PROTECTING YOUR PRIVACY
Hardies Property & Construction Consultants and J&E Shepherd are committed to protecting the privacy and security of your personal information. This privacy notice aims to give you information on the types of personal data we may collect about you when you interact with us, how we will collect and process your personal data through your use of our website and during and after use of any of the services provided by us. It also explains how we will store and handle and keep that data safe.
This notice applies to anyone who uses our website or services.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting personal data about you so that you are fully aware of how and why we are using your data.
The following sections will answer any questions you have but if not, please do get in touch by contacting us by post, telephone or email. Contact details are shown below.
Hardies Property & Construction Consultants (Company No. SO300703) Registered Office: Swilken House, 35 Largo Road, ST ANDREWS, Fife, KY16 8NJ and J&E Shepherd (Company No. 2837574810) Registered Office: 13 Albert Square, Meadowside, DUNDEE, DD1 1XA (collectively referred to as Firm, we, us, our in this privacy notice) are the controllers and are responsible for your personal data. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
It is likely that we will need to update this Privacy Notice from time to time. You are welcome to come back and check this at any time or contact us by any of the means shown below. The law on data protection sets out a number of different reasons or conditions for which an organisation may collect and process your personal data, including:
In specific situations, eg special categories, we may collect and process your data with your consent. This might include when you complete a form online to receive an email about ways you can receive information about us and our services.
When Hardies Property & Construction Consultants and J&E Shepherd collect your personal data, we will always make clear to you why data is necessary and for what purpose.
We may need your personal data to comply with our contractual obligations when using one of our many services.
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting Hardies Property & Construction Consultants and J&E Shepherd to law enforcement.
In respect of our clients, we require your data to pursue our legitimate interests in a way which might reasonably be expected when we pursue our aims and objectives as an organisation and which does not materially impact your rights, freedom or interests.
For example, we will use personal details to send regular information to our clients about our services.
Special category data
"Special categories" of particularly sensitive personal data require higher levels of protection. We take extra care when collecting, storing and using this type of personal data. We aim to collect and process special category data as little as possible. Generally, we will only collect information on your health to ensure we can make any necessary adjustments. This is to uphold our duty of care, our contractual arrangements and to ensure the safeguarding of staff, those using our services and visitors to our various locations. Other special categories of data may be revealed to us by subjects during the course of delivering our services; we do not strictly process this information but acknowledge it may on occasion be recorded. We will document all incidents of this processing of special category data in our Information Asset Register with reasons, having conducted assessment where required.
The Special Categories of personal data consist of data revealing:
• racial or ethnic origin;
• political opinions;
• religious or philosophical beliefs;
• trade union membership.
They also consist of the processing of:
• genetic data;
• biometric data (e.g. fingerprints) for the purpose of uniquely identifying someone;
• data concerning health;
• data concerning someone's sex life or sexual orientation.
We may process special categories of personal data in the following circumstances:
• With your explicit written consent; or
• Where it is necessary in the substantial public interest, and further conditions are met;
• Where the processing is necessary for further safeguards for your fundamental rights and interests specified in law;
• Where there is a legal obligation.
Further legal controls apply to data relating to criminal convictions and allegations of criminal activity. We may process such data on the same grounds as those identified for “special categories” referred to above.
When we collect your data
When you email us we may collect your name, gender, date of birth, postal address, email and telephone number. For your security, we keep all data secure with appropriate organisational and technical safeguards to keep information safe. When we interact with you we may also collect notes from our conversations with you, details of any complaints or comments you make. We might record your age for identity where the law requires this. We may use technology such as cookies to help us deliver relevant and interesting content in our communications in the future.
We will only ask for and use your personal data collected for the purpose stated at the point at which it is collected. If we believe your data is no longer needed for this purpose we will not process your data further.
Your image may be recorded on CCTV when you visit our premises for safety and crime prevention and detection.
Telephone call may be recorded for security and staff training purposes.
We may collect your social media username, if you interact with us through those channels, to help us respond to your comments, questions and feedback.
The data privacy law allows this as part of our legitimate interest in understanding our clients.
If and when you wish to change how we use your data, you will find details in the ‘What are my rights?’ section below.
An overview of your data protection rights
• Access to the personal information we may hold about you. This is free of charge and will be supplied to you within one month of your request.
• You can withdraw consent, or object to marketing communications we send you if we do not have a legitimate interest to continue, or once the purpose for which we hold the data has ended.
• You can object to our processing of your personal information for direct marketing purposes.
• You have a right to know why we are processing your data and whether we are sharing your information with any third parties.
• You have the right to request a copy of any information about you that we may hold at any time to check whether it is accurate.
• To ask for your information, please contact the Data Protection Officer using the details below.
Whenever you have given us your consent to use your personal data you have the right to change your mind and stop future communications. You may also opt-out, in some cases, of our processing of your data where we have a legitimate interest.
To protect the confidentiality of your information and the interests of the Firm, we will ask you to verify your identity before proceeding with any request for information. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to request such information.
You are free to opt out of hearing from us by any channels at any time unless we have a legal obligation to communicate with you.
We may send you relevant and personalised communications by post. We will do this on the basis of our legitimate interest but only after certain risk assessments.
You are free to opt out of receiving marketing materials from us by post at any time.
Sometimes we are required to inform you about certain changes. For example, updates to this Privacy Notice and where we have a legal obligation. These administrative messages will not include any marketing content and do not require prior consent when sent by email. If we did not use your personal data for these purposes, we would be unable to comply with our legal obligations.
To display the most interesting content to you on our website, we may use data we hold about your previous visits.
We may use your data to send you a survey and feedback requests to help improve the way we communicate. These messages will not include marketing and do not require prior consent when sent by email. We have a legitimate interest to do so as this helps make our services more relevant to you.
Whenever we collect or process your personal data, we will only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely, put beyond use or anonymised.
Sharing your data
Should we need to, we will share your personal data with third parties and suppliers outside the European Economic Area (EEA).
Protecting your data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA such the USA. For example, this might be required when we store data in a Cloud.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA and we will treat the information under the guiding principles of this Privacy Notice.
Stopping us from using your data in the future
You can stop communications from us by contacting us using the information below.
How to complain about our processing of your data
If you feel that your data has been handled incorrectly, or you are unhappy with the way we have dealt with your query regarding the way we use your personal data, you have the right to complain to the Information Commissioner’s Office (ICO) which regulates the use of information in the UK.
You can call them on 0303 123 1113 or go online to www.ico.org.uk/concerns
If you are based outside the UK you have the right to complain to the relevant data protection supervisory authority in your country.
If you would like to discuss any aspect of this policy or the way we handle or process your information please contact our Data Protection Officer using the details below.
Here is how to get in touch:
By Post – By writing to us at: Data Protection Officer, Swilken House, 35 Largo Road, ST ANDREWS, Fife, KY16 8NJ.
By e-mail – You can e-mail us at:
email@example.com or firstname.lastname@example.org
By Telephone – Please call us on 01334 476469
Date 1 March 2019
Review Dated Annually