Latimer as part of Clarion Housing Group (Clarion), needs to process personal data in order to deliver our services to you as applicable:
- To provide development and the sales of private properties.
- To deliver on our Group ambition to ‘transform lives and communities’
We are committed to treating your information securely, with respect and in line with data protection legislation.
This privacy notice tells you what to expect when Latimer processes your personal information. It applies to information about any individuals who have dealings with Latimer.
This is the main privacy notice for Latimer. If you go on to receive any other services from the Clarion Housing Group, you will be referred to the relevant Clarion Housing Group Privacy Notices which can be found on the Clarion Housing Group website.
It is important for you to read this Notice in full to understand what information we hold about you, how we may use it and your rights in relation to your data. However, we have also produced a summary version explaining why ‘Privacy Matters at Latimer (PDF)’.
Clarion Housing Group includes a number of subsidiary organisations such as Grange, Centra and Clarion Futures.
We keep our privacy notice under regular review and we will place any updates on our websites. If you would like to receive a hard copy of our current privacy notice, please let us know.
For further information you can contact the Data Protection Officer as follows:
The Data Protection Officer
Clarion Housing Group Ltd
Level 6, 6 More London Place
London SE1 2DA
For independent advice about data protection, privacy, e-privacy and data sharing issues, you can contact the Information Commissioner. (Lots of useful information is accessible on their website):
Wycliffe House, Water Lane,
Cheshire SK9 5AF
Phone: 0303 123 1113
We will only collect personal information when we need this. The type of information we need from you will vary depending on our relationship with you. When we ask you for information, we will make it clear why we need it. We will also make it clear when you do not have to provide us with information and any consequences of not providing this.
Most information we hold will be collected from you but where necessary we may also obtain this from third parties such as property portals like Zoopla and Rightmove, our appointed sole selling agents, financial advisers, mortgage advisors, solicitors or legal representatives, or Help to Buy agents. In addition, we may also obtain information from publicly accessible sources or engage the service of market research organisations to validate, or where appropriate, enhance the information that we hold.
We collect information from you (as applicable):
- To manage our records of people interested in a development
- We will need details of what locations and type of properties you are interested in and up to date contact details (including telephone numbers, email addresses and details of anyone you may choose to represent you) so we can reach you when we need to discuss details pertaining to your potential purchase. We will also use your contact information to tell you about changes to Latimer and Clarion, for example our organisational structure and governance arrangements, and to resolve or investigate complaints.
This information is voluntary and is being processed with your consent. If you would like us to remove you form our records, please just let us know.
To manage your reservation or sales process:
- We will hold financial records about any deposits taken. Depending on your method of payment, we may hold your bank account details.
- We will need details of your solicitor and other relevant information to proceed with the sales process such as proof of your identity (passport/driving licence). This will be fully explained to you at the time.
- We will hold records of all our contact with you, your contact with us, and any contact from third parties representing you or about you. This may include call recordings.
- We will hold details relating to any works to be carried out to the property during any applicable defects period (although this information will not necessarily constitute your personal data).
Provision of the information is a ‘Contractual Requirement’. Without this information, we may be unable to manage your services. For example, we cannot proceed with a sale if we do not hold your contact. Please speak to us with any concerns.
- To prevent fraud
- we will collect enough information to verify your identity.
Processing for the purpose of fraud prevention is required in order to meet our legal obligations. Therefore if we are unable to verify your identity we may not be able to provide services to you.
- To assist with personal security and prevention and detection of crime
- we may capture your image on our CCTV systems if you visit a sales office or show cabin.
Processing of this information may be required to meet Latimer’s legal obligations and our legitimate business interests around health and safety and crime prevention.
To understand how we’re performing we may use your contact details to:
- carry out market research and customer satisfaction surveys to help us to monitor our performance and to improve our services to our customers.
- to segment customers to help target our resources and prioritise services.
- in managing and analysing complaints.
- for statistical analysis.
It is in our legitimate interests to understand how we are performing so we can meet our mission statement and objectives.
There may also be a legal obligation for us to process the information or to demonstrate to our regulator that we are fulfilling our obligations, for example around anti-discrimination laws.
We also use your personal information in the following ways:
- Keeping in touch with you, understanding your needs, and inviting you to events.
It is in our legitimate interests to communicate with you and keep you up to date with news and events in order to meet our objectives
- Prevention and detection of crime, and quality management.
We do this to meet our legal obligations.
- Meeting our legal obligations including the requirements of our funders or regulators.
This is a legal obligation on Clarion.
Automated Decision Making and Profiling
We do not undertake automated decision making or profiling which has legal or similarly significant effect on you (where a computer system makes a decision about you without human intervention e.g. deciding if you are eligible for a loan). Should this change in the future, we will inform you and explain your rights relating to this, for example that you have the right to challenge the validity of any decisions made in this way or object to automated decision making and ask us not to use this method of processing.
Latimer will not ask you for any sensitive data (also known as special categories of data), however, you may choose to disclose this to us if you feel it is relevant to part of your service. For example, telling us that you require a wheelchair accessible property. We would only process this information under your direct instruction and with your consent.
We will apply additional security and confidentiality measures when processing your sensitive personal information.
Where you provide consent for us to process sensitive personal information, you have the right to withdraw this consent at any time.
We may also process confidential data about you including bank account information.
We will apply appropriate technical and organisational measures to ensure your personal information is secure. For example, we have systems in place to ensure that access to personal information is restricted to authorised individuals on a strictly need-to-know basis.
When we need to share personal data with our contractors and third party suppliers, our relationships are governed by our contracts with them which include strict data sharing and confidentiality protocols.
To help us ensure confidentiality of your personal information we may ask you (and any of your representatives) security questions to confirm your identity when you call us and as may be necessary when we call you. We will not discuss your personal information with anyone other than you, unless you have given us prior written authorisation to do so or where we have received a clear verbal instruction from you (as a one-off circumstance).
Sometimes we need to share personal information we hold about you with other organisations that we work with or who provide services on our behalf. When sharing information we will comply with all aspects of data protection legislation.
Where the information is of a sensitive nature, for example about your health, we will generally obtain consent from you prior to sharing this information, unless we are required or permitted to share this by law.
Where ‘sharing’ is in our ‘legitimate business interests’, we may share your information without seeking your consent first. This may be with:
- Our agents who advertise our developments or properties on our behalf.
- Other organisations in the Clarion Housing Group that provide services. For example, the contractor who manage the defects period.
- Local authority teams such as environmental health
- Utility companies (and their representatives) and Council Tax Departments to ensure billing details are correct.
- Third parties providing services on our behalf. For example a mailing company distributing our newsletter; a research company carrying out a customer satisfaction survey, or a debt collection agency pursuing former tenant arrears.
- Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative. More information can be found on the work undertaken by the Cabinet Office at: https://www.gov.uk/government/collections/national-fraud-initiative
- Police and other relevant authorities (e.g. Department of Work & Pensions, Probation Service, HM Revenue and Customs) in relation to the prevention and detection of crime, the apprehension of offenders or the collection of tax or duty.
- Other statutory organisations e.g. social services and health authorities as necessary for exercising statutory functions.
We may also share information when required by law for example where ordered by the Court or to protect an individual from immediate harm.
We will routinely use your contact details to send you information and communicate with you about developments and areas you have expressed an interest. We will also tell you about events in your area such as development open days. If you have a preferred method of contact, you can make this known to us, but we will use all means of contact available should we need to contact you in the event of an emergency or to enforce the terms of any contract.
We may also keep you updated with information about other products and services (of ours and other reputable companies we work with) which do not form part of our core landlord services but which we think may be of interest to you and where this will assist us in meeting our Clarion Housing Group objectives to transform lives and communities. This could include information such as energy efficiency and digital support. It’s a legitimate business interest for us to send you postal communications (from time to time) which may comprise information about all these areas of our work. You can object to receiving this type of content from us in the post. Before sending electronic communications of this nature, we will follow the law and guidance which requires us to seek your consent. You can change your mind at any time. Please just contact us or follow the ‘unsubscribe’ instructions that will be available on all of our promotional publications.
We will never sell your personal data to 3rd party organisations for marketing purposes.
Latimer only holds records during the period of our relationship and for a set period afterwards to allow us to meet our legal obligations including resolving any follow up issues between us.
Generally we will delete your information at the point the development or scheme you were interested in is fully sold, unless you have asked us to delete your information prior to this date, or you have asked us to keep you on our records for future schemes.
Latimer is committed to upholding your rights in respect of your personal data.
The right to be informed
Through the provision of our suite of privacy notices, we will be open and transparent about how and why we use your personal information.
The right of access
You have a right to ask us what personal information we hold about you and to request a copy of your information. This is known as a ‘subject access request’ (SAR).
SARs need to be made in writing (we have a subject access form you can use for this purpose), and we ask that your written request is accompanied by proof of your address and identify.
If you are seeking to obtain specific information (e.g. about a particular matter or from a particular time period), it helps if you clarify the details of what you would like to receive in your written request.
If someone is requesting information on your behalf they will need written confirmation from you to evidence your consent for us to release this and proof of ID (both yours and theirs).
We have one calendar month within which to provide you with the information you’ve asked for (although we will try to provide this to you as promptly as possible). In response to SARs, we will provide you with a copy of the information we hold that relates to you. This will not generally include information about your property such as repair logs or details of contractor visits as this is unlikely to constitute your ‘personal information’. Please be clear if you are seeking property or repairs related information as a SAR is unlikely to fulfil your information requirements.
The right to rectification
You can ask us to rectify your personal data if it is inaccurate or incomplete. Please help us to keep our records accurate by keeping us informed if your details change.
The right to erasure
The right to erasure is also known as ‘the right to be forgotten’. In some circumstances, you can ask us to delete or remove personal data where there is no compelling reason for its continued processing. This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data. Our response will also be guided by the provisions of our retention schedule.
The right to restrict processing
In some circumstances you can ask us to restrict processing, for example
- if you disagree with the accuracy of personal data
- if we’re processing your data on the grounds of legitimate interests (as detailed earlier), and whilst we consider whether our legitimate grounds override those of yours.
The right to data portability
If the situation arises where it would be helpful for you to move, copy or transfer personal data we hold about you, across different services, you may be able to ask us to do this. Please contact us to discuss.
The right to object
You can tell us if you object to our processing of your personal data:
- based on legitimate interests
- for the purpose of direct marketing (including profiling);
Rights in relation to automated decision making and profiling.
You can ask us to review any decisions that are determined by automated means. You can also object to our use of your personal data for profiling.
As explained earlier, we do not currently undertake this and will advise you if this position changes.
If you’d like to talk to us about your rights, you can contact us at firstname.lastname@example.org. Alternatively, if you want to raise a complaint about our processing of your data or would like to seek an independent view, you can contact the Information Commissioner using the contact details provided at the start of this notice.
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