Homewise Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how Homewise Ltd collects and processes your personal data. This includes your use of the website (www.homewise.co.uk) and your contact with us, including any data you may provide through the website, in person, in writing, or over the phone when you make an enquiry or use our service (we record outgoing and incoming calls).
Our service (including our website) is not intended for children and we do not knowingly collect data relating to children.
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 or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Homewise Ltd is made up of the following legal entities:
- Homewise Ltd.
- Homewise Properties Ltd.
- Secure Sale Ltd.; and
- Wakeley Residential Investments
Together these are known as the Homewise Group. This privacy notice is issued on behalf of the Homewise Group so when we mention Homewise, "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the Homewise Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us.
We have appointed a Customer Care & Compliance Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights as set out in clause 8, please contact our Compliance Team using the details set out below.
Our full details are:
- Full name of legal entity: Homewise Ltd
- Email address: email@example.com
- Postal address: Homewise, 1 Liverpool Gardens, Worthing BN11 1TF
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes address, email address and telephone numbers.
- Financial Data includes information that we need to check to see if our service is right for you including any outstanding mortgage, debts and the likely cost of any property that you would like to use our services in relation to.
- Transaction Data includes details in relation to any services that we are providing to you.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the website.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We may collect information about your health (for example any illnesses or conditions and/or disabilities) and incidentally about your sexual orientation (for example who you live with) (Special Categories Data). We need this information to provide our services to you. Information about your health and sexual orientation are Special Categories of Personal Data. We will not collect any other Special Categories Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership). We do not collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Financial Data and Special Categories Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our services;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
We record our outgoing and incoming calls and these call recordings are processed in accordance with this policy.
- Third parties. We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- advertising networks such as Google Adwords and Bing based outside the EU; and
- search information providers such as Google based outside the EU.
- We may receive Contact Data about you from one of our estate agent partners.
We will only use your personal data when the law allows us to.
Most commonly, we will use your personal data (except for your Special Categories Data) in the following circumstances:
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our Compliance Team.
- Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
- Consent means your clear, affirmative and informed consent to process your personal data.
With the exception of (i) Special Categories Data and (ii) the Contact and Identity data that we receive from our partner agents, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending certain direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting our Marketing Team (firstname.lastname@example.org).
We will require your consent to process (i) Special Categories Data and (ii) the Contact and Identity data that we receive from our partner agents:
- Where we approach you for your consent to allow us to process your Special Categories Data we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us, however we may be unable to provide some services without this information. You can withdraw your consent at any time by contacting our Compliance Team.
- Where we use the consent that you have given one of our partner clients to get in contact with you. It is not a condition of your contract with us that you agree to any request for consent from us. If you do not want us to contact you / process your data you can withdraw your consent at any time by contacting our Marketing Team.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact the Compliance Team if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Should you wish to change your preferences at any time, please contact us.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or used our services or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Homewise group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages by speaking with us or contacting us on email@example.com at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Compliance Team.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 3 above.
- Internal Third Parties: other companies in the Homewise Group acting as joint controllers or processors and who are based in the UK.
- External Third Parties:
- Service providers acting as processors based in the UK who provide IT and system administration services and analysis of our database.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
- Our estate agent partners based in the UK whose services may be of interest to you.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5. INTERNATIONAL TRANSFERS
An Investor and/or lender may purchase (or provide finance for) the long-term interest on the property on which you are being granted a Home for Life Plan, i.e. the interest in the property that survives the termination of the Home for Life lease.
If you have been granted a Home for Life lease we will need to give the Investor your personal information. Such disclosures will be subject to a duty of confidentiality, as referred in ‘Data Security’ below. If the Investor is based outside of the EU then we will send your personal information to the country that the Investor is based in. The Investor is required to meet all data protection legislation requirements in order to ensure the security of your data. We can make this transfer because:
- the transfer is necessary for the performance of a contract between you and us (or the implementation of pre-contractual measures taken at your request); or
- the transfer is necessary for the conclusion or performance of a contract concluded in your interest between us and the Investor.
Please contact our Compliance Team if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
6. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have policies in place to deal with any suspected personal data breach and will notify you where appropriate, and any applicable regulator where we are legally required to do so, of any breaches which occur.
7. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting our Compliance Team.
8. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact our Compliance Team.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
APPLICANT PRIVACY NOTICE
Data controller: Homewise Ltd.
1 Liverpool Gardens
As part of any recruitment process, Homewise (we, us, our) collects and processes personal data relating to job applicants. Homewise is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.
What information does Homewise collect?
Homewise collects a range of information about you. This includes:
- The information you have provided to us in your curriculum vitae and covering letter
- The information you have provided on [our application form], including name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications
- Any information you provide to us during an interview
We may also collect, store and use the following types of more sensitive personal information:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions
- Information about your health, including any medical condition, health and sickness records
- Any criminal convictions (this does not include spent convictions under the Rehabilitation of Offenders Act 1974)
How is your personal information collected?
Homewise may collect this information in a variety of ways. For example:
- You, the candidate
- Recruitment agencies, from which we collect the following categories of data: information about you including your name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications
- Credit reference agencies, from which we collect the following categories of data: information about your creditworthiness and financial background
- Your named referees, from whom we collect the following categories of data: the dates of your employment and your job title
Homewise will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.
Why does Homewise process personal data?
Homewise will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the role
- Carry out reference checks, where applicable
- Communicate with you about the recruitment process
- Keep records related to our hiring processes
- Comply with legal or regulatory requirements
It is in our legitimate interests to decide whether to appoint you to role since it would be beneficial to our business to appoint someone to that role.
We also need to process your personal information to decide whether to enter into a contract of employment with you.
Having received your CV and covering letter and/or your application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references before confirming your appointment.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
How Homewise uses particularly sensitive personal information
We will use your particularly sensitive personal information in the following ways:
- We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview
- We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting
Homewise may also need to process particularly sensitive data from job applicants to respond to and defend against legal claims.
Homewise will use your data for the purposes we have explained in this policy; we will not use it in any way that is incompatible with these purposes.
Who has access to data?
Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area for which you may be considered and IT staff if access to the data is necessary for the performance of their roles.
For some technical areas of the business, Homewise may ask its partners, for example its IT supplier, to assist with the recruitment process. This may include conducting a telephone interview, providing additional testing, or providing a presence at a face to face interview for example. In these circumstances Homewise will share your personal information with the relevant partner with whom we share a data sharing agreement.
Homewise will not share your data with any other third parties, unless your application for employment is successful and it makes you an offer of employment. Homewise will then share your data with former employers to obtain references for you.
Homewise will not transfer your data outside the European Economic Area.
How does Homewise protect data?
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our Customer Care & Compliance Manager.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
For how long does Homewise keep data?
If your application for employment is unsuccessful, Homewise will hold your data on file for 12 months after the end of the relevant recruitment process. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds, that we have conducted the recruitment exercise in a fair and transparent way, and in order to allow us to identify that you have applied to work with us previously in the event of any subsequent application. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice which applies to your employment.
As a data subject, you have a number of rights. You can:
- 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
If you would like to exercise any of these rights, please contact our Compliance Team at the above address, or by emailing firstname.lastname@example.org.
Right to withdraw consent
When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact our HR team. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.
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