Personal Data Fair Processing Notice - Sourcing

v1.1 Updated 8 September, 2020

This notice explains what information we collect, when we collect it and how we use this. During the course of our activities, we will process personal data (which may be held on paper, electronically, or otherwise) about you and we recognise the need to treat it in an appropriate and lawful manner. The purpose of this notice is to make you aware of how we will handle your information.

 

Who am I?

 

Wolf and Sword Services Limited at 45 Fife Street, S9 1NN, we take the issue of security and data protection very seriously and strictly adhere to guidelines published in the General Data Protection Regulation (EU) 2016/679 which is applicable from the 25th May 2018, together with any domestic laws subsequently enacted.

 

We are notified as a Data Controller with the Office of the Information Commissioner under registration number ZA778965 and we are the data controller of any personal data that you provide to us.

 

Our Data Protection Officer is Nicholas Osborn

 

Any questions relating to this notice and our privacy practices should be sent to 45 Fife Street, S9 1NN or nick@wolfandsword.com.

 

How we collect information from you and what information I collect

 

We collect information about you:

  • From your completed Sourcing Fact Find document
  • Through electronic and verbal correspondence during the sourcing process

 

We collect the following information about you:

  • Name, e-mail address, telephone number, date of birth, address.
  • Copies of ID documents such as passport and driving license
  • Proof of funds evidence – for example (but not limited to) a broker letter, copies of bank statements or screenshots of online banking.
  • Property investment preferences

 

Why we need this information about you and how it will be used

 

We need your information and will use your information:             

  • to undertake and perform our obligations and duties to you in accordance with the terms of our contract with you;
  • to enable us to supply you with the services and information which you have requested;
  • to carry out due diligence on any prospective client;
  • to analyse the information we collect so that we can administer, support and improve and develop our business and the services we offer;
  • to contact you in order to send you details of any changes to our suppliers which may affect you; and
  • for all other purposes consistent with the proper performance of our operations and business.

 

 

 

Sharing of Your Information

 

The information you provide to us will be treated by me as confidential.

 

We may disclose your information to other third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:

  • If we enter into a joint venture with or merge with a business entity, your information may be disclosed to our new business partners or owners;
  • To carry out due diligence on you as a prospective client;
  • To facilitate a purchase of a sourced property once you have indicated you wish to proceed, we will share your contact details, copies of ID documents and proof of funds with the agent for the property sale
  • For invoicing and if direct contact with 3rd parties involved in the project is required (such as builders, surveyors and service providers), we may need to share your contact details with these 3rd parties.

 

Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.

 

Transfers outside the UK and Europe

 

We may transfer your information outside the UK and/or EEA:

  • The cloud based storage systems used by our back office may replicate data outside of the UK and/or EEA for backup and availability purposes.

 

Where information is transferred outside the UK or EEA, we ensure that there are adequate safeguards in place to protect your information in accordance with this notice, including the following:

  • Decision by the Commission that the third country has adequate safeguards/ details of appropriate security provisions in place.

 

Security

 

When you give us information we take steps to make sure that your personal information is kept secure and safe.

 

  • Information is processed and accessed only by trusted associates of Wolf and Sword group of companies, or certified 3rd party organisations such as reference agencies.
  • Electronic access to the information is restricted

 

 

How long we will keep your information

 

We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract I have with you.

 

Our full retention schedule is available on request via email to nick@wolfandsword.com.

 

Your Rights

 

You have the right at any time to:

  • ask for a copy of the information about you held by us in my records;
  • require us to correct any inaccuracies in your information;
  • make a request to us to delete what personal data of yours we hold; and
  • object to receiving any marketing communications from us.

 

If you would like to exercise any of your rights above please contact us at nick@wolfandsword.com

 

Should you wish to complain about the use of your information, we would ask that you contact us to resolve this matter in the first instance. You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information.  The Information Commissioner’s contact details are noted below:

 

 

England:

Information Commissioner's Office

Wycliffe House, Water Lane

Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113

Email: casework@ico.org.uk

 

Scotland:

The Information Commissioner’s Office

45 Melville Street, Edinburgh, EH3 7HL

Telephone: 0131 244 9001

Email: Scotland@ico.org.uk

 

 

Wales

Information Commissioner's Office

2nd floor, Churchill House

Churchill way, Cardiff, CF10 2HH

Telephone: 029 2067 8400

Email: wales@ico.org.uk

 

Northern Ireland:

Information Commissioner's Office

3rd Floor, 14 Cromac Place

Belfast, BT7 2JB

Telephone: 028 9027 8757

Email: ni@ico.org.uk

 

 

The accuracy of your information is important to me - please help us keep our records updated by informing us of any changes to your email address and other contact details.