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privacy-policy

Privacy Notice
Redpath Bruce is committed to ensuring that your privacy is protected and our use of your personal information is governed by this Privacy Notice.
In this Privacy Notice, “Redpath Bruce”, “our” and “we” each mean Redpath Bruce Property Management Ltd registered in Scotland No: SC347692 and having its registered office at Crown House, 152 West Regent St, Glasgow G2 2RQ and Redpath Bruce LLP registered in Scotland no SO301894 and having its registered office at Crown House, 152 West Regent St, Glasgow G2 2RQ.  Any reference to “you” or “your” refers to anyone whose personal information we collect and process.
This document will explain how Redpath Bruce collects and processes personal information to conduct normal business activities.  We will treat your personal information as confidential and in accordance with applicable data protection legislation and your personal information will only be shared with others in accordance with this privacy notice.
Our data protection officer oversees compliance with data protection laws and this privacy notice and provides guidance and advice to Redpath Bruce.  Contact information for our Data Protection Officer is provided below under the heading Contact Details and Complaints.
In this privacy notice we explain:
• What personal information is
• How we collect your personal information
• The types of personal information we collect
• The legal basis for processing your personal information
• How we use your personal information
• How we share your personal information
• How long we keep your personal information
• How we keep your personal information secure
• Your rights in relation to your personal information
• How to make complaints and how to contact us
What is personal information?
Personal information is any information that tells us something about you. This includes information such as name, contact details, date of birth, bank account details or any information about your needs or circumstances which would allow us to identify you. Some personal information is classified as special data under data protection legislation.  This includes information relating to health, racial or ethnic origin, religious beliefs or political opinions and sexual orientation.  This information is more sensitive and we need to have further justification for collecting, storing and using this type of personal information.  There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data.
Any references to personal information in this privacy notice includes personal data, and where relevant, special categories of personal data.
How we collect your information
We collect information from you via a variety of sources, including when you apply for one of our properties or services, complete one of our forms, when you call, write, e-mail or meet with us or respond to a survey.  We may collect information when you use our social media sites, websites or self-service portal ‘My Property’.
Our landline phone calls are not recorded for training and monitoring purposes however our voice mail recordings are usually held for a period of six months.
We operate a CCTV system at our West Regent Street premises for the detection and prevention of crime. It operates continuously, and recordings are held for one month.
From time to time we may request access to your property’s CCTV / sound recording and / or use photography to capture information relating to the management of your property for repairs, alleged anti-social behaviour or crime that results in property damage.
We may also take photographs at our events and at properties to use for general marketing and publicity. However, photographs of individuals will only be used for those purposes with your consent.
We may receive information about you from third parties including:
• Your appointed solicitor or a solicitor acting for a seller client
• Your council or benefits office relating to your tenancy.
• Prior landlords, credit agencies, employers when you apply for a tenancy.
• Police, welfare or support organisations dealing with you.
• Councillors, MPs or other representatives acting on your behalf/instruction.
What personal information do we collect about you?
We will collect your full name and contact details such as phone numbers, email addresses and postal addresses from you whenever you engage with us.
In addition if we are providing a service to you, or on your behalf, where we are required to do so by law, we will collect information relating to your identity, which will be at least one form of photographic identification such as a passport, or driving licence and one form of documentation with proof of your place of residence such as a recent utility bill.
Depending on the service that we provide to you or on your behalf we may also collect additional personal information as detailed below:
Selling, Buying, Letting or Renting a Property
If you are selling or letting a property through us:
• We will collect a contact telephone number to get in touch with you about organising viewings and  updating you on any offers received or rental applications for your property.
• A copy of your Title Deed if you own the property.
• Where you are not the legal owner of the property we will request details from you as to your ability  to sell or let the property such as a Power of Attorney, Guardianship Order or Confirmation or Grant  of Probate.
• We will collect your bank account details to arrange onward payment of rent due to you.
• Tax status information for overseas landlords which will be provided along with your name, address  and the tenanted property address to HMRC
If you wish to rent a property we are listing:
• Photo ID, full name, date of birth, age, postal address, email address and telephone numbers.
• Your next of kin and emergency contact details, and information about your dependants including  personal information relating to any children aged 16 and over who will be living with you at the  property.
• Information about your employment, including length of service, status and salary.
• Your national insurance number.
• Specific access requirements so that we can find a property that is suitable for your needs.
• Bank statements, payslips or income details and tax status when we require this information for  processing a lease agreement.
• Your bank/ building society details to allow us to manage an approved tenancy deposit account for  you, to set up your rental payments and deal with any other tenancy payments.
• Disabilities or vulnerabilities to ensure we tailor our service to meet your circumstances and needs.  We may use this information for safeguarding our staff.
• References and other information included as part of the application process.
• Information about any outstanding debt decrees and county court judgments against you or  bankruptcy, voluntary arrangements and other insolvency proceedings.
We may also collect information about you from other sources.  This may include the following:
• Publicly available information from sources such as Companies House, The Electoral Roll, debt decrees and county court judgements and repossessions.
• Information you have shared publicly on social media.
• Information from third party databases or data suppliers, such as property sites, auction sites and credit reference agencies, including details about your home, belongings and creditworthiness.
If you fail to provide certain information when requested, the landlord may not be able to offer you a tenancy, implement the tenancy agreement, manage the property or comply with legal obligations.
Property Management/ Factoring
If we provide you with a common factoring service:
• We will ask for 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.
• If you pay for your common charges by direct debit we will collect your bank details to allow us to collect your service charge/ common charges.
Investment Consultancy
Where you engage with us as an individual investor we will collect information required to identify you to meet anti-money laundering and counter terrorist financing requirements.  If the investor is an entity such as a company, trust or charity, we may need to collect personal information about the controllers and the beneficiaries of the entity.
Contractors
If you wish to be added to our contractor system or you provide services to us and/ or our clients we will collect and process identification and contact information such as your full name, postal address, email address and telephone numbers, insurance and compliance certificates and evidence of industry and service related qualifications.
General
If you subscribe to receive news or other market updates from us then in addition to the above we may collect details about the sector in which you work and the type of content that you would like to receive but only with your consent.
What is the legal basis of our processing your personal information?
Under data protection legislation we are only permitted to use your personal information if we have a legal basis for doing so.  We rely on the following legal bases to use your information.
For employment related purposes
Where we need information to perform the contract we have entered into with you
Where we need to comply with a legal obligation
Where we have your consent
Where the processing is necessary for us to carry out activities for which it is in our legitimate interests (or those of a third party) to do so and provided that your interest and fundamental rights do not override those interests, including:
• Processing that is necessary for us to promote our business brands and products and measure the reach and effectiveness of our campaigns.  This may include sending you marketing information from time  to time after you have engaged us to provide services or received services from us either which may  be similar and 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.
• Processing that is necessary to improve our knowledge of the property sector – we may conduct  research and statistical analysis to help improve our business processes and the services offered to our  clients, as well as to evaluate our performance against other benchmarks. When possible, statistical  information is anonymised or pseudonymised.
• Processing to improve our service – we conduct surveys regularly and periodically relating to our  services to gauge satisfaction and make improvements based on feedback.
• Processing necessary for us to operate the administrative and technical aspects of our business,  efficiently and effectively – this will include: verifying the accuracy of information that we hold about  you and creating a better understanding of you as a customer.
• Processing for administrative efficiency purposes such as where we outsource certain administrative functions to third parties who are specialists in such services:
• Processing for network and information security purposes, in order for us to take steps to protect your information against loss, damage, theft or unauthorised access or to comply with a request from you  in connection with the exercise of any of your rights outlined below.
In more limited circumstances we may also rely on the following legal bases:
• Where we need to protect your interests (or someone else’s interests); and/ or
• Where it is needed in the public interest or for official purposes we may process special categories of personal information and criminal conviction information with your explicit consent, in which case we will explain the purpose for which the information will be used at the point where we ask for your consent.
How we use your personal information
The information we require from you is used to manage your property, tenancy agreement or other contract between you and us.
The processing activities we conduct can be summarised as:
Selling, Buying, Letting or Renting a Property
• We use your personal information for the purposes of fulfilling our legal obligations to you to let or sell your property or, if you are a buyer or tenant, for the purposes of arranging a contract for sale or a lease for you.
• We may share your information with a language translation service if it is necessary to translate any information into or from a foreign language for you.
• If you are purchasing a property we are acting as agents for the sale of, we will use your personal information to comply with our statutory anti- money-laundering obligations. We share your personal information with our client, the solicitors acting for our client and any other third parties necessary to facilitate the sale and meet our legal obligations in respect of the sale.
• If you are selling a property through us we will share your personal information with any prospective purchasers, your appointed solicitors and the solicitors acting for the other side of the deal, home report surveyors, our suppliers and any other third parties as is necessary to facilitate the sale or purchase.
• If you are applying to rent a property we are acting as letting agents of, or you are an existing tenant we share your personal data with third party referencing agencies for the purposes of the prevention and detection of crime, fraud and/or money laundering and checking your suitability to rent that property, the landlord, suppliers, contractors, our bank, Local Authorities, HMRC, legal agents, an approved deposit scheme and any other third parties necessary for us to process your tenancy application, complete the tenancy agreement, manage the property and fulfil our legal obligations in respect of the let and management.
  Property Management/ Factoring 
Where we are managing property on your behalf we may need to pass your personal information from time to time on to contractors whom we have engaged to carry out maintenance on your properties, legal agents to assist in securing debts, surveyors, insurers and brokers in order to facilitate claims, Local Authorities, government agencies, quasi-governmental bodies, other statutory bodies, in order to facilitate the work we carry out on your behalf and to meet our legal obligations in respect of the work that we carry out on your behalf.
Professional Services
If we are providing you with professional services we will share your personal information with our suppliers, contractors, HMRC and any other third parties necessary to facilitate the work we carry out on your behalf and to meet our legal obligations in respect of the work that we carry out on your behalf.
Investment Consultancy
Where you engage us for portfolio management services we will share your personal information with third party lenders as is necessary to allow us to fulfil our obligations to you, to raise finance for you and to properly manage and advise you on your property investments.
Contractors
If you are on our contractor system or you provide services to us and/ or our clients we will share your personal information with clients, landlords, tenants, other contractors and professionals.
Other uses of your personal information
• 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 will 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 will share personal information with third party services providers who process personal information on our behalf in order to provide services to us. This includes IT systems providers and IT contractors as well as third party referencing or screening agencies for the purposes of the prevention and detection of crime.
• We may share your personal information with any person working within Redpath Bruce on a need to know basis to ensure we are able to perform our obligations to you.
• We will hold your personal information on our client management systems and use this to provide you with marketing information about similar services offered by us to those which you have engaged us to provide which we feel you might find useful from time to time. You have the opportunity to opt out of receiving this information at any time.
What happens if you do not provide information that we request?
We need some of your personal information to perform the services you have requested from us.  For example:
• Where we are selling a property on your behalf we need to know your contact information so that we can update you with information on viewings, offers and progress of the sale.
• Where we are managing a property on your behalf we need to know your contact information so that we can update you on repairs and maintenance required to your property and properly account to you for expenditure incurred.
We also need some information so that we can comply with our legal obligations.  For example, we may need identity documents from you to meet our obligations to prevent fraud and money laundering.
If you do not provide the information required for these purposes, we will not be able to perform our contract with you and may not be able to provide services to you or continue to provide certain services to you.  We will explain when this is the case at the point where we collect personal information from you.
Property information
Much of the data we use relates to your property maintenance and repair. We do not consider property information used in conjunction with the property address to be your personal information. For example, results from an asbestos survey, planning to replace windows or a repair to a tap.
We are usually happy to provide you with answers to questions you may have about the property you are living in and work done to it.
As soon as your name, contact details or other personal information is used in conjunction with property information, such as to complete a property repair visit, then this is treated as personal information.
How long do we keep your personal information?
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.   We have in place a retention policy which sets out the different retention periods for the types of information we hold.
How we keep your information secure
The security of information is very important to us and we have measures in place which are designed to prevent unauthorised access to your personal information, including but not limited to:
Our 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.
Hard copy documentation is stored in locked cabinets.
All data is hosted in datacentres which have systems and protections in place to protect against both unauthorised access, and other external factors that could cause damage to your personal data.  There are strict access requirements in place and access is restricted to those absolutely necessary.
We ensure access to personal information is restricted to Redpath Bruce employees and workers or other persons working within Redpath Bruce on a need to know basis.  Training is provided to any of those Redpath Bruce employees and workers who need access to personal information.
Overseas transfers of your personal information
We ensure that the personal information we hold on your behalf is stored in locations within the UK and the European Economic Area (EEA)
Your rights in relation to your personal information
You have a number of rights in relation to your personal information, these include the right to:
• Be informed about how we use your personal information
• Obtain access to your personal information that we hold
• Request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate
• Request that we erase your personal information in the following circumstances:
  •     If Redpath Bruce is continuing to process personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected
  •     If Redpath Bruce is relying on consent as the legal basis for processing and you withdraw consent
  •     If Redpath Bruce is relying on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us to continue with the processing
  •     If the personal information has been processed unlawfully (i.e. in breach of the requirements of the data  protection legislation)
  •     If it is necessary to delete the personal information to comply with a legal obligation
• Ask us to restrict our data processing activities where you consider that:
  •   Personal information is inaccurate
  •   Our processing of your personal information is unlawful
  •   Where 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
  •   Where 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.
If you would like to exercise any of your rights please contact AMcLaughlin@redpathbruce.co.uk who will respond within one month of receiving your request.
It will always help if you can be as specific about what personal data you want to see, what it relates to and within what timeframe, as that will assist our search.
Contact Details and Complaints
If you are unhappy about the way we use your personal information please contact our data protection officer at AMcLaughlin@redpathbruce.co.uk.  If we cannot resolve any issue or if you think we have breached a legal requirement you also have the right to make an enquiry or to complain to the Information Commissioner’s Office (ICO).  Further details at https://ico.org.uk/
If you have questions, comments or request regarding any aspect of this Privacy Notice please do not hesitate to contact us by sending an email to AMcLaughlin@redpathbruce.co.uk or writing to the Data Protection Officer, Redpath Bruce, Crown House, 152 West Regent St, Glasgow, G2 2RQ.
Changes to our Privacy Notice
Our Privacy Notice is regularly kept up to date and this version was updated on 21st May 2018. The latest full version is always available from our website at www.redpathbruce.co.uk