The Lettings Hub - the home for lettings

Privacy Notice

How we protect your personal information

PLEASE READ THIS CAREFULLY

Privacy Notice

This privacy notice sets out the basis on which we process any personal data that we collect from you or about you that you provide to us or that we receive from other sources. By processing, we mean when we collect, use, store, delete and access personal data.

“We” means The Lettings Hub, The Landlord Hub and LetRisks as trading names of Let Insurance Services Limited and The Lettings Hub Ltd.

We are required to process your personal data in accordance with the law which includes The Data Protection Act 1998 (DPA) and from 25 May 2018, the General Data Protection Regulation 2016 (the “GDPR”).

If we ask you to provide information from which you can be identified, including as a result of using our website, www.lettingshub.co.uk, it will be used in accordance with this privacy notice, as it is varied from time to time.

What information do we collect about you?

The personal information detailed below relating to you or anyone else to be covered by an insurance policy or in connection with our tenant referencing, right to rent checking and utility management services will be collected and processed by us and/or on our behalf by our third party service providers.

We may collect and process the following personal data. This is information we may gather from you that will directly or indirectly identify you as individual. This type of data will be processed strictly in accordance with our Basis at Law stated in the table below. This data will include but may not be limited to:

  • Information you give us. You may give us personal data by filling in paper or online forms or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your name, title, marital status and gender, current and previous postal and risk addresses, e-mail address, phone number, details of earnings, current and or previous occupation, National Insurance number, passport number, driving licence number, personal description and photograph, bank details, credit / debit card details, Next of Kin information, children’s names (optional) and their ages.

  • Information we collect about you. For each of your visits to our website we may automatically collect the technical information, including the Internet protocol (IP) address used to connect your device to the Internet, and your login information.

  • Information we receive from other sources. To help us fulfil our contractual obligations and to verify the information you have given us we may receive personal data from third parties who we work with including insurers, landlords, employers, letting and managing agents, utility brokers and companies. We may also obtain information that is readily available in the public domain through Internet Search engines Social Media, Press etc

  • Credit Reference Agencies. Through these agencies we obtain your credit report. These agencies keep your information and only disclose it to us as permitted by law. By submitting an application you authorise us to request your credit report. This will not affect your credit rating. The Credit Referencing Agency will use and share personal data (also called ‘bureau data’) in accordance with Credit Reference Agency Information Notice (CRAIN). Please click here for more information https://www.equifax.co.uk/crain.html

We do not process special categories of personal data, for example: race, ethnic origin, politics, health. Data for criminal convictions and offences will only be collected as permitted by UK Law.

How we will we use the information about you and for what purposes?

We collect a variety of information to enable us to provide our services and insurance. We collect this through your application form, your communications with us, your transactions, your credit report and use of our service.

Insurance: We obtain, collect and process your personal data (which includes sharing your data with others) to enable us to quote for your insurance needs, place you on cover, make any payment arrangements requested, make any alterations to your policy that you may request during the policy term, and in the unfortunate event that a claim occurs we will need to share your information to help you make your claim. We may also have regulatory and / or legal obligations for sharing data with others, but we will only share it for the purposes stated, or in a way you would reasonably expect us to, unless we inform you otherwise. If you do not provide the data requested it may not be possible to obtain a quote or provide you with a policy or process a claim.

Tenant Referencing: We obtain, collect and process your personal data to enable us to fulfil our contractual obligations to tenants, landlords and/or their agents in connection with the application and granting of and managing a tenancy. We will only share it for the purposes stated below and specifically in our Terms and Conditions which you agree to when you first submit any personal data, or in a way you would reasonably expect us to, unless we inform you otherwise. If you do not provide the data requested we will not be able to process the application.

Utility Management Service: We obtain, collect and process your personal data (which includes sharing your data with others) to enable us to fulfil our contractual and legal obligations on behalf of tenants, landlords and/or their agents to communicate and process “change of occupier” notifications to the statutory authorities, and utility providers.

Our legal basis for processing your data

In order to provide our services and insurance we will be using one or more of the following legal bases:

  • Processing is necessary in order for us to take steps, at your request, to enter into a contract of insurance when you ask us to place cover, and for the performance of that contract when you need to make a claim, or we are required to arrange insurance as part of our contract with your landlord or letting agent or where it is a requirement of a legal tenancy agreement.

  • Processing is necessary for fulfilling a contract with tenants, landlords and/or their agents for provision of references in connection with the application and granting of and managing a tenancy.

  • Processing is necessary for us to comply with any legal or regulatory obligation

  • Where we believe a customer is vulnerable, processing might be necessary to protect the vital interests of that person or other person covered by the policy

  • Processing for changes to any quotation or policy which you may request, or for any other reason necessary to undertake any other requests related to your insurance policy is necessary for the performance of a contract.

Consent: We will ask your consent to use your personal data to provide a quotation for any products or services that are likely to be relevant to your needs. Unless we have your consent we will not share your data for marketing purposes with any third party organisation.

How long do we keep your data?

For legal reasons we hold your data securely for a minimum of 7 years from your last interaction with us, before we delete it unless we are required to retain the data for a longer period due to business, legal or regulatory requirements.

After seven years, this may be destroyed without notice to you. You should therefore retain all documentation issued to you.

Who do we share data with?

In order to process your data we may be sharing your data with one or more other third party organisations (for example, insurance companies who underwrite our insurance policies, credit reference agencies, utility companies, and letting agents and landlords) to fulfil our contractual and legal obligations:

Letting agents, property managers and landlords

To manage and progress tenancy applications including obtaining and verifying references, arranging ancillary insurances and administration associated with any changes in tenancy terms or breaches

Statutory authorities, and utility providers

To manage and progress tenancy applications including administration associated with any changes in tenancy

Insurers

Quotation, cover, to manage and progress claims

Insurance Providers, (Placing Brokers, Delegated Authority Schemes, Wholesalers and the like)

Quotation, cover, to manage and progress claims

Loss Adjusters

To manage and progress claims

Insurance Fraud Bureau

Potential policy fraud

Loss Assessor

To manage and progress claims

Financial Conduct Authority

Regulatory obligations

Financial Services & Compensation Scheme

Compensation in the event of insurer failure, if eligible

Financial Ombudsman Service

Unresolved Complaints, if eligible

National Crime Agency

Suspected criminal / fraudulent activity

HM Treasury Sanctions

Checking clients are not on the banned list

Premium Finance Company

Payment of insurance premiums

Police

Legal obligations

Claims Management Company

To manage and progress insurance claims

Surveyor

Risk survey to analyse, report upon risk.

Also in the event of an insured loss, the opportunity to survey post-loss

Debt Collection Agency

To collect unpaid monies due

IT Providers - Software

Holds all collective management information, system testing when system not responding or errors occur

IT Providers - Hardware, Cloud & Systems Management

To detect issues, secure the system, and test the system. Also backup of data.

Interested Parties (Mortgage Lender)

Proof of cover

Third Party Insurers

To manage and progress claims

Third Party Assessor

To manage and progress claims

Credit Reference Agencies

To obtain credit data, credit scores and ratings, to support applications for tenant references

Claims Exchange Underwriting

Sharing of previous claims information between insurers

Employers Liability Tracing Office

To provide confirmation of cover being in place

Our own Insurers

Where we need to provide information about you

Solicitor

Claims by us or on behalf of our clients, or claims against us

Group Offices

Other offices within the firm may need to use data centrally to deal with clients if another office is busy or not available

Email marketing service companies

To send email marketing and other communications on our behalf, where we have your consent

Google

To provide us with website analytic services

Other Data Controllers not detailed above

To be shared only for the purposes stated, or in a way you would reasonably expect us to, unless we inform you otherwise.

Under some circumstances we may be required to disclose or share your information, for example if we are required to by the police, the courts, or for other legal reasons.

We will never sell your data to another company.

Transfer of your data to countries outside the European Union

The majority of our data is stored within the Republic of Ireland and is not transferred outside the EEA. If it is necessary to transfer the data to a location outside the EEA, we would always ensure that the regulations or certifications covering the proposed location were fully compliant with GDPR, to ensure the lawful transfer of the data. For example, for the management of our email marketing communications to you or your clients, where we have consent, we may use companies which use the "EU-US Privacy Shield Framework" for transfers of personal information outside the EEA. For more information please contact us.

Data security

Data security is of great importance to us. We endeavour to do our best to protect your personal data. However, transmission of information over the internet is not entirely secure and is done at your own risk. To protect your data, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected via our website.

Where password access is required for login access, you are responsible for keeping your password confidential.

Your rights in relation to your personal data

You have several rights in relation to how we use your information. They are:

Right to be informed

The General Data Protection Regulation sets out the information we must provide to you about your Data. All of the information we are required to give you is contained within this Privacy Notice. If you do not understand any part of this, you should contact us immediately and we will be happy to explain it to you.

Right of access

You have the right of access to your personal information. If you wish to receive a copy of the personal information we have about you, you can send us a request for access to this information using the contact details set out at the end of this privacy statement.

After receiving your request and sufficient information to verify your identity we will provide you with a copy of the personal information we have about you which you are entitled to have under applicable law. We will also confirm the purposes for which such personal information is being used, its recipients and the origin of the information.

Right to request that your personal information be rectified

If your personal information is inaccurate or incomplete, you can request that it is corrected.

Right to request erasure

You have the right to request that we erase your Personal Data. For example, you may exercise this right in the following circumstances:

  • your Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed by us;

  • you withdraw consent and no other legal ground permits the processing;

  • you object to the processing and there are no overriding legitimate interests for the processing;

  • your Personal Data was unlawfully processed; or

  • your Personal Data must be erased for compliance with a legal obligation.

We refuse the right to delete your information when it falls within our data retention period stated above, as this data may be required to exercise or defend litigation in the event of a claim whether covered or not by an insurance policy.

Right to restrict processing

You have the right to restrict our processing of your Personal Data where any of the following circumstances apply, although we will still be allowed to store it:

  • where you feel that the Personal Data which we hold about you are not accurate. Processing will be restricted until you verify the accuracy of the information

  • where the processing is unlawful and you do not want your Personal Data be erased and request the restriction of its use instead;

  • where we no longer need to process your Personal Data but the data may be required to establish, exercise or defend a legal claim

  • where you have objected to our processing of your Personal Data pending the verification of whether or not our legitimate business interests override your interests, rights and freedoms.

Where you exercise your right to restrict our processing of your Personal Data, we will only continue to process it in accordance with the requirements of this notice or our legal obligations.

Right to data portability

You have a right to receive and transfer the Personal Data that we hold about you. This only applies to:

  • personal data you have provided to us

  • where the data was processed by you giving us your individual consent or for the performance of a contract

  • and where processing was carried out by automated means.

Where you make such a request, this will be provided in a structured, commonly used, machine readable format such as a CSV file.

Right to object

In certain circumstances, you have a right to object to our processing of your Personal Data.

  • Where we have processed it as a legitimate interest (including profiling)

  • Direct Marketing (including profiling)

  • Processing for scientific / historical research and statistics

We will still be able to process your Personal Data where

  • We can demonstrate compelling legitimate grounds for us to process your Personal Data which override your interests, rights and freedoms

  • The processing is for establishment, exercise and defence of legal claims.

Rights related to automatic decision making including profiling

We may process your data by automated means via a Credit Reference Agency but do not make decisions based on this.

We may process your data by automated means when offering insurance quotations via our online insurance platform. You have a right not to be subjected to decisions being made solely by automated means without any human involvement. We will still be able to carry out this type of decision-making where:-

  • It is necessary to enter into or for the performance of a contract (such as a contract of insurance) which is the main reason we would use this type of decision-making; or

  • You have given your explicit consent for us to do so.

We will only process data in the way you would expect it to be used, and you will be entitled to have a person from our firm to review the decision so that you can query it and set out your point of view and circumstances to us.

Withdrawing consent

Where the legal basis of consent has been used you have the right to withdraw that consent at any time.

How to request access, deletion or correction of your personal data

If you would like to exercise any of your rights detailed above, please contact using the contact details set out at the end of this privacy notice.

If any personal information we have about you is not accessible through our website, you can send us a request for access to this information at no cost.

You may write to us at any time requesting amendments to certain personal information that you consider to be incorrect or irrelevant or to request that we block, erase or otherwise remove your personal information. You may also write to us at any time to object to our use of your personal information, restrict our use of your personal information, or request that we provide your personal information in a usable electronic format and transmit to a third party (right to data portability). We will comply with these requests in relation to your personal information in line with applicable law.

Cookies

Cookies are small text files which are downloaded, with your permission, to the hard drive of your computer or mobile device. This happens when you first visit our website. The cookie helps analyse web traffic and recognise you when you return to our site.

We use them for administration and statistical data purposes, e.g. gathering information about browsing behaviour to measure and improve our website’s performance.

They do not save details such as your name, address or payment details.

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. However, this may prevent you from accessing many of the online services we provide. Unless you adjust your browser to refuse cookies - our system will automatically issue cookies when you log on to our site.

You can disable the cookies using your browser’s options, although if you do this you may not be able to use some of the services on our website.

Changes to this privacy notice

We keep our privacy notice under regular review to keep pace with new developments and stay in line with applicable law.

This privacy notice was last updated on 16th May 2018.

How to make a complaint

You may raise any concerns with us about our processing of your Personal Data, using the contact details below.

If you are not happy with how we have investigated your complaint you can refer your concerns to the Information Commissioner’s Office (or ICO), the body that regulates the handling of personal data in the UK. You can contact them by writing to them at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF or going to their website at www.ico.org.uk

The Lettings Hub and Let Insurance Services are registered with the Information Commissioner’s Office: Z3591737 and Z1178083

How to contact us

If you want to change the way in which we use your data, exercise your rights or if you have a question about how your personal information is used please contact us using the methods below: