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Privacy Policy

GENERAL DATA PROTECTION REGULATIONS (2018) PRIVACY POLICY
CUSTOMER PRIVACY POLICY
In compliance with the General Data Protection Regulations (GDPR) 2018, Henry Graham Estate Agents (where Controller of your personal information), Is committed to protecting your privacy and ensuring that the information we hold regarding you is used for the purposes stated and is maintained securely. To that end this policy sets out to explain
• The information we collect and hold about you
• The lawful basis for using your data and how that information will be used
• Data retention periods
• How you can amend or delete information held
• Who to contact in the event of a complaint
• How data is stored and how it is destroyed
In addition, how we obtain and process your consent and how you can withdraw consent.
THE INFORMATION WE COLLECT AND HOLD ABOUT YOU
The information we collect and hold about you will be dependent on your relationship with Henry Graham Estate Agents: whether you are a vendor, purchaser, both vendor and purchaser, viewer, builder, landlord, tenant or mortgage applicant.
Most information will be provided by you when you make an initial enquiry to us and will be used to process your enquiry and progress the transaction specified by you.
This information will include some or all of the following:
• Your full name, address, landline telephone number, mobile number, email contact address
• Reason you decided to make contact with Henry Graham Estate Agents, e.g. browsing web site, saw ‘For Sale’ or ‘To Let’ board
• Whether you have a property to sell or rent and the status of the property i.e. is it in on the market for sale,
• Some general features of the property
• If an appointment to value the property is being requested
• Whether a mortgage is in place and if not, would a mortgage appointment referral be considered
• Your personal status and property ownership details
HOW YOUR INFORMATION WILL BE USED
Henry Graham Estate Agents can only process and share the information provided by you for certain lawful purposes within Henry Graham Estate Agents, this means we will only use the information provided to enable us to process and complete the transaction as entered into by yourself – selling/buying a property, progressing a mortgage appointment or renting a property (landlord and/or tenant). This includes new build developments purchases.
This includes:
• Marketing the property for sale (advertising your property on our web site, Property Pal and if appropriate other property related web sites or periodicals. Informing potential purchasers registered on our mailing list)
• Managing requests from interested parties to view the property and potentially make an offer to purchase
• Arranging viewings from said interested parties
• Securing information relating to an offers to purchase including source of funding, ID verification
• Arranging credit history checks for potential tenants
• Arranging mortgage appointments where this has been agreed to by the purchaser
• Liaising with surveyors, solicitors and EPC agents as required to successfully complete the sale of the property
• Arranging repair and inspection appointments in the case of tenants. These include property content inventories, gas boiler checks, minor and major property repair works.
We are required to adhere to the Money Laundering Regulations 2007 (under review) and therefore have an obligation to secure information regarding identity and funding. Under the regulations and the associated legislation, we are required to advise the appropriate agencies where we have concerns or suspicions regarding any transactions.
In rental situations, we are required to check credit histories on behalf of our landlords and therefore send and receive information from them to enable us to do so
We are required in certain rental situations to advise Her Majesty’s Revenue and Customs (HMRC) on rental incomes as well as responding from time to time to requests for information.
Once a property has been sold, we will retain information on selling price to enable future area price comparisons to be completed
Where offer individuals, should they wish, the opportunity to join a ‘mailing list’ service. This service enables unsuccessful bidders and those interested in purchasing generally to stay in touch with the market and new properties being listed. This service may be terminated at any time by the individual.
DATA RETENTION PERIODS
To comply with the Money Laundering Regulations, Henry Graham Estate Agents is required to retain your information for seven years. In the case of viewers who do not become purchasers, or those on our automated mailing list, the individual may delete their information at any point. All records are held securely and at the end of the required time period disposed of using a confidential waste disposal system.

CONSENT
We use the information you provide to us only for the purpose of ensuring the successful completion of your business with us. We do not generally ask for your consent however should we wish to use your information for reasons other than those detailed we will write and ask for your consent to do so.
Please refer to the GDPR Guide that forms part of our policy where you will find details including withdrawing consent.
ACCESSING, AMENDING OR DELETING INFORMATION
You have the right to get confirmation that your personal information is being processed and to access your personal information. This can be provided on request to the Director, Henry Graham Estate Agents, 58-60 Bachelors Walk, Lisburn, BT28 1XN
As a data subject you have the right to amend any information that is inaccurate or incomplete. Should inaccurate information have been disclosed to third parties involved in the transaction being processed on your behalf, we will advise them of the amendment where possible. To do so contact Henry Graham Estate Agents, 58-60 Bachelors Walk, Lisburn, BT28 1XN. Tel 02892672929 or email, info@hgraham.co.uk
Information can be deleted in certain circumstances, these include:
• Where consent has been withdrawn
• Where the personal information is no longer necessary
• When you have an objection to the processing and there is no legitimate interest in continuing the processing eg where you have withdrawn your sale or your offer on a property.
There are other considerations regarding your rights:
• You have the right to restrict processing – where there is an inaccuracy and this is being rectified
• The right to information portability – this allows in certain circumstance and where consent has been given, to reuse your data for your own purposes across different services
• The right to object – to the processing of your data based on legitimate interests, direct marketing (including profiling) and on your particular situation
• Your rights in relation to automated decision making and profiling – where you do not want to be subject to a decision based on automated processing where it has a legal or significant impact on you.
HOW DATA IS STORED AND HOW IT IS DESTROYED
All hard copy data is held on file, in a secure location. All data provided by e mail or other electronic means is stored on our central server and is kept secured using a variety of security and anti virus software systems.
Data is destroyed using a trusted confidential waste management disposal company who provide proof of destruction certification.
WHO TO CONTACT IN THE EVENT OF A COMPLAINT
Director
Henry Graham Estate Agents,
58-60 Bachelors Walk,
Lisburn,
BT28 1XN.
Tel 02892672929 or email, info@hgraham.co.uk
Further information can be found on the Information Commissioner web site
www.ico.org.uk
Original policy 25 May 2018

GENERAL DATA PROTECTION REGULATIONS GUIDE 2018
INTRODUCTION
In compliance with the General Data Protection Regulations (GDPR) 2018, Henry Graham Estate Agents, is committed to protecting your privacy and ensuring that the information we hold regarding you is used for the purposes stated and is maintained securely. To that end the General Data Protection Regulations Policy attached (also available on our web site www, jimmcmilan.co.uk)
CONSENT
Generally we do not rely on consent as a lawful basis for processing your personal data for the purposes you have requested
Based on the essential information you provide, Henry Graham Estate Agents will use that information for the clear and specific purpose of
• selling your property
• Advertising your property for rental
• processing the purchase, the property you have agreed on
• processing the tenancy of the property you have agreed to rent
and ensuring the process is concluded successfully and without undue delay.
The amount of information we collect and hold about you will be dependent on your relationship with Henry Graham Estate Agents in undertaking one or several of the above mentioned actions.
Most of information will be provided by you when you make an initial enquiry and will be used to process your enquiry.
This information will include some or all of the following:
• Your full name, address, landline telephone number, mobile number, e mail contact address
• Reason you decided to make contact with Henry Graham Estate Agents, eg browsing web site, saw ‘For Sale’ or ‘To Let’ board
• Whether you have a property to sell or rent and the status of the property ie is it in on the market for sale,
• Some general features of the property
• If an appointment to value the property is being requested
• Whether a mortgage is in place and if not, whether a mortgage appointment be considered
• Your personal status - employed/unemployed
Should an enquiry progress further, more information will be requested from you, this information will be essential to the progress of your enquiry and the nature of the transaction but may include
• Mortgage or financial information
• Family, probate or inheritance details
Henry Graham Estate Agents General Data Protection Regulations Policy details how we:
• collect
• process
• store
• retain
• destroy your information,
as well as your rights as a data subject to access, amend and delete your personal information.
We will need to liaise with a number of third party professionals and businesses who provide services essential to the complete the process you have asked of us and as detailed earlier in this guide.
These include:
• liaising with solicitors (purchaser and vendor),
• liaising with mortgage providers (regarding the status of mortgage applications)
• referral to in house mortgage agent (for purposes of arranging mortgage appointments)
• liaising with surveyors (on behalf of mortgage providers)
• liaising with energy performance agents (to complete required energy performance grading)
• liasing with credit referencing agencies (regarding credit status for tenants)
• liaising with NIHE and other housing agencies (regarding tenant information)
• liaising with professional contractors eg electricians, builders, boiler maintenance, inspection providers (to manage and maintain rental properties on behalf of Landlords)
The information we request is essential to undertake these actions. Should you not provide the information lawfully requested to fulfill our obligations to you, it may not be possible to complete your transaction
We may be required to contact HMRC and other associated agencies as per our legal obligations under the Money Laundering regulations and associated legislation.
Henry Graham Estate Agents will only use the information you provide to undertake the actions as above. We will not use or give any information to other third parties for the purposes of marketing without obtaining your specific consent to do so.
CONSENT AND YOUR RIGHTS
This guide gives you information on what consent is and how we obtain and process it. It also outlines how you can withdraw consent.
The information we collect and hold about you will be dependent on your relationship with Henry Graham Estate Agents: whether you are a
• vendor,
• purchaser,
• both vendor and purchaser,
• viewer,
• landlord,
• tenant,
• mortgage applicant.
Most of information will be provided by you when you make an initial enquiry to Henry Graham Estate Agents either in person, by telephone or using e mail or a web based enquiry.
In many situations there are several bidders for
• a property marketed for sale
• a rental property for let
In these cases, we will offer, or you may request the opportunity to register for mailing list updates of current properties.
Those registered on the Henry Graham Estate Agents mailing list may de register at any time using the unsubscribe link. Their data will be deleted automatically. Reregistration may be done at any time.
CONSENT
Consent must be
• Given freely
• Be specific in terms of what it is being used for
• Informed
• Unambiguous
• Not implied
At Henry Graham Estate Agents we will take the time to explain what information we require, why we require it and how it will be used so that you are completely aware of what information is being asked for. Information requested will not be superfluous to the task of estate agency and the successful completion of the transaction being undertaken.
• Withdrawing your consent
You may choose to withdraw your consent to use information given. This means you will not receive any marketing or other information.
• Changing your personal information
You should contact the office at Henry Graham Estate Agents, 58-60 Bachelors Walk, Lisburn, BT28 1XN, 02892672929 or email info@hgraham.co.uk should your personal information change

WHO TO CONTACT FOR FURTHER INFORMATION

Director
Henry Graham Estate Agents,
58-60 Bachelors Walk,
Lisburn,
BT28 1XN,
02892672929 or email info@hgraham.co.uk
Further information can be found on the Information Commissioner web site
www.ico.org.uk