Privacy Policy

Privacy Notice

Thank you for visiting our website.

We are committed to protecting and respecting your privacy. This Privacy Notice sets out the basis on which we process any personal information we collect about you or that you provide to us. We may change this Privacy Notice from time to time, so please refer to this frequently when visiting our website.

General Information

This website is operated by Churchill Sales and Lettings. Churchill Sales and Lettings is a trading name of Churchill Retirement Living Limited. Churchill Retirement Living Limited is the controller for the personal information we process, unless otherwise stated.

There are a number of ways that you can contact us;

• Postal Address: Data Protection Office, Churchill Retirement Living Limited, Churchill House, Parkside, Ringwood, Hampshire, BH24 3SG
• By E-mail: gdpr@crl.co.uk

The type of personal information we collect

We currently collect and process the following information:-

• Personal identifiers, contacts and characteristics (for example, title, name, contact details and date of birth);
• ID for Money Laundering Regulation purposes;
• Financial data including bank account details;
• Online identifiers such as IP addresses and cookie identifiers; and
• Employee data.

How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you through our website, by email, in writing or in a call to us, for one of the following reasons:-

• You have made a general enquiry or information request to us;
• You have registered your interest in a property;
• You have requested our estate agency services;
• You have requested our lettings services;
• You wish to attend, or have attended, an appointment or event;
• You have provided your details to act as a contact for one of our Customers;
• You have provided your details as you are a supplier or subcontractor that undertakes works for us;
• You have made a complaint to us;
• You have applied for a job or secondment with us;
• You are a Colleague; and
• You are representing your organisation.

We also receive personal information indirectly, from the following sources in the following scenarios:-

• Lodge Managers whom you have asked to pass on your contact details to us;
• co.uk or Housingcare.org;
• Through the natural course of a sale/purchase or lettings transaction including mandatory money laundering due diligence;
• Customers provide your personal contact details, as you may hold a power of attorney;
• Colleagues of ours give your contact details as an emergency contact or referee;
• You are named in a Whistleblowing report through our Speak Up process; and
• A complainant refers to you in their correspondence.

If it is not disproportionate or prejudical, we’ll contact you to let you know we are processing your personal information.

Why we process personal data

We use the information that you have given us in order to:-

• To respond to enquiries;
• To perform a requested service and or enter into a contract;
• For marketing and events;
• To improve our services;
• To respond to complaints or other allegations; and
• In recruitment and employment matters.

 Legal basis for processing personal data

Under the General Data Protection Regulation (GDPR), the lawful basis we rely on for processing this information is through:-

1. Estate agency or lettings agreement – Performance of a contract with you or because you have asked us to take specific steps before entering into a contract;
2. Registering your interest – we have your consent to hold your data and contact you with properties that you may be interested in;
3. Employment matters – we have your consent or a legal obligation, details of which can be provided in the Colleague Privacy Policy;
4. Supplier or sub-contractor – Performance of a contract with you or because you have asked us to take specific steps before entering into a contract; and
5. Responding to general enquiries, complaints and other allegations – depending on the circumstances this may be through the performance of a contract, legitimate interests and on occasions we may have a legal obligation to do so.

We do not request or hold any special category personal data or criminal offence data.

 Sharing of personal data

We will not share your information with any third parties for the purposes of direct marketing.

We use data processors who are third parties and who provide elements of services for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

In some circumstances we are legally obliged to share information, such as the processing of payroll and taxes.

We will not send personal data outside of the UK. Should we be required to do so in future, additional safeguards would be put in place.

 Automated Decision Making

We use a limited amount of automated decision making in our money laundering checks, which are necessary for legal purposes. We ensure that there is human intervention to refine results, and where necessary, would allow you to challenge the results of the decision.

 How we store your personal information

Our retention schedule details the types of data we store, how it is stored, how long we keep it and how we dispose of it.

Security of your data

We are committed to taking appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage.

The information that you provide to us will be held in our systems, which are located on our premises or those of an approved third party. We may also allow access to your information by other third parties who act for us for the purposes described in this Privacy Notice or for other purposes approved by you. We believe that we do not currently conduct any processing outside the European Economic Area (the EEA), should that change we would require that appropriate safeguards be put in place.

Your data protection rights

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we are required to respond to you within one month.

Please write to us at gdpr@crl.co.uk or Data Protection Office, Churchill Retirement Living Limited, Churchill House, Parkside, Ringwood, Hampshire BH24 3SG, if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at gdpr@crl.co.uk

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk