have expressly indicated that you would like to receive such information. You have the right to opt out of receiving this information at any time.
- Processing that is necessary to improve our knowledge of the real estate sector – this will include undertaking market analysis and research so that we better understand trends in the property sector and provide better knowledge along with more tailored and relevant services for our customers in the future.
- Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively – this will include: verifying the accuracy of information that we hold about you and create a better understanding of you as a customer; processing for administrative efficiency purposes such as where we outsource certain administrative functions to third parties who are specialise in such services; processing for network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access or to comply with a request from you in connection with the exercise of any of your rights outlined below.
In more limited circumstances we may also rely on the following legal bases:
- Where we need to protect your interests (or someone else’s interests); and/or
- Where it is needed in the public interest or for official purposes
Other uses of your personal information.
- We will share personal information with our regulators, professional body, governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our regulatory and legal obligations;
- Where we use third party services providers who process personal information on our behalf in order to provide services to us. This includes IT systems providers and IT contractors as well as third party referencing or screening agencies for the purposes of the prevention and detection of crime.
- We may share your personal information with any person working within Stratton Creber Commercial on a need to know basis to ensure we are able to perform our obligations to you.
- From time to time we will share your personal information with third party contractors or suppliers as is necessary to allow us to fulfil our obligations to you and your interests.
6. How we keep your information secure?
The security of information is very important to us and we have measures in place which are designed to prevent unauthorised access to your personal information including but not limited to:
- Our files are stored on our secure management systems. Access is restricted on our systems to those within the business who are required to have access to your information for legitimate business purposes.
- Hard copy documentation is stored in locked cabinets.
All data is hosted in datacentres which have systems and protections in place to protect against both unauthorised access, and other external factors that could cause damage to, your personal data. There are strict access requirements in place and access is restricted to those absolutely necessary.
We ensure access to personal information is restricted to Stratton Creber Commercial employees and workers. Training is provided to any of those Stratton Creber Commercial employees and workers who need access to personal information.
7. For how long do we keep your personal information?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, regulatory, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
8. Your rights in relation to your personal information.
- To be informed about how we use your personal information
- To obtain access to your personal information that we hold
- To request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate
- Request that we erase your personal information in the following circumstances:
- If Stratton Creber Commercial is continuing to process personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected
- If Stratton Creber Commercial is relying on consent as the legal basis for processing and you withdraw consent
- If Stratton Creber Commercial is relying on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us to continue with the processing
- If the personal information has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation)
- If it is necessary to delete the personal information to comply with a legal obligation
- Ask us to restrict our data processing activities where you consider that:
- personal information is inaccurate
- our processing of your personal information is unlawful
- where we no longer need the personal information, but you require us to keep it to enable you to establish, exercise or defend a legal claim
- where you have raised an objection to our use of your personal information
- Request a copy of certain personal information that you have provided to us in a commonly used electronic format. This right relates to personal information that you have provided to us that we need in order to perform our agreement with you and personal information where we are relying on consent to process your personal information
- Object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal information; and
- Not be subject to wholly automated decisions which produce legal effects, or which could have a similarly significant effect on you.
If you would like to exercise any of your rights, please contact email@example.com or in writing to Farrer Court, 75 North Hill, Plymouth, PL4 8HB.
9. Complaints and Contact Details.
If you are not a client of ours but you complain to us about how we have processed your Personal information, or you seek to exercise a data protection right such as a data subject access request, we will retain details of your complaint or request. We will only use the Personal Information we collect to process the complaint or request, to audit the level of service we have provided and to provide information to the regulator.
We hope that we can resolve any query or concern you may raise about our use of your information. If you want to complain about how we have handled your Personal Information, please email firstname.lastname@example.org
We will investigate your complaint but if you are not satisfied with our response or believe we are processing your Personal Information unlawfully, you can complain to the UK Information Commissioner’s Office (ICO). Further information is available on the ICO website www.ico.org.uk.