Personal Information is any information that tells us something about you.

We will collect personal information including your full name and contact details (such as phone number, email address and postal address) from you whenever you engage with us.

In addition, where we are required to do so by law, we will collect information for proof of identity purposes, which will be at least one form of photographic identification (e.g. a passport or a driving licence) and one form of documentation with proof of your place of residence (e.g. a recent utility bill).

Depending on the service that we provide to you, or on your behalf, we may also collect additional personal information, including but not limited to:

• Where you are not the legal owner of the property in question we may need to request details from you as to your ability to sell or let the property such as a Power of Attorney, Guardianship Order or Confirmation
• We may collect your bank account details to arrange the onward transfer of funds, depending on which of our services you engage us on
• We may ask if you have any specific access requirements if you are looking to rent or buy a new property or to arrange a viewing
• We may need to request additional emergency contact information in case we need to get in touch with you outside of working hours or in the event there is a matter requiring your urgent attention.

Our use of personal information will always have a lawful basis, either because it is required to comply with a legal obligation, because it is necessary for our performance of a contract with you, or because you have consented to our use of personal information.

We may also process your personal information where the processing is necessary for us to carry out activities which it is in Coulters’ legitimate interests to do so, provided that your interests and fundamental rights do not override those interests. This may include processing that is necessary for us to promote our brand and services and measure the effectiveness of our marketing. This will include sending you marketing information from time to time which may be 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.

There are certain circumstances where we will share your personal information. These circumstances will include, but are not limited to:

• If you are purchasing a property where we are acting as agents for the seller we may share your personal information with your appointed solicitors and the solicitors acting for the other side of the transaction.
• If we sell any part of our business and/or integrate it with another organisation your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers. If this occurs the new owners of the business will only be permitted to use your information in the same or similar way as set out in this privacy notice.
• We may share personal information with our regulators, 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.
• We may share your personal information with third party providers who process personal information on our behalf, such as IT providers and third party referencing or screening agencies for the purposes of the prevention and detection of crime.

All personal information is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected.

We have measures in place which are designed to prevent unauthorised access to your personal information including but not limited to:

• Our digital client files are stored on our secure client management systems
• Access is restricted on our client systems to those within the business who are required to have access to your information for legitimate business purposes
• Active paper documentation is stored in locked cabinets
• Archived client files are stored off site at a secure facility
• Hardware is encrypted

All systems used to store personal information protect against unauthorised access and access is restricted to those absolutely necessary in order to fulfil our contract with you and comply with our legal obligations.

The period for which we will keep your personal information will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in case of a legal claim.

A cookie is a small text file that is downloaded onto your computer when you visit certain websites and allows a website to recognise a user’s computer. Cookies are used to help users navigate websites more efficiently and to perform certain functions, as well as to provide information to the owners of the website.

Your web browser may allow you to restrict or delete cookies set by this website. The Help function within your browser should tell you how. Alternatively, you can visit www.allaboutcookies.org which provides general information about cookies and how you can manage cookies on your computer.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

You have a number of rights in relation to your personal information. These include the right to:

• Obtain access to the personal information we hold about you
• Request to be informed about how we use your personal information
• Correct any personal information we hold about you if you believe it is incorrect
• Request that we delete any personal information we hold about you
• Ask us to restrict our data processing activities where:
  • You consider that personal information is inaccurate
  • You consider that processing of your personal information is unlawful
  • You consider that 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
  • 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.
• Not be subject to wholly automated decisions which produce legal effects or which could have a similarly significant effect on you.
• Our Data Protection Lead is Wilson Browne, Partner.

If you would like to exercise any of your rights, please contact data@coulters.io.

If you have any complaints about the way we use your personal information please email data@coulters.io. If we cannot resolve any issue, you have the right to complain to the data protection authority in your country (the Information Commissioner in the UK).

The company collects a range of information about you. This includes: 

• your name, address and contact details, including email address and telephone number; 

• details of your qualifications, skills, experience and employment history; 
• information about your current level of remuneration, including benefit entitlements; 
• whether or not you have a disability for which the company needs to make reasonable adjustments during the recruitment process; 
• information about your entitlement to work in the UK; and 
• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief. 

The company collects this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment. 

The company will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. The company will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so. 

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email). 

The company needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you. 

In some cases, the company needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts. 

The company has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the company to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The company may also need to process data from job applicants to respond to and defend against legal claims. 

Where the company relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not. 

The company processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment. 

Where the company processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes. 

For some roles, the company is obliged to seek information about criminal convictions and offences. Where the company seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment. 

If your application is unsuccessful, the company will keep your personal data on file in case there are future employment opportunities for which you may be suited. The company will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time. 

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles. 

The company may share your data with third parties for the purposes of processing your job application and possible employment. Should your application be successful, the company will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks. 

The company will not transfer your data outside the European Economic Area. 

The company takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

If your application for employment is unsuccessful, the company will hold your data on file for 4 months after the end of the relevant recruitment process. If you agree to allow the company to keep your personal data on file, the company will hold your data on file for a further 14 months for consideration for future employment opportunities. At the end of that period or once you withdraw your consent, your data is deleted or destroyed. 

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice. 

As a data subject, you have a number of rights. You can: 

• access and obtain a copy of your data on request; 
• require the company to change incorrect or incomplete data; 

• require the company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; 
• object to the processing of your data where the company is relying on its legitimate interests as the legal ground for processing; and 
• ask the company to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the company’s legitimate grounds for processing data 

If you would like to exercise any of these rights, please contact data@coultersproperty.co.uk and mark your email Job Application Privacy Enquiry.  

If you believe that the company has not complied with your data protection rights, you can complain to the Information Commissioner. 

You are under no statutory or contractual obligation to provide data to the company during the recruitment process. However, if you do not provide the information, the company may not be able to process your application properly or at all. 

Recruitment processes are not based solely on automated decision-making.