The Leaders Romans Group must look after your personal information by law. The main legislation that applies to protecting your information is:
This Privacy Notice applies to the use and processing of personal information collected under our trading names Leaders, Romans, Boyer, Portico, Revolution, Scott Fraser, Outlook, Moginie James, Hello Ted, Bode Insurance Solutions, Mortgage Advice Bureau, Mortgage Scout, Portico Financial Services, Relocate UK, Rebloom, Hill & Clark, Gibbs & Gillespie, Dewhurst, Orchards of London, Thorgills, Three Sixty Maintenance and Dunlop Heywood, which form part of The Leaders Romans Group. The Leaders Romans Group Limited is the overall Data Controller and we have a legal duty to protect any information we collect from you. The phrases 'us', 'we' or 'our' will mean those businesses listed above which form the Leaders Romans Group Limited.
Our statutory Data Protection Officer is Zara Harrington. She can be contacted by email at dataprotection@lrg.co.uk or in writing at Crowthorne House, Nine Mile Ride, Wokingham, RG40 3GZ.
This Privacy Notice covers use of personal information as defined in GDPR UK & the Data Protection Act 2018.
Personal data. This is information, or any combination of separate pieces of information, that could be used to identify you. This includes your name, address, contact details etc.
"Special category" personal data. This sensitive personal information is given more protection in law. For example, details of your health or nationality.
For more details of these definitions see below.
Personal data is any information relating to an identified or identifiable natural person "a data subject"; an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as their name, alias, address, national insurance number, telephone number, email, contact information, financial information, IP address. It can include information in different formats including electronic data, hand-written notes, voice recordings, photographs, CCTV footage.
Special category personal information is personal information which reveals racial or ethnic origin, political opinions, religious/spiritual/philosophical beliefs, trade union membership, genetic or biometric data, physical or mental health data, sex life or sexual orientation data, criminal or alleged criminal offences.
When you enquire or register for products and services provided by the Leaders Romans Group Limited we may collect personal information from a variety of sources.
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.
However, we may also obtain your personal data from other sources including:
We collect your personal information based on the service or services we are offering you. We will only collect the information needed. We will not sell your personal information to anyone. Some examples of information we may collect directly from you, can be found here:-
We may request additional information from you which is relevant to the provision of specific services. If we do this, we will always tell you why the information is needed.
If you ask us to provide you with life, critical illness, or landlord insurance and we may need to gather "special category" personal information, we treat this sensitive information in accordance with the additional protection it is given under the Data Protection Act 2018 and GDPR.
Telephone calls may be recorded for training, monitoring, and security purposes. We will always advise you before any recording commences.
Information we collect when you visit our websites
We use cookies and other technologies to collect information when you visit our web sites, including when you make use of our online chat.
We may collect personal information in connection with your use of our website, such as:
Details of how we use cookies are provided in our Cookies Policy.
Information obtained from online portals
Where you contact us via online portals such as Rightmove 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.
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.
CCTV & Call recording
We currently have CCTV installed in only a couple of branches for the prevention and detection of crime and to protect our business assets. Appropriate signage is displayed if CCTV is installed. Please ask branch staff.
We only record telephone calls in our call centre. You will hear a notification to advise you of the call being recorded if recording will occur.
We will process the information you provide or we obtain from other sources to provide you with products and services and answer any questions you may have. If you would like to see some examples of the how we use your information in the services we offer, please see below:-
The following are examples of how we use the information we collect:
To provide estate agency services, including marketing your property, valuing your property, arrange and carry out accompanied viewings, selling your property and helping you search for a new home
To provide a full lettings service for tenants, prospective tenants and landlords
To provide full property management and maintenance services
To advise on financial products, such as mortgages, insurance and protection products
To provide property auction services
To carry out regulatory checks to prevent fraud, unauthorised transactions, money laundering, tax evasion etc.
To register a tenant's deposit with a deposit protection scheme
To process payments of rent, and maintenance for you if a property is being let
To arrange an energy performance certificate or home report/survey inspections for you
To offer an inventory and check in/check out service for rented properties
To liaise with utility companies and local authorities regarding property services
To carry out tenant referencing and credit reference checks
To monitor and improve our products and services
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.
The Leaders Romans Group processes your personal information under any of the following lawful conditions:
Consent 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) GDPR - for example carrying out money laundering checks.
Legitimate interests Article 6 (1)(f) GDPR - some personal information is processed by the Leaders Romans Group as part of its legitimate interests which includes direct marketing, web analytics, sales and lettings.
The lawful basis for processing "special category" personal information
The Leaders Romans Group 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) GDPR
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.
Withdrawing consent
You have the right to withdraw your consent at any time. Please contact the branch or office you have been dealing with.
Children's privacy
We do not offer any products or services to children (defined as under the age of 16 in GDPR UK). In some circumstances, for example a mortgage application, we may be required by the mortgage provider to collect the names and dates of birth your dependent children or other adults who may reside with you.
We may share information within the Leaders Romans Group to provide you with an agreed product or service, for example planning advice or mortgage services or for any other purpose agreed by you.
Third Party service providers
Where we engage third party service providers to provide products (such as mortgages, home/contents insurance or utility services) or business services, (such as credit reference checks) we provide them with the minimum personal information needed to perform the service or provide the product we have requested. We ensure all third party service providers understand they are required to protect your information, and not to use it for any other purpose.
If you would like to see the third party organisations we share your information with and why, please below:-
We are required to keep your information for as long as is reasonably necessary to fulfil our legal and regulatory obligations. We have a Retention and Destruction Schedule to ensure we comply with the relevant legislation when processing your information.
Anonymised information on properties and geographical areas may be kept for longer to assist us with property market forecasting and trends. Anonymised information is not subject to privacy legislation or the Data Protection Act 2018 and may be kept for as long as it is needed.
Where you contact us via our website, in branch or by phone, or via online portals such Rightmove 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:
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. If you would like to unsubscribe from our email service, please contact unsubscribe@lrg.co.uk. We aim to stop emails within 3 working days, but this may be extended to 10 working days over public holidays and to cover staff absence within the Data Protection Team.
You have a number of rights concerning the personal information we process about you. You have the right to:
Subject Access Request
If you wish to make a request for access to a copy of your personal data, or to exercise any of your other rights, please write to your local branch in the first instance. Further information on the request process and a subject access request form is available from dataprotection@lrg.co.uk Please be aware if we receive all the necessary information with your request, we are able to locate your data and send it to you more quickly.
We will endeavour to respond to and comply with your request as quickly as possible. We are aware of the statutory deadline for a subject access request, however we will always try to send your information before the legal deadline.
Making a data subject access request
We have a form to assist you with making your request, it is available from dataprotection@lrg.co.uk
We store your personal information on our electronic computer systems and in our paper filing systems.
In accordance with the law we have strict security procedures to ensure that personal information is not damaged, destroyed or misused, and to prevent unauthorised access to your information. We have an internal breach reporting system to record all information security incidents and breaches. Serious data breaches are reported to the ICO within 72 hours, in accordance with the GDPR UK and the Data Protection Act 2018.
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 the Leaders Romans Group, we are not responsible for their compliance with the GDPR UK, the Data Protection Act 2018 or other privacy legislation.
Updates to our Privacy Notice
We reserve the right to amend and update this Privacy Notice as required, therefore it is advisable you review this notice at regular intervals.
This Privacy Notice was last updated in November 2021.
If you wish to make a complaint about our compliance with data protection or GDPR to our statutory Data Protection Officer Zara Harrington, please write to her at dataprotection@lrg.co.uk
We ask you to state in your complaint, the following information to enable an independent investigation:-
Once we have the information above, an investigation will be carried out by the Data Protection Team. We aim to respond to your complaint as soon as possible, but no later than 10 days from receipt. If you remain dissatisfied following a complaint to our Data Protection Officer, you can submit a complaint about data protection, privacy and data sharing issues directly to the Information Commissioner's Office (ICO) at:
Information Commissioner's Office Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Website: https://ico.org.uk/ Email: casework@ico.org.uk Telephone: 0303 123 1113
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