04 July 2019
How your personal information is used by Countryside Properties plc
Countryside Properties PLC and the companies that it owns and controls (together ‘Countryside’) collect, in the course of conducting its business, personal data from its customers, employees, contractors and suppliers. The personal data is collected in a number of different ways and for a number of different purposes.
This Information Privacy Notice (‘Notice’) sets out your legal rights with respect to your personal data in accordance with the EU General Data Protection Regulation (‘GDPR’). It also describes what personal data Countryside collects, how it is collected and stored, with whom it may be shared and the purposes for which the personal data may be used. Finally, this Notice sets out who to contact if you have any questions.
Countryside’s Shareholder Privacy Notice sets out what personal data it collects and how it’s processed for individuals that are current or former registered shareholders of Countryside
Countryside’s Data Retention Policy sets out for how long personal data may be stored.
2. Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
3. Legal requirements and how to complain
Countryside processes the personal data that it collects and Countryside Properties plc is the ‘Data Controller’. The person responsible for ensuring that Countryside satisfies its legal requirements for the collection, processing and retention of your personal data is the Countryside Data Protection Officer (DPO).
The Countryside DPO can be contacted by email at [email protected]
If you have provided personal data and you wish to exercise any of your legal rights that are set out in paragraph 2, then please contact the DPO.
If you believe that Countryside is in breach of its legal duties, in the first instance you should contact the DPO.
If you believe that you have received an inadequate response from the DPO, and you wish to complain, then please lodge your complaint with the supervisory authority – the Information Commissioners Office at ico.org.uk.
4. Ways to contact Countryside and provide information
4.1 Visitors to our websites
Countryside collects, uses and processes the following information about you when you visit one of our websites:
- Personal information that you provide by filling in forms on the website. This includes information you provide at the time of registering your interest in our developments on the website and signing up for media alerts and Investor email alerts.
- If you contact us, we may keep a record of that correspondence. We may also ask you for information when you report a problem with the website.
We will do our best to protect your personal information and we will use technology that will help us to do this, however the transmission of your information across the internet is entirely at your own risk.
Once we have received your information, we will use strict organisational procedures, policies and security features to prevent unauthorised access and disclosure. We will keep your personal data on a secure server and use it only for the purposes described in this policy.
We may use the information that we have collected for any of the following purposes:
- To help us improve the design and layout of the website, and to ensure that content is presented in the most effective manner for you and for your computer.
- In aggregate form, for statistical analysis and developing our marketing plans.
- To provide you with information about products, services or offers that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes. If you no longer wish to receive such information, please send an e-mail to [email protected]lc.com.
- To respond to any queries you make.
- To notify you about changes to our products and/or services.
A ‘cookie’ is a small text file stored on your computer to associate a unique ID with your visit in order to make it easier and faster for you to use the website.
To find out more about cookies, including how to manage and delete them, visit www.allaboutcookies.org, or to opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
Countryside will not (and will not allow any third party) to use analytics tools to track or to collect any personally identifiable information from visitors to the website. We will not associate any data gathered from this site with any personally identifying information from any source.
If we do want to collect personally identifiable information through the website, we will be transparent about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
4.2 People who contact us via social media
We use a third party platform, Sprout, to manage our social media interactions.
If you send us a private or direct message via any social media platform, your message will be saved to ensure we have a record of all interaction with you. If you do not want your messages saved, then you should notify us with a direct message via that specific social media site and we will delete it immediately.
4.3 People who contact us via email
Personal data collected via email is stored on our central database system. We will use your information to respond to your request or the subject of your enquiry. Emails are not necessarily secure against interception. Should you request to be registered on our database system, we may use your information to contact you to let you know about our services and products which may be of interest to you. We only require the information needed to provide a service to you, such as name, address, email address and telephone number. Where we request more information to improve our service to you it will be made clear that this is purely voluntary on your behalf and you have to absolute right not to provide us with this information.
4.4 People who contact us by telephone
We may monitor or record your telephone call for training or reporting purposes. We will collect information that we need specifically to assist in providing a level of service to you and with your enquires in relation to our products. We require information such as name, address, telephone, email address. Where we request further information to improve our service, this will be purely voluntary on your behalf and you have the absolute right not to provide us with this information.
4.5 People who use property portals
We collect information when you request details of Countryside properties via property portals such as Rightmove or Zoopla. The personal data is stored on our central database system. We only collect the information required to provide a service to you, such as name, telephone, email, country and postcode. Where we request more information to improve our service to you, it will be made clear that this is purely voluntary on your behalf and you have the absolute right not to provide us with this information.
4.6 People who visit our Developments
If you visit a Countryside development and enquire about a particular property, we will collect information that we need specifically to assist in providing a level of service to you and dealing with your enquires in relation to our products. We require information such as name, address, telephone number, email address. Where we request further information to improve our service, this will be purely voluntary on your behalf and you have the absolute right not to provide us with this information.
5. Enquiring, reserving or buying a Countryside property
5.1 Enquiring about a Countryside property
When enquiring about a Countryside property we will collect the information that we need specifically to assist in providing a level of service to you and with your enquires in relation to our products. We require information such as name, address, telephone number, email address. Where we request further information to improve our service, this will be purely voluntary on your behalf and you have the absolute right not to provide us with this information.
We will ask for your consent to use the personal data you provide for the purposes outlined below at the time you make an enquiry.
We will use the information you provide to contact you about our homes, schemes and events to assist you with your decision making when thinking of buying a new home. We use your information to provide you with the best and most appropriate service. We may also contact you for market research purposes or to help improve customer service.
Ways in which we may contact you:
- Mail outs
If you change your mind, you can request for your personal data to be removed from our records by calling 01277 260000 and asking to speak to one of our Marketing team, or emailing [email protected], or writing to Countryside Properties PLC, The Drive, Brentwood, Essex CM13 3AT. Alternatively you can ask to stop receiving emails by using the unsubscribe links contained within the emails. You can request to stop receiving SMS messages by calling 01277 260000 and asking to speak to a member of our Marketing team. You also have the option to not receive information and updates from Countryside and we will not provide you with details of new developments or services beyond your instruction.
You can request any information we hold about you by emailing [email protected] or writing to Countryside Properties PLC, The Drive, Brentwood, Essex CM13 3AT.
5.2 Reserving a Countryside property
When a customer reserves a Countryside property, a reservation form will be completed in either paper format or on our sales database system called ‘Contact Builder’. The reservation form will contain the details of the reserved property (such as price) and other transaction details, including the identity of the purchasers and other individuals involved in the transaction (for example, relatives who may be providing financial assistance to the purchasers). We require details such as name, address, telephone numbers, email addresses, occupation and date of birth to process any reservation.
We will only use the personal data we collect to process the reservation and maintain contact throughout the buying process.
We will disclose the information only to those third parties directly involved in the reservation process, such as the customer’s financial advisor and/or conveyancer/solicitor.
We will keep the personal data contained in the reservation forms on our ‘Contact Builder’ sales database and ‘Pursuit’ Client Relationship Management system. Any hard copies of the reservation forms will be held and securely retained in line with our Retention Policy and are made available to those only with a genuine need to know.
We will share your information with internal departments who have a ‘need to know’, such as Customer Care and Construction.
5.3 Buying a Countryside property, part-exchanging your own property and ‘chain-breakers’
When buying a Countryside property, part-exchanging your own or in a ‘chain-breaker’ transaction we will require some of your personal data. We can obtain this data from you directly, from our Sales department, solicitors, estate agents, surveyors, public bodies, managing agents and companies, and landlords. The data collected will consist of names, addresses, dates of birth, phone numbers, email addresses, signatures, mortgage and utility account details, service charge and ground rent information.
The data is held by our Legal Department for 12 years from the date of legal completion of the transaction. The data is held in secure filing cabinets, Countryside’s external archive centres, and on our computer servers, databases and systems, which are maintained and protected by our I.T. Department to ensure your personal data is kept safely and securely.
5.4 Land transactions, infrastructure agreements, shared equity and miscellaneous matters
We may also require your personal data for land transactions, infrastructure agreements, shared equity and miscellaneous matters. We can obtain this data from you directly, from our Land and Development Team, solicitors, estate agents, surveyors, public bodies, managing agents and companies, landlords, Help to Buy agencies, joint venture and regeneration partners.
The data is collected for the purpose of negotiating and legally completing agreements, contracts and other documents and will consist of names, addresses, and signatures. The data is held us for up to 12 years from the end of any contractual period, any statutory extensions or upon fulfillment of contractual obligations. These documents may be shared with public bodies such as the Land Registry, Councils, HMRC and the HCA agencies who will keep the agreements permanently. In the case of shared equity, it will also be shared with our appointed administrator who will keep the information for 12 years from the end of the contractual period.
5.5 How we handle and share personal data contained in legal documents
We will only collect personal data necessary for carrying out our obligations arising from any contracts entered into between you and Countryside. The data will not be further processed in any manner incompatible with those purposes. The Legal Department have strict controls over how and why your data can be accessed, and your personal data will only be shared with third parties who are involved in your legal transactions with Countryside, such as solicitors, buyers of part exchange/chain-break properties, management agents and companies, landlords, reversioners, estate agents, surveyors, finance companies, joint venture and regeneration partners.
Some of your personal data, if so required either by law or as a consequence of your obligations under any contract with Countryside, may also be shared with public bodies (such as the Land Registry, HMRC, Homes and Communities Agencies, Credit Control Agencies, Debt Collection Agencies and the Courts) or third party administrators (such as Capita for shared equity).
Your information will also be shared with internal departments who have a ‘need to know’, such as Sales, Land and Development and Accounts.
5.6 Review of our services
We may contact you via email to invite you to review any services and/or products you received from us in order to collect your feedback and improve our services and products (the “Purpose”).
We may also use such reviews in other promotional material and media for our advertising and promotional purposes.
6. Customers using customer service
When an existing customer contacts customer services, either by phone, in writing, or via our website, we complete a customer service/complaint form containing the details of the customer, the details of their property and the details of the matter requiring resolution.
We will only use the personal information we collect to deal with the customer’s particular service requirement or complaint.
Where work is carried out by a third party (such as a contractor engaged to remedy a defect), the necessary personal information will be shared with the third party.
7. Contractors who work on a Countryside site
All contractors and suppliers that engage with or work on Countryside sites are required to provide a level of personal information, to assist Countryside in discharging their duties under the Health & Safety at Work Act 1974.
All personal information collected is stored on the Groups’ secure network, which has limited access internally and no access externally. Information is also stored on external databases which are password protected for security. Any data recorded on paper is placed in secure ‘confidential paper’ bins provided on each site and destroyed.
When providing requested information, suppliers, contractors agree that Countryside, its group companies and affiliates, may collect, use and disclose the personal data, as provided for the following purposes and in accordance with the (EU General Data Protection Regulation and our data protection policy):
(a) The processing of accident / incident information, including sharing with necessary external consultants – i.e. insurance / claims / Enforcing Authorities
(b) Enabling compliance with the Health & Safety at Work Act 1974, Reporting of Injuries Disease and Dangerous Occurrence Regulations, Construction Design and Management Regulations 2015, and other associated regulations
(c) The processing of Training documents including sharing with awarding bodies for certification purposes
(d) The payment of invoices
(e) The calculation and submission of returns requested by any tax authorities, and any other information requests from them
(f) The preparation of financial statements
(g) Providing data to external and internal auditors
In addition to the above we also collect, in some cases sensitive (special) personal data, which is stored solely on a confidential file within the Groups network. Access to this file is restricted on a strictly need to know basis.
We will keep all personal information contained within the above in line with our retention policy. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
8. Job applicants, current and former Countryside employees
8.1 Applying to Countryside
When individuals apply to work at Countryside, we will only use the information they supply to us to process their application and to monitor recruitment statistics. Where we want to disclose information to a third party, for example where we want to take up a reference or obtain a ‘disclosure’ from the Criminal Records Bureau, we will not do so without informing them beforehand unless the disclosure is required by law.
Personal information about unsuccessful candidates will be held for 6 months after the recruitment exercise has been completed, it will then be destroyed or deleted. We retain de-personalised statistical information about applicants to help inform our recruitment activities, but no individuals are identifiable from that data.
Once a person has taken up employment with Countryside, we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once their employment with Countryside has ended, we will retain the file in accordance with the requirements of our retention schedule and then delete it.
8.2 How we collect employees’ Personal Data
We may collect your Personal Data in a number of ways, for example:
- When you contact our HR team either via email or telephone;
- When you apply for a vacancy internally or externally;
- When we collect data through the implementation of any HR Employee Relations Policies e.g. disciplinary;
- In the course of managing your employment with Countryside, for example PDR, Payroll, Company car or car allowance;
- Contact details you place on the company’s internal staff directory;
- When you use any HR services;
- When we receive your Personal Data from third parties, for example security screening and recruitment agencies;
8.3 What type of employees’ Personal Data do we collect?
We may collect the following types of Personal Data:
- You name, address, email address, telephone number and other contact information that allows us to meet our organisational and statutory obligations to you as an Employer;
- Details of family members and Next of Kin details;
- Bank details;
- Right to work documentation and other security screening information;
- Details of car, insurance and driving license.
Some of the information we collect about you may include Sensitive Personal Data as defined in the EU General Data Protection Regulation. We will not utilise this data unless we have your consent.
8.4 Using the employees’ information we collect
We may use your personal data in the following ways:
- To ensure that the information we hold about you is kept up-to-date
- To deal with any employee/employer related disputes that may arise
- For assessment and analysis purposes to help improve the operation of, and manage the performance of our business
- To prevent, detect and prosecute fraud and other crimes
- For any other purpose for which you give us your consent to use Personal Data e.g. to administer employee benefit and pension schemes
- To comply with legal obligations e.g. HRMC, pensions, s29 request
- To process and manage employee share schemes
- To pay qualifying business expenses
- To calculate and submit returns requested by any tax authority
- To prepare financial statements
- To provide data to internal and external auditors
- To provide employment references on request from a third party
In order to manage the business we will use information which personally identifies you; however we may also use consolidated information.
We may share your personal data:
- With our Employees, agents and/or professional advisors;
- With other companies within the current and future Countryside Group;
- With other third party contractors who provide services to us;
- Where we are under and legal obligation to do so, for example where we are required to share information under statute, to prevent fraud and other criminal offences or because of a Court Order for example HMRC, the police.
8.5 Participants in the Countryside Save As You Earn (SAYE) scheme and the Countryside Long Term Incentive Plan (LTIP)
When employees apply to participate in the SAYE Plan, they are authorising Countryside to deduct monthly contributions from their salary and pass this information to Equiniti Limited, who administer Countryside’s SAYE and LTIP.
8.6 Employees’ rights
You can request a copy of the information that we hold about you at any time by emailing us at [email protected] or by writing to:
Countryside Properties plc
All Suppliers and Manufacturers of materials that engage with Countryside, its group companies and affiliates are required to provide a level of personal information to assist Countryside to satisfy the legal requirement imposed on us by the Construction (Design & Management) Regulations 2015 to employ the use of competent and resourced Suppliers.
All personal information collected is stored on Countryside’s secure network, which has limited access internally and no access externally. Information is also stored on external databases which are password protected for security.
We have a separate Shareholders Privacy Notice which applies to individuals that are current or former registered shareholders. A copy of the notice can be accessed through the investor section of our website.
11. Connected persons of a Person Discharging Managerial Responsibility (PDMR)
We required by the Companies Act and international financial reporting standards to report transactions between Countryside and ‘connected persons’ of a PDMR. To fulfil this obligation we will retain information relevant to such transactions (including, but not limited to, the purchase of a property from Countryside, or the supply of goods or services to or from Countryside). Such information may be shared with third parties as necessary to comply with laws and regulations.
The security of your Personal Data is very important to use.
We will ensure that we have in place appropriate technical and organisational measures to prevent unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to Personal Data.
13. Retention, transfer and destruction of personal data
Generally, personal data will be retained by Countryside for no longer than is necessary for the purposes for which the personal data is processed. In some cases, it may be necessary to store the personal data for longer periods solely for the purpose of archiving for legal and regulatory compliance and in accordance with Countryside’s Records Data Retention Policy.
If you wish to have a copy of any of your personal data held by Countryside, please contact the DPO at [email protected].
If you are concerned that your personal data is being held by Countryside for an improper purpose, or for too long, then please contact the DPO.
14. Changes to this information privacy notice