GOADSBY GROUP OF COMPANIES
- Goadsby & Harding (Holdings) Limited trading as Goadsby (Reg. In England No. 2446167)
- Goadsby & Harding (Residential) Limited trading as Goadsby (Reg. In England No. 1871280)
- Goadsby & Harding (Commercial) Limited trading as Goadsby (Reg. In England No. 4150232)
- St Pauls Surveying Limited trading as Goadsby (Reg. in England No. 02926416)
- St Manor Limited trading as Goadsby Mortgage Services & epcsouth (Reg. In England No. 04774941)
All of the above companies Registered Office is: 99 Holdenhurst Road, Bournemouth, BH8 8DY.
All of the above companies are individually ‘Data Controllers’ and you can contact each company by referring to the ‘How to Contact Us / Complaints and Feedback’ in 1.14 below.
Where we use the name Goadsby & Harding (Holdings) Ltd the policy applies to all group and relevant associated companies.
1.1 The information we collect
We may collect information about you from a variety of sources; the information we may typically collect is:
Names (including previous names)
postal addresses (including previous addresses)
usernames & passwords
log in/log off information
date of birth
dependants (number of and age)
next of kin
bank account details
mortgage statements and or information
credit card statements
personal debt details
proof of funds
self-employed accounts or HMRC Self-Assessment returns
future communication preferences
close circuit television recordings
vehicle tracking information
landlord details (including previous landlords)
estate agent details (including previous estate agents)
National Insurance Number
previous employers details
trade union membership
salary and or income details
personal information inputted on our computers
information held on you on publically available sources such as land registry
social media platforms (blogs/videos/text/internet postings and general user content),
web pages viewed
mobile application use
recorded telephone calls
Any other general information or fiscal information provided.
Staff Car Insurance and other car or driving licence related details
1.2 Information collection methods
The information we collect can be collected by various parties or methods; these include being collected from or via;
next of kin
publically available sources such as land registry
social media platforms
credit / default agencies
web pages view
emails opened or clicked
consented third parties
cookies and other technologies
face to face conversations
Such information will generally be collected by us via the use of any of our standard forms, over the internet, via email, or through a telephone conversation with you. We may also collect personal information through our affiliates or suppliers.
In addition, you may choose to submit information directly to us via several methods, including:
- in response to marketing or other communications
- through social media
- by signing up for a product or service
- through participation in an offer, program or promotion
- in connection with an actual or potential business or employment relationship with us
You may also agree to third parties disclosing information about you to us that those third parties have collected.
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.
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 limit the usage of the information collected.
1.3 Purpose of collection and how we use it
We use the information collected we collect to provide you products, offers and services, to deliver you advertisements, offers or other content tailored to your interests and to conduct other Goadsby & Harding (Holdings) Limited business operations and employment / administrative duties. Generally, we will collect, hold and may use your information for the purposes of:
- Providing, administering and communicating with you about services and products provided or marketed by Goadsby & Harding (Holdings) Ltd or associates.
- Develop new products and services.
- Protect or identify possible Money Laundering, fraud, tax evasion, claims.
- Manage risk exposure, integrity, compliance, security, sales performance and security of business processes.
- Accounting, auditing, reconciling, process payments and record transactions, authorisation, clearing, chargebacks, billing, collection, complaints and related dispute resolution activities, enquiries,
- Credit Checks
- Create and manage your account/files/logins/passwords.
- Compile business directories.
- Operate, evaluate, monitor and improve & develop our website, staff, products, services, mobile applications and generally help manage our business.
- Personalise your experience on our website and / or web applications.
- The enforcement of our terms and conditions of business or any other legal rights.
- Develop and provide marketing to you.
- Manage, evaluate and monitor employment or potential employment of you.
- Compliance with laws, industry standards and regulations.
- Compliance with industry standards and Goadsby & Harding (Holdings) Ltd policies, procedures and contracts.
- Allow the delivery of our products and services - Sales, Lettings, property management, professional property services, valuation services activities, building surveying activities, town planning, conveyancing referral, financial services, general insurance brokerage, EPC’s, Acquiring property, and any other core products or related ancillary property services.
- Compilation of statistics
1.4 Lawful basis of processing
Goadsby & Harding (Holdings) Ltd may process your information under different or more than one legal basis. Accordingly Goadsby & Harding (Holdings) Ltd may process your information under the following:
Performance of a contract – Where we have contracted with you we will need to process, retain and maybe share your information in order to perform in accordance with the contract or administer or enforce the terms of the contract.
Legitimate Interest – In addition to the above legal basis, all relevant services, employment or potential employment may require for us to process, retain and potentially share your information in order to fulfil our legitimate interest. Our legitimate interests include fraud, risk management, due diligence, network and information security, suppressions and managing opting out of communications, profiling, direct marketing, monitoring, web analytics, cloud storage, acquisitions, updating customer details and other core products and services provided by the Data Controller and any other factors which could be a legitimate interest.
Legal obligation – There may be circumstances where we have to process, retain and potentially share your information under a legal obligation with relevant government or relevant regulatory bodies such as (but not limited to), the Police, Serious Organised Crime Agency, National Crime Agency, Her Majesty’s Revenue & Customs, Department of Work and Pensions, Councils, Health and Care providers etc.
Vital Interest & Public Interest – We may need to carry out a task in the public interest which is laid down by law or a vital interest which may have circumstances where we have to process, retain and potentially share your information where there is, for example, a concern for the welfare of a person.
Consent – We may need to process your information where consent is required; in these circumstances, consent will sought from you before processing your information.
1.5 Sharing of your information
- Vetted affiliates / Financial Institutions / Insurance Companies and Brokers / Mortgage Companies for business facilitation to provide requested services.
- Vetted affiliates for the purpose of conducting consumer research
- Formally contracted service providers to perform services on our behalf:
- Law and Conveyancing firms
- Estate Agency firms
- Insurance Brokers and Insurers
- Utility firms or similar
- A Network Principal (Financial Services and General Insurance)
- 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.
- Our clients, purchasers, landlords, tenants and their solicitors etc.
- Councils, Health and Care providers
- Health Professionals
- Pension Providers
- Police or other Government Agencies
- Prospective employers requesting references
- Third Party Software Providers
- Relevant Ombudsman
- HMRC Approved Tenancy Deposit Schemes
On websites, features can be accessed where we may partner with other entities that are not affiliated with us. These include social networking, geo-location tools, valuation tools etc. who are operated by third parties (indicated appropriately) who may use or share personal information in accordance with their own privacy policies. It is recommended that you review the third parties' privacy policies if you use the relevant features.
We and/or associated third parties may transfer the personal information collected about you to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Notice or as otherwise disclosed to you at the time the data is collected (e.g. via program specific privacy notice).
This web site contains links to third party web sites over which Goadsby & Harding (Holdings) Ltd has no control. Specifically therefore, the third party operating any external web site is responsible for compliance with the General Data Protection Regulations (GDPR) for that web site. Goadsby & Harding (Holdings) Ltd assumes no responsibility for the content of third party web sites or for any losses which may arise out of use of a third party web site. The presence of a link to a third party does not necessarily mean that Goadsby & Harding (Holdings) Ltd endorses that site or has any association with the proprietor of that web site.
1.6 How long do we hold your information for
We only keep your information for as long as is necessary.
We will normally keep personal information for 7 years after the last contact with you but we may potentially delete it earlier. However, in certain instances we may need to retain the personal information longer for legal, accounting, fiscal or regulatory reasons.
For the purposes of business conduct, enhancement, identification of fraud, money laundering and other potential unauthorised activities, we may engage in profiling activities via direct use or anonymisation of sensitive personal information.
1.8 Direct Profiling
Direct profiling is engaged for the fair and lawful purposes, to provide us with the ability to enforce Goadsby & Harding (Holdings) Ltd policies, legal reporting as may be required by applicable laws, regulations, policies / standards or requested by any judicial process or governmental agency having or claiming jurisdiction over us or our affiliates; including, but not limited to:
- Background checks for customers
- Financial Viability analysis / reports
- Business partner / customer portfolio position, performance, risk positions
- Anti-money laundering
- Tax reporting
- Credit defaulting / exposure
1.9 Indirect Profiling
Indirect profiling via anonymisation of personal information is also used for preparing and furnishing aggregated data reports showing anonymised information, including, but not limited to, the following:
- Compilations, analyses, analytical and predictive models and rules, and other aggregated reports for the purpose of advising our partners / affiliates and servicing institutions, retailers and other customers regarding past and potential future patterns of service usage, spending, fraud, and other insights that may be extracted from this data.
- Compiling and communicating promotional and marketing information about products and services that we, our affiliates and other organisations that we have affiliations with have and that may be of interest to you.
- Conducting market research
- Facilitating our internal business operations, including the fulfilment of any legal requirements.
1.10 Your rights and choices
Your rights regarding the sensitive / personal information we maintain about you enable you to exercise choices about what personal information we collect from you, how we use that information, and how we communicate with you. However, if we require data for the purposes of performing a contract with you, it may not be possible to proceed unless you supply us with the data required for that purpose.
1.11 Access and Correction
You may have the right to:
- obtain confirmation that we hold personal information about you
- request access to and receive information about the personal information we maintain about you
- receive copies of the personal information we maintain about you
The right to access personal information may be limited in some circumstances by local law requirements.
To exercise these rights, please see details below of requirements:
1.11.1 Update and correct inaccuracies in your personal information
If you feel that the information we hold about you is incorrect or inaccurate you can contact us outlining the information you feel is incorrect or inaccurate.
If we refuse to correct your personal information, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint. We will provide you with access to information we hold about you
1.11.2 Object to the processing of your personal information
If you would like to object to any processing of your information by us you can contact us outlining what processing of information you would like to object to.
1.11.3 Have the information blocked, anonymised or deleted.
If you would like us to delete, block or anonymise information we hold about you, you can contact us outlining what information you would like deleted, blocked or anonymised.
To update your preferences, ask us to remove your information from our mailing lists or submit a request to access, update, correct or delete your personal information, please contact us as specified in the “How To Contact Us” section below.
1.12 Opting out of processing
You can opt out of collection of personal information by automated means e.g. when visiting our website or visit third-party websites and interacting with our adverts, by using the Cookie Consent tool displayed in the website (the browser you use may provide options on how to opt out of receiving certain types of cookies). However, without cookies you may not be able to use all of the website features and/or online services.
You can at any time tell us not to send you marketing communications by:
- e-mail email@example.com
- unsubscribing via the “unsubscribe link” within the marketing e-mails you receive from us, or
- contacting Goadsby & Harding (Holdings) Limited as indicated below.
1.13 Withdrawal of consent
If we obtain your information by consent you have the right to withdraw any consent you previously provided to us.
If we process your information under legitimate interest you can object at any time on legitimate grounds, to the processing of your personal information.
Goadsby & Harding (Holdings) Ltd will apply your preferences going forward. Doing so will mean that you cannot take advantage of certain Goadsby & Harding (Holdings) Ltd and affiliate products, services and promotions.
The right to consent removal may be limited in some circumstances by local law requirements and you will be informed appropriately.
1.14 How to Contact Us / Complaints and Feedback
1.14.1 Complaints to the Data Controllers
- believe we fall short of your expectations in processing your personal information
- wish to make a complaint about a breach of your personal information, applicable privacy laws / principles or have a concern about our privacy practices
- would like access and/or update information or preferences you provided to us,
Please e-mail us at: firstname.lastname@example.org *
Or write to us at:
The Company Secretary
Goadsby & Harding (Holdings) Limited *
99 Holdenhurst Road
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.
If we cannot for lawful reasons complete your request we will explain this to you to the extent that we lawfully can.
1.14.2 Complaints to the Information Commissioners Office
If you are not happy with the way in which we have dealt with your complaint, you also have the right to complain to the UK supervisory authority for data protection - The Information Commissioners Office. See www.ico.gov.uk.
1.15 How We Protect Personal Information
The security of your personal information is very important and we are committed to protecting the information we collect. We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.
We use SSL encryption on our website from which we transfer certain personal information.
We store 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.
Cookies are small amounts of data stored on your PC’s hard drive which makes it easier to identify you personally. Some personal information is gathered by these cookies.
Our web site may store cookies on your web browser in order to improve service for you on your subsequent visits to this web site.
By using cookies, web sites can track information about visitors' use of the site and provide customised content. Most web browsers can be configured to notify the user when a cookie is received, allowing you to either accept or reject it. You may also inspect the cookies stored by your web browser and remove any that you do not want.
1.17 Review and Updates
This privacy notice may be updated from time to time. Any changes made will be posted on our website in this Privacy Notice and you should review it on a regular basis. This policy will come into effect on 25th May 2018.
1.18 Applicable Laws
This policy is governed by English Law and takes account of the following legislation;
1. The General Data Processing Regulation 2016; and
2. The Data Protection Bill/Act 2018.