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Data Privacy, Cookie & Retention Policy

 

Definitions and Interpretation

Professional Sourcing Compliance Ltd (trading as Get Property Compliant) (referred to as “PSC”, “We”, “Us”, “Our” from here forward) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits Our website(s): www.yourpsc.co.uk or www. getpropertycompliant.co.uk (“Our Site(s)”) and will only collect and use personal data in ways that are described here and in a way that is consistent with Our obligations and your rights under the regulation, the Data Protection Act 2018.

By providing your Personal Data, you are affirming that you are over 18 years of age.

For the purpose of the Data Protection Act 2018, PSC are the data controller and are registered with the Information Commissioner’s Office as such with Registration Number: ZA787506 - Please see: PSC - ICO - Registration Page for further details.

Roles and Responsibilities

PSC’s Data Protection Officer is:
Tina Walsh (Director)
Email: [email protected]
Office Tel No: 01254 721 976
In Writing: c/o Mayes Accountants, 22-24 Willow Street, Accrington, Lancashire, BB5 1LP.

Please read this Privacy Policy carefully and ensure that you understand it.

Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our Site and you will be required to read and accept the Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

If you are not happy with any aspect of how We obtain, hold or use your personal data then you have a right to make a complaint to the Information Commissioners Office (ICO) – www.ico.org.uk - We would however prefer that you contact Us first and be given an opportunity to resolve any issue that you might have.

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

The Regulation defines “personal data” as 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, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

This Policy sets out the procedures that are to be followed when dealing with personal data. The procedures and principles set out herein must be followed at all times by PSC, its employees, agents, contractors, or other parties working on behalf of PSC.

PSC is committed not only to the letter of the law but also to the spirit of the law and places a high premium on the correct, lawful and fair handling of all personal data, respecting the legal rights, privacy and trust of all individuals with whom it deals.

Summary

PSC will at all times:
a) Be transparent about what information:

1.

  1. i)  We collect

  2. ii)  Why We collect it

  3. iii)  How We store it

  4. iv)  Where We store it

  5. v)  What We do with it

  6. vi)  When We dispose it

  7. vii)  How We dispose it

b) Have measures in place to protect your personal data and keep secure;

c) Respect your rights under the Data Protection Act 2018 and aim to give you control over your own personal data;

d) Cease communication with you if requested to do so.

The Data Protection Principles

This Policy aims to ensure compliance with the Regulation. The Regulation sets out the following principles with which any party handling personal data must comply. All personal data must be:

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

2.

a) Processed lawfully, fairly and in a transparent manner in relation to the data subject.

b) Collected for specified, explicit and legitimate purpose and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.

c) Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

d) Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, is erased or rectified without delay.

e) Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the Regulation in order to safeguard the rights and freedoms of the data subject.

f) Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

Lawful, Fair, and Transparent Data Processing

The Regulation seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The Regulation states that processing of personal data shall be lawful if at least one of the following applies:

  1. a)  The data subject has given consent to the processing of his or her personal data for one or more specific purposes.

  2. b)  Processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.

  3. c)  Processing is necessary for compliance with a legal obligation to which the controller is subject.

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

d) Processing is necessary to protect the vital interests of the data subject or of another natural person.

e) Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

f) Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

3. Processed for Specified, Explicit and Legitimate Purposes

3.1 PSC collects and processes the personal data set out in Part 20 of this Policy.
This may include personal data received directly from data subjects (for example, contact details used when a data subject communicates with Us)

3.2 PSC only processes personal data for the specific purposes set out in Part 20 of this Policy (or for other purposes expressly permitted by the Regulation). The purposes for which We process personal data will be provided to data subjects via a link to Our company Data Privacy, Cookie & Retention Policy at the time that their personal data is collected included when they join our VIP Membership programme (must tick to indicate they have read) or as soon as possible (not more than one calendar month) after collection where it is obtained from a third party.

A link to a copy of our Data Privacy, Cookie & Retention Policy is available to at any time, at the bottom of each page of our website: www.getpropertycompliant.co.uk.

4. Adequate, Relevant and Limited Data Processing

PSC will only collect and process personal data for and to the extent necessary for the specific purpose(s) informed to data subjects as under Part 3, above.

5. Accuracy of Data and Keeping Data Up To Date

PSC shall ensure that all personal data collected and processed is kept accurate and up-to-date. The accuracy of data shall be checked when it is collected and at 12-monthly intervals thereafter. Where any inaccurate or out-of-date data is found, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

6. Data Retention

PSC shall not keep personal data for any longer than is necessary in light of the purposes for which that data was originally collected and processed. When the data is no longer required, all reasonable steps will be taken to erase it without delay.

For full details of the Companies approach to data retention, including retention periods for specific personal data types held by PSC, please refer to the Data Retention Policy section later in this document.

7. Secure Processing

PSC shall ensure that all personal data collected and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage. Further details of the data protection and organisational measures, which shall be taken, are provided in Parts 22 to 28 of this Policy.

8. Accountability

8.1

8.2 8.3

PSC’s Data Protection Officer is Tina Walsh (Director) Email: [email protected]

The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy and with the Data Protection Act 2018 and other applicable data protection legislation.

PSC shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:

  1. a)  The name and details of PSC, its Data Protection Officer, and any applicable third party data processors.

  2. b)  The purposes for which PSC processes personal data.

  3. c)  Details of the categories of personal data collected, held, and processed by PSC; and the categories of data subject to which that personal data relates.

  4. d)  Details (and categories) of any third parties that will receive personal data from PSC.

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

  1. e)  Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards.

  2. f)  Details of how long personal data will be retained by PSC; and

  3. g)  Detailed descriptions of all technical and organisational measures taken by PSC to ensure the security of personal data.

9. Data Protection Impact Assessments

PSC shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data, which involve the use of new technologies and the processing involved is likely to result in a high risk to the rights and freedoms of data subjects under the Regulations.

Privacy Impact Assessments shall be overseen by PSC’s data protection officer and shall address the following areas of importance:

  1. a)  The types of personal data that will be collected held and processed.

  2. b)  The purpose(s) for which personal data will be used.

  3. c)  The Companies objectives.

  4. d)  How personal data is to be used.

  5. e)  Any parties (internal or external) who may be consulted.

  6. f)  The necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed.

  7. g)  Risks posed to data subjects.

  8. h)  Risks posed both within and to PSC; and

  9. i)  Proposed measures to minimise and handle identified risks.

10. The Rights of Data Subjects

The Data Protection Act 2018 sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details):

a) The right to be informed (Part 11); b) The right of access (Part 12);

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

c) The right to rectification (Part 13);

  1. d)  The right to erasure (also known as the ‘right to be forgotten’) (Part 14);

  2. e)  The right to restrict processing (Part 15);

  3. f)  The right to data portability (Part 16);

  4. g)  The right to object (Part 17);

  5. h)  Rights with respect to automated decision-making and profiling (Parts 18 and 19).

11. Keeping Data Subjects Informed

11.1 PSC shall ensure that the following information is provided to every data subject when personal data is collected:

  1. a)  Details of PSC including, but not limited to, the identity of Tina Walsh (Director), its Data Protection Officer;

  2. b)  The purpose(s) for which the personal data is being collected and will be processed (as detailed in Part 20 of this Policy) and the legal basis justifying that collection and processing;

  3. c)  Where applicable, the legitimate interests upon which PSC is justifying its collection and processing of the personal data;

  4. d)  Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;

  5. e)  Where the personal data is to be transferred to one or more third parties, details of those parties;

  6. f)  Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place (see Part 28 of this Policy for further details concerning such third country data transfers);

  7. g)  Details of the length of time the personal data will be held by PSC (or, where there is no predetermined period, details of how that length of time will be determined);

  8. h)  Details of the data subject’s rights under the Regulation;

  9. i)  Details of the data subject’s right to withdraw their consent to PSC’s processing of their personal data at any time;

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

  1. j)  Details of the data subject’s right to complain to the Information Commissioner’s Office (the ‘supervisory authority’ under the Regulation);

  2. k)  Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it;

  3. l)  Details of any automated decision-making that will take place using the personal data (including but not limited to profiling), including information on how decisions will be made, the significance of those decisions and any consequences.

11.2 The information set out above in Part 10.1 shall be provided to the data subject at the following applicable time:

11.2.1 Where the personal data is obtained from the data subject directly, at the time of collection;

11.2.2 Where the personal data is not obtained from the data subject directly (i.e. from another party):

a) If the personal data is used to communicate with the data subject, at the time of the first communication; or

b) If the personal data is to be disclosed to another party, before the personal data is disclosed; or

c) In any event, not more than one month after the time at which PSC obtains the personal data.

12. Data Subject Access

  1. 12.1  A data subject may make a subject access request (“SARs”) at any time to find
    out more about the personal data which PSC holds about them. PSC is normally required to respond to SARs within one month of receipt (this can be extended by up to two months in the case of complex and/or numerous requests, and in such cases the data subject shall be informed of the need for the extension).

  2. 12.2  All subject access requests received must be forwarded to Tina Walsh (Director) PSC’s Data Protection Officer - Email: [email protected]

  3. 12.3  PSC does not charge a fee for the handling of normal SARs. PSC reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

13. Rectification of Personal Data

  1. 13.1  If a data subject informs PSC that personal data held by PSC is inaccurate or incomplete, requesting that it be rectified, the personal data in question shall be rectified, and the data subject informed of that rectification, within one month of receipt the data subject’s notice (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).

  2. 13.2  In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification of that personal data.

14. Erasure of Personal Data

  1. 14.1  Data subjects may request that PSC erases the personal data it holds about them in the following circumstances:

    1. a)  It is no longer necessary for PSC to hold that personal data with respect to the purpose for which it was originally collected or processed.

    2. b)  The data subject wishes to withdraw their consent to PSC holding and processing their personal data.

    3. c)  The data subject objects to PSC holding and processing their personal data (and there is no overriding legitimate interest to allow PSC to continue doing so) (see Part 17 of this Policy for further details concerning data subjects’ rights to object).

    4. d)  The personal data has been processed unlawfully.

    5. e)  The personal data needs to be erased in order for PSC to comply with a particular legal obligation.

  2. 14.2  Unless PSC has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).

  3. 14.3  In the event that any personal data that is to be erased in response to a data subject request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

15. Restriction of Personal Data Processing

  1. 15.1  Data subjects may request that PSC ceases processing the personal data it holds about them. If a data subject makes such a request, PSC shall retain only the amount of personal data pertaining to that data subject that is necessary to ensure that no further processing of their personal data takes place.

  2. 15.2  In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

16. Data Portability

16.1 PSC processes personal data using automated means:

a) Sendible – Automated Email Response system
b) Calendly – Automated Telephone call booking system

c) Zoom – Telephone Conference facility
d) Kajabi – Website – Contact Us and/or Request further information Forms e) Stripe – Payment syaytem

f) Xero – Send Invoices for payment

g) WeTransfer – File Transfer System

  1. 16.2  Where data subjects have given their consent to PSC to process their personal data in such a manner or the processing is otherwise required for the performance of
    a contract between PSC and the data subject, data subjects have the legal right under the Regulation to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers, e.g. other organisations).

  2. 16.3  To facilitate the right of data portability, PSC shall make available all applicable personal data to data subjects in the following format(s):

    16.3.1 data in csv file format;

  3. 16.4  Where technically feasible, if requested by a data subject, personal data shall be sent directly to another data controller.

  4. 16.5  All requests for copies of personal data shall be complied with within one month of

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

the data subject’s request (this can be extended by up to two months in the case of complex requests in the case of complex or numerous requests, and in such cases the data subject shall be informed of the need for the extension).

17. Objections to Personal Data Processing

  1. 17.1  Data subjects have the right to object to PSC processing their personal data based on legitimate interests (including profiling), direct marketing (including profiling).

  2. 17.2  Where a data subject objects to PSC processing their personal data based on its legitimate interests, PSC shall cease such processing forthwith, unless it can be demonstrated that PSC’s legitimate grounds for such processing override the data subject’s interests, rights and freedoms; or the processing is necessary for the conduct of legal claims.

  3. 17.3  Where a data subject objects to PSC processing their personal data for direct marketing purposes, PSC shall cease such processing forthwith.

18. Automated Decision-Making

  1. 18.1  In the event that PSC uses personal data for the purposes of automated decision and those decisions have a legal (or similarly significant effect) on data subjects,
    data subjects have the right to challenge to such decisions under the Regulation, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from PSC.

  2. 18.2  The right described in Part 18.1 does not apply in the following circumstances:

    1. a)  The decision is necessary for the entry into, or performance of, a contract between PSC and the data subject;

    2. b)  The decision is authorised by law; or

    3. c)  The data subject has given their explicit consent.

19. Profiling

PSC does not use personal data for profiling purposes. If it did the following would apply:

a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

  1. b)  Appropriate mathematical or statistical procedures will be used;

  2. c)  Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and

  3. d)  All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling (see Parts 22 to 28 of this Policy for more details on data security).

20. Personal Data

The following personal data may be collected, held, and processed by PSC:

Contact Type

Data Collected

Purpose of Data

Visitor

a) Technical b) Site Usage

• To improve Our website, product/ services, customer relationships and provide a bespoke site experience

Purchase Goods – On-line Shop

  1. a)  Identity – Name

  2. b)  Address: For delivery of goods purchased

  3. c)  Contact Details – Email &/or Telephone Number

  4. d)  Financial Data

  5. e)  Technical

  6. f)  Site Usage

  • Contact

  • Collect Payment for Goods purchased

  • Marketing & Communication

  • To make suggestions to you about goods or services that may be of interest to you

PSC Trainee

Name, address, email, contact telephone & Financial data

• Provide training, coaching or support service(s)

• Receive payment for services provided

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

Contact Type

Data Collected

Purpose of Data

Professional Associate

Company name, contact name, email, contact telephone number
& details of services provided or required

• Communication
• Provide business service(s)

21. Marketing Communications

You may receive marketing communications from Us if you have:

• Requested information, purchased goods or services from Us. Or

• Completed one of Our ‘Contact Us’ forms and ticked the box requesting information.

• Not opted out of receiving marketing from Us.

You can opt–out at anytime by emailing Us at [email protected] and typing STOP in the subject line.

22. Data Protection Measures

PSC shall ensure that all its employees, agents, contractors, or other parties working on its behalf comply with the following when working with personal data:

  1. a)  No personal data is to be sent via an email(s) system unless expressly requested by the data owner.

  2. b)  All emails containing personal data must be marked “confidential”;

  3. c)  Where any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of.

  4. d)  Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;

  5. e)  Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

  1. f)  Personal data should not be transferred via email, however if this happens, whether sent or received, it should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted using the ‘CleanMyMacX’ (held on Director(s) Laptop);

  2. g)  Where Personal data is to be sent by facsimile transmission it should be marked as “confidential” and the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;

  3. h)  Where Personal data is to be transferred in hardcopy form it should be marked as “confidential” and passed directly to the recipient or sent using Royal Mail (receipt signature required) Postal Service;

  4. i)  No personal data may be shared informally and if an employee, agent, sub- contractor, or other party working on behalf of PSC requires access to any personal data that they do not already have access to, such access should be formally requested from Tina Walsh (Director).

  5. j)  All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in either the locked filing cabinet or locked, fire proof safe.

  6. k)  No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of PSC or not, without the authorisation of Tina Walsh (Director);

  7. l)  Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors or other parties at any time;

  8. m)  If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it.

23. Data Security - Storage

PSC shall ensure that the following measures are taken with respect to the storage of personal data:

a) No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

agents, contractors, or other parties working on behalf of PSC where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Regulation (which may include demonstrating to PSC that all suitable technical and organisational measures have been taken);

  1. b)  All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols.

  2. c)  Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of PSC, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;

  3. d)  Where personal data held by PSC is used for marketing purposes, it shall be the responsibility of Tina Walsh (Director) to ensure that no data subjects have added their details to any marketing preference databases including, but not limited to, the Telephone Preference Service, the Mail Preference Service,

    the Email Preference Service, and the Fax Preference Service. Such details should be checked at least annually.

24. Data Security - Disposal

When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. For further information on the deletion and disposal of personal data, please refer to PSC’s Data Retention Policy below.

25. Data Security - Use of Personal Data

PSC shall ensure that the following measures are taken with respect to the use of personal data:

25.1 No personal data may be shared informally and if an employee, agent, sub- contractor, or other party working on behalf of PSC requires access to any personal data that they do not already have access to, such access should be formally requested from Tina Walsh (Director) – The Data Protection Officer - Email: tina@ getpropertycompliant.co.uk;

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

  1. 25.2  No personal data may be transferred to any employees, agents, contractors,
    or other parties, whether such parties are working on behalf of PSC or not, without the authorisation of Tina Walsh (Director) – The Data Protection Officer – Email:     [email protected];

  2. 25.3  Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any time;

  3. 25.4  If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it; and

  4. 25.5  Where personal data held by PSC is used for marketing purposes, it shall be the responsibility of Tina Walsh (Director) – The Data Protection Officer – Email: tina@ getpropertycompliant.co.uk to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service.

26. Data Security - IT Security

PSC shall ensure that the following measures are taken with respect to IT and information security:

  1. 26.1  All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised.
    All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols.

  2. 26.2  Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of PSC, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords.

  3. 26.3  All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. PSC’s Director’s shall be responsible for installing any and all security-related updates as soon as reasonably and practically possible, unless there are valid technical reasons not to do so; and

  4. 26.4  No software may be installed on any Company-owned computer or device without the prior approval of the Tina Walsh (Director) – The Data Protection Officer – Email: [email protected]

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

27. Organisational Measures

PSC shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

  1. a)  All employees, agents, contractors, or other parties working on behalf of PSC shall be made fully aware of both their individual responsibilities and PSC’s responsibilities under the Regulation and under this Policy, and shall be provided with a copy of this Policy;

  2. b)  Only employees, agents, sub-contractors, or other parties working on behalf of PSC that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by PSC;

  3. c)  All employees, agents, contractors, or other parties working on behalf of PSC handling personal data will be appropriately trained to do so;

  4. d)  All employees, agents, contractors, or other parties working on behalf of PSC handling personal data will be appropriately supervised;

  5. e)  Methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed;

  6. f)  The performance of those employees, agents, contractors, or other parties working on behalf of PSC handling personal data shall be regularly evaluated and reviewed;

  7. g)  All employees, agents, contractors, or other parties working on behalf of PSC handling personal data will be bound to do so in accordance with the principles of the Regulation and this Policy by contract;

  8. h)  All agents, contractors, or other parties working on behalf of PSC handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of PSC arising out of this Policy and the Regulation;

  9. i)  Where any agent, contractor or other party working on behalf of PSC handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless PSC against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

28. Transferring Personal Data to a Country Outside the EEA

  1. a)  PSC does not transfer any personal data to any country outside the EEA, unless:

  2. b)  The transfer is made with the informed consent of the relevant data subject(s);

  3. c)  The transfer is necessary for the performance of a contract between the data subject and PSC (or for pre-contractual steps taken at the request of the data subject);

  4. d)  The transfer is necessary for important public interest reasons;

  5. e)  The transfer is necessary for the conduct of legal claims;

  6. f)  The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or;

  7. g)  The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

29. Data Breach Notification

  1. 29.1  All personal data breaches must be reported immediately to PSC’s Data Protection Officer (Tina Walsh).

  2. 29.2  If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the data protection officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.

  3. 29.3  In the event that a personal data breach is likely to result in a high risk to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.

  4. 29.4  Data breach notifications shall include the following information:

    1. a)  The categories and approximate number of data subjects concerned;

    2. b)  The categories and approximate number of personal data records concerned;

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

c) The name and contact details of PSC’s Data Protection Officer (or other contact point where more information can be obtained);

  1. d)  The likely consequences of the breach;

  2. e)  Details of the measures taken, or proposed to be taken, by PSC to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

30. Third Party Links

Our website may include links to ‘third party websites’, applications or plugins. By clicking on any of those links you are enabling those connections and that may allow third party websites to collect data about you.

We do not control those third-party websites and cannot be held responsible for their privacy policies. We advices that if you leave Our website, that you read privacy notices for all other websites that you may visit. For more information please refer to Our Data Retention Policy section later in this document.

31. Cookies

You are able to set your browser to refuse some or all cookies. You can also set to alert you when a website sets or adds cookies. If you disable or refuse cookies, some parts of Our website may become inaccessible or fail to function as meant to. You can gain more information about cookies at: Wikipedia - Guide - HTTP Cookies. For more information please refer to Our Cookie Policy section later in this document.

32. Implementation of Policy

This Policy shall be deemed effective as of 30th January 2019. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

This policy has been approved & authorised by:

Name: Christina Walsh Position: Director
Date: 10th February 2022

Signature: C. C. Walsh

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

 

Cookie Policy Cookies - What Are They?

Our website uses cookies to distinguish you from other users of Our Site. They help Us to provide you with a good experience when you browse Our Site and also allow Us to improve Our Site.

A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. This Policy describes what information We gather, how We use it and why We sometimes need to store the cookies.

Whilst you can prevent these cookies from being stored on your computers, to do so may well reduce or even cause ‘failure’ in certain elements of the websites functionality.

For a more general guide on HTTP cookies see the Wikipedia Guide: Wikipedia - Guide - HTTP Cookies

 

Cookies – How Do We Use Them?

We use cookies in several different ways as detailed below. Sadly, more often than not, there is no option for disabling cookies without completely disabling how the website operates, losing functionality and features that are a part of the Site. It is recommended that you leave all cookies ‘active’ if you are not sure whether you need them or not, just in case they are used by the website to provide an improved level of service to those who use it.

 

Cookies – How To Disable?

To make cookies ‘in-active’ you will need to adjust the settings in your browser of choice. Please note that by disabling cookies it may well affect the quality of experience as well as some if not all functionality of Our website. Therefore We recommend that you do not disable cookies.

 

Cookies – Which Do We Set?

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of Our Site. They include, for example, cookies that enable you to log into secure areas of Our website, use a shopping cart or make use of e-billing services.

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

  • Analytical/performance cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around Our Site when they are using it. This helps Us to improve the way Our Site works, for example, by ensuring that users are finding what they are looking for easily.

  • Functionality cookies. These are used to recognise you when you return to Our Site. This enables Us to personalise Our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

  • Targeting/Analytics cookies. These cookies record your visit to Our Site, the pages you have visited and the links you have followed. We will use this information to make Our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. If you don’t want analytics cookies to be used when visiting Our Site then you can remove them by following these steps: (a) click ‘Tools’ and select ‘Internet Options’; (b) click the ‘Privacy’ tab and select ‘Advanced’; (c) click ‘Override automatic cookie handling’; and (d) specify how you wish to handle cookies from first and third party websites.

  • Session cookies. These cookies store your browsing information and will be active until you leave Our Site and close your browser at which point they are erased.

  • Persistent cookies. These cookies stay in one of a browser’s subfolders until they are deleted manually or your browser deletes them based on the duration period contained within the persistent cookie’s file. You can set your browser to automatically remove these cookies.

  • Social sharing. These cookies enable you to share any of Our content that you may find interesting with friends via email and social media platforms.

    Cookies – Third Party

    We may also use cookies provided by trusted third parties. Here are the third party cookies you might encounter by using Our Site.

  • Google Analytics – Cookies help Us to understand how you use Our Site and ways to improve your experience by analysing how long you spend on the Site and the pages that you visit. Google Analytics Cookie Usage Policy: Google Analytics Cookie Policy

  • Testing New Features - Cookies may be used to ensure consistency on Our Site and ensure that We understand what experience Our users want.

 

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976

• Site Usage Analysis – Cookies may be used to gather statistical information to help Us to track and understand about numbers of visitors to the Site and numbers of those who made purchases.

• Business Partners – Cookies (Affiliate Tracking) allow Us to track customers
who have come to Our Site via a business partners, allowing Us to credit them appropriately. Also allowing those business partners to provide any bonus material as promised for making a purchase from them.

 

If You Need More Information

We hope that this policy document has answered any questions that you may have had. However, if you are still unsure and would like more information please do not hesitate to get in touch:

Tina Walsh (Director) – The Data Protection Officer – Email: tina@getpropertycompliant. co.uk

 

This policy has been approved & authorised by:

Name: Christina Walsh
Position: Director
Date: 10th February 2022 Signature: C. C. Walsh

Professional Sourcing Compliance Ltd

t/a Get Property Compliant

Registered Number: 12828156 Registered address: c/o 22-28 Willow Street, Accrington, Lancashire, BB5 1LP

ICO Registration Number: ZA787506 Email: [email protected] Phone: 01254 721976