Privacy Notice
Dawsons Privacy Notice
Dawsons are committed to protecting your personal data and respecting your privacy.
This privacy notice covers use of your personal information as defined in the GDPR UK and the Data Protection Act 2018.
This privacy notice provides information on how Dawsons use and process personal information collected under our trading name/s, associated businesses and Third party Service Providers. Dawsons is provider of Residential Sales, Residential Lettings, Surveying Services, Leasehold Estate Management Services, Commercial Sales and Lettings, Land and New Homes, Auctions and Dawsons Training Wales.
Third Party Service Providers
Mortgage Advice Bureau, Relocation Agent Network, Fine and Country, EU Auction Platform, Feefo,Tenancy Deposit Scheme, Rent Smart Wales, Rent Insurance Providers, Maintenance Contractors, Utility Companies, Solicitors, Mortgage lenders, Approved Contractors, Sprift, Acaboom, Spectre, Alto, Focus, Arla PropertyMark, The Property Ombudsman, Debt Collection Companies, Local Authority, Referencing Companies
The main legislation that applies to protecting your information is:
- General Data Protection Regulations (UK) (GDPR UK)
- Data Protection Act 2018 (DPA)
- Human Rights Act 1998 (Article 8) (HRA)
- Privacy and Electronic Communications Regulations 2003 & 2011 (PECR)
- Money Laundering Regulations 2017
- Proceeds of Crime Act 2002
- The Data Protection, Privacy and Electronic Communications (Amendments etc.)(EU Exit) Regs 2019
- Telecommunications (Lawful Business Practice (Interception of Communications) Regulations 2000
- Regulation of Investigatory Powers Act 2000 (RIPA)
Methods of Collection
We only collect the data required to fulfil our contractual and legal obligations in connection with the services we provide. The majority of the personal information we collect will have been provided by you during the course of your relationship with us either through face to face contact, by telephone, email or electronic communication such as messaging or emails.
Personal data we collect will include:
- Full contact details (Name, contact number, email & postal address)
- Precious Names and number of dependants
- Gender
- Marital status
- Nationality
- Employment status and employer
- Details of your mortgage arrangements
- Proof you have available funds to support any offer to buy a property
- Financial information, such as bank statement, mortgage offer
- Employment details
- Insurance
- National insurance number
- Residential status
- Credit history
- Bank details
- Credit card details and statements
- Personal/Secure Loan details
- Pay slips
- Personal Debt details
- Doctors
- Banking details (for payment of rent)
- Any communication with us in the form of emails or telephone conversations.
- Your marketing, purchasing or letting preferences
- Identity details, for example passports/Driving licence
- Technical information about your visit and use of our website
- Referees
However, we may also obtain your personal data from other sources including:
- Information we collect when you visit our websites.
- other companies, for example our mortgage brokering service
- companies which support advertising services that promote our services including
- online property portals (such as Onthemarket.com and Zoopla), social media and networking sites (such as Facebook and Twitter) and online advertising platforms
- information provided to us by other third parties, such as your solicitor
- other publicly available sources such as the Electoral Roll and Land Registry
Information obtained from online portals
- Where you contact us via online portals such as Onthemarket.com or Zoopla, we will use your contact details to enable us to communicate with you and offer the services you have enquired about.
- Information obtained from third parties
Where we are required by law, or for legitimate business needs, we will obtain information about you from third parties, but only after we have your consent to do so. For example, the third parties we may need to contact include: credit reference agencies, employers, banks, solicitors etc. in order to obtain references, verify your identity and confirm your income.
In addition, you may choose to submit information directly to us via several methods, including: through Dawsons and affiliates websites in response to marketing or other communications through social media by signing up for a Dawsons product or service through participation in an offer, program or promotion in connection with an actual or potential business or employment relationship with us.
We, our service providers and partners collect certain information by using automated means, such as cookies and web beacons, when you interact with our advertisements, mobile applications, or visit our websites, pages or other digital assets.
The information we collect in this manner may include: IP address, browser type, operating system, referring URLs and information on actions taken or interaction with our digital assets.
Criminal disclosures
Certain types of insurance may involve disclosure by you of information relating to historic or current criminal convictions or offences. When we process any criminal records checks we do so in accordance with The Data Protection Act 2018 (Schedule 1, Part 3, Paragraph 33) and Article 10 GDPR UK. We will only carry out such checks where they are necessary.
We may use third-party web analytics services on our websites and mobile apps, the analytics providers that administer these services use technologies such as cookies and web beacons to help us analyse how visitors use our websites and apps. "Your Rights and Choices" section of this Privacy Notice specifies your ability, to opt out or limit the usage of the information collected.
Purposes of collection
Generally, we will collect, use and hold your information for the purposes of: Assessing applications for and providing Dawsons products/services.
Conducting business, developing relationships with Dawsons and affiliates.
Process payments / transactions including: Accounting, Authorisation,
Clearing, Chargebacks, Auditing, Billing, Reconciliation, Collection,
Complaints, Enquiries, Credit Checks and related dispute resolution activities.
Protect against and prevent fraud, unauthorised transactions, money laundering, tax evasion, claims, other liabilities and manage risk exposure and agent /franchise quality, integrity, compliance and security of business processes.
Create and manage any accounts, associated authentication criteria (id’s and passwords) you may have with Dawsons.
Provide, administer and communicate with you about Dawsons products, services, offers, programs and promotions, their issuers, acquirers, retailers and partners.
Compile business directories, including business contact information.
Operate, monitor, evaluate and improve our products, services, websites, mobile applications, other digital assets and business.
Developing new products and services.
Managing communications, assess effectiveness and optimisation of
advertising.
Functionality of our websites, mobile applications other digital assets
Evaluate your interest in employment and contact you regarding possible employment opportunities
Enforce Dawsons “Terms of Use”, other legal rights as may be required by
applicable laws and regulations or requested by any judicial process or governmental agency having or claiming jurisdiction over Dawsons or its affiliates.
Comply with industry standards and Dawsons policies.
Lawful basis of processing
Article 6 (1)(a) GDPR - if we process information under consent we will seek your clear and affirmative consent before processing your data, for example, to receive marketing information of properties for sale or to let.
Performance of a contract Article 6 (1)(b) GDPR - this is where the collection and processing of your data is necessary for the performance of a contract to which you are a party.
Legal obligation Article 6 (1)(c) GDPR- where the collection and processing of your personal data is necessary for compliance with a legal obligation, for example, to comply with the Data Protection Act, verify your identity, for fraud and money laundering prevention.
Processing is necessary for the performance of a task carried out in the public interest Article 6 (1)(e) for example carrying out money laundering checks.
Legitimate interests Article 6 (1)(f) GDPR - some personal information is processed by Dawsons as part of its legitimate interests which includes direct marketing, web analytics, sales and lettings.
The lawful basis for processing “special category” personal information
Dawsons processes “special category” information only when it is necessary. The lawful basis we use to process your “special category” information is:
Explicit Consent Article 9 (2)(a) GDPR – is freely given, specific and unambiguous consent before the processing of your data. For example, your health information will be needed to process an application for critical illness insurance.
Data that has been made public Article 9 (2)(e)
Establishing, exercising or defending a legal claim Article 9 (2)(f) GDPR – for advice on underwriting, arranging or administering an insurance contract (Schedule 1 Part 2 of Data Protection Act 2018) or on the suspicion of money laundering in line with the Proceeds of Crime Act 2002 (Section 339ZB)
You may want to inform us of your “special category” data voluntarily to enable us to offer you appropriate products or services. For example, you may have a health condition that means you are unable to climb stairs. We will record your needs/preferences without recording your medical/health conditions in most cases.
Our marketing services
Where you contact us via our website, in branch or by phone, or via online portals such Onthemarket.com or Zoopla we will use the details you have supplied to us to provide you with properties by email. You can choose to unsubscribe at any time.
We may contact you to offer information about our other products and services which we believe may be of interest to you. We use several methods of communication, including:
- By email
- By post
- Mobile Text Messages
- Telephone
We only send you promotional emails, mail, text messages or contact you by telephone, if you agree to each method of communication. You can stop receiving promotional mail, text messages or telephone calls by contacting your local branch
Information we share
We do not sell or otherwise disclose personal information we collect about you, except as described in this Privacy Notice or as indicated via the consent process at the time the data is collected. We share the information we collect with, but not limited to: Vetted affiliates and partners/Financial Institutions / Insurance Companies for business facilitation to provide required services, such as mortgages, insurance cover etc.
Formally contracted service providers to perform services on our behalf:
Hosting Datacentres, Infrastructure, Applications (Development / Support), Cloud Services (Software as a Service – SaaS, Platform as a Service – PaaS, Infrastructure as a Service – IaaS)
Helpdesk, Call Centres etc.
We contractually require these service providers to safeguard the privacy and
security of personal information they process on our behalf and authorise them to use or disclose the information only as necessary to perform services on our behalf or comply with legal requirements.
Councils, health and care providers
Other Law firms
Credit agencies, Land Registry Office, Her Majesty’s Revenue and Customs (HMRC),
Financial Conduct Authority (FCA) and other relevant regulatory bodies
Additionally, we may share information about you, if required legally, to prevent harm or financial / reputation loss, for investigation of suspected or actual fraudulent or illegal activities.
Perspective employers requesting references via your written consent
Dawsons reserve the right to transfer your information in the event of a sale or transfer (wholly or partially) of our business or assets, with reasonable efforts for the acquirer protect / use your information consistent with our Privacy Notice. You can exercise your rights to contact the acquiring entity with questions concerning the protection and processing of your information
Customer Surveys
We may invite you to participate in surveys from time to time to help us gather feedback on our products and services, to make improvements. We may use a third party company to carry out these surveys on our behalf.
Credit scoring & Automated Decisions
Some of the services provided by third parties may involve an automated decision or credit scoring to determine whether we are able to provide a service or product. You have a right to challenge an automated decision and ask for the issue to be considered by human intervention.
How long do we keep information for
We will keep information for a reasonable amount of time in order to perform the purposes listed above.
We only keep your information for as long as necessary. We generally keep personal information for 7 years after last contact with you. However Dawsons reserves the right to
keep information for longer if we feel that this is in the legitimate interests of Dawsons.
Data transfers
The GDPR UK applies to the UK only. GDPR UK is based on the GDPR EU which applies all countries within the EU and European Economic Area (EEA). The EU and the UK have agreed adequacy status for the continued free-flow of personal data within the UK, EU and EEA. We will ensure that there is adequate security and comparable legislation in place before sending your information to other countries outside the EEA. In accordance with the Data Protection Act 2018 and UK GDPR, if we need to transfer data outside the EEA and the country it’s transferred to is not on an approved list for having adequate security controls in place, we will limit the amount of personal data we send. We will also impose contractual obligations (standard contractual clauses) in accordance with the EDPB (European Data Protection Board) (as approved by the ICO) from the recipients to ensure the security and confidentiality of your personal data to safeguard your information.
Links to other websites
Our websites and communications with you may provide links to other websites for your convenience and information. These websites operate independently from us and have their own privacy notices or policies, which we strongly suggest you review. Where linked websites are not owned by Dawsons, we are not responsible for their compliance with the GDPR UK, the Data Protection Act 2018 or other privacy legislation.
Your statutory rights
You have a number of rights concerning the personal information we process about you. You have the right to:
- ask us for access to a copy of your personal information we hold about you. This is called a data subject access request. We may ask you to provide ID to verify your identity.
- ask us to correct your personal information if it is inaccurate. We may ask you to provide confirmation to ensure the information we hold is accurate.
- ask us to delete your personal information. We are unable to delete your information if the law requires us to keep it for a statutory period or there is a lawful reason we must keep the information. We will always investigate any request and advise you, if we are unable to erase your data.
- withdraw your consent to use your personal information. Where you have provided consent for our processing of your personal data, you may withdraw that consent at any time by simply contacting the branch or team you have been speaking to.
- ask us to restrict the use of your personal data, including direct marketing.
- object to our use of your personal data for our legitimate business interests. You have an absolute right to object to our use of your data for direct marketing.
- object to an automated decision.
EQUAL OPPORTUNITY POLICY
We aim to ensure that no job applicant, employee, worker or customer is discriminated against on
the grounds of a protected characteristic. The following are protected characteristics:
a) Age;
b) Disability;
c) Gender Reassignment;
d) Marriage and Civil Partnership;
e) Pregnancy and Maternity;
f) Race (Including Colour, Nationality, and Ethnic or National Origin);
g) Religion or Belief;
h) Sex; and
i) Sexual Orientation
How to Contact Us / Complaints and Feedback
If you:
Make a complaint about a breach of your personal information, applicable privacy laws /
principles or a concern about Dawsons privacy practices
Would like access and/or update information or preferences you provided to us.
Write to us
Dawsons
Data Protection
11 Walter Road
Swansea
SA1 5NF
If we fall short of your expectations in processing your personal information or you wish to
make a complaint about our privacy practices, please contact us via your local branch in the first instance.
To assist us in responding to your request, please give full details of the issue. We attempt
to review and respond to all complaints within a reasonable time and no later 10 working days from receipt.
If we cannot for lawful reasons complete your request we will explain this to you to the extent that we lawfully can.
How We Protect Personal Information
The security of your personal information is very important and Dawsons is committed to
protecting the information we collect. We maintain administrative, technical and physical
safeguards designed to protect the personal information you provide or we collect against
accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.
We use SSL encryption on a number of our websites from which we transfer certain
personal information.
Dawsons stores personal information only for as long as it is necessary for the fulfilment
of the purpose for which the personal information was collected, unless otherwise required
or authorised by applicable law.
We take measures to destroy or permanently de-identify personal information if required by law or if the personal information is no longer required for the purpose for which we collected it.
Updating this privacy statement
We will update this statement from time to time so we suggest that you review this statement at regular intervals. Where we undergo substantial changes to our privacy statement we will endeavour to inform you directly about these changes.
Up-dated January 2022