· It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
· For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), the company responsible for your personal data ("Let Easy London" or "us") can be found on our website.
· Clients - while it speaks for itself, this category covers our customers, clients, and others to whom Let Easy London provides services in the course of its business.
· Delete –while we will endeavor to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or Staff.
. General Data Protection Regulation (GDPR)– a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.
· Other people whom Let Easy London may contact – these may include Let Easy London's Staff emergency contacts and referees. We will only contact them in appropriate circumstances.
· Suppliers – refers to partnerships and companies (including sole traders), and a typical workers such as independent contractors and freelance workers, who provide services to Let Easy London.
. Website Users - any individual who accesses any of the Let Easy London websites.
What kind of personal data do we collect?
· CANDIDATE DATA: In order to provide the best possible letting opportunities that are tailored to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you, such as your name, contact details, references, address history, immigration status, financial information, and social security number (and of course you may choose to share other relevant information with us). Where appropriate and in accordance with local laws and requirements, we may also collect information related to your health, diversity information or details of any criminal convictions.
· We thus may collect the following:
· Contact details (home telephone number, mobile numbers);
· Emails and Email addresses;
· 3 year address history;
· Referee details;
. Immigration status (whether you need a work permit);
· A copy of your driving license and/or passport and/or identity card;
· Information on your places of interests and needs regarding future letting, both collected directly and inferred, for example from Interviews/discussions with you;
· Extra information that you choose to tell us;
· Extra information that your referees chooses to tell us about you;
· Any emails you may have sent us may contain further information in addition to the above.
· Please note that the above list of categories of personal data we may collect is not exhaustive.
· At present we can collect any personal data via our website if you wish to tell us this way.
· CLIENT DATA: If you are a Let Easy London customer, we need to collect and use information about you, or individuals at your organisation, in the course of providing you services such as:(i) finding Candidates who are the right fit for you or your property;
· However, the data we collect about Clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We also hold information relating to your online engagement with Candidate profiles and other material published by Let Easy London, which we use to ensure that our marketing communications to you are relevant and timely. We may also hold extra information that someone in your organisation has chosen to tell us. If we need any additional personal data for any reason, we will let you know.
· SUPPLIER DATA: We need a small amount of information from our Suppliers to ensure that things run smoothly. We need contact details of relevant individuals at your organisation so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide (if this is part of the contractual arrangements between us).
· PEOPLE WHOSE DATA WE RECEIVE FROM STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: In order to provide Candidates with suitable employment opportunities safely and securely and to provide for every eventuality for them and our Staff, we need some basic background information. We only ask for very basic contact details, so that we can get in touch with you. To ask for a reference, we'll obviously need the referee's contact details (such as name, email address and telephone number). We'll also need these details if a member of our Staff has put you down as their emergency contact so that we can contact you in the event of an accident or an emergency.
· WEBSITE USERS: We don’t collect any data from our Website Users unless they send us an email via the website by submitting the form.
How do we collect your personal data?
· CANDIDATE DATA: There are two main ways in which we collect your personal data:1. Directly from you; and2. From third parties.
Personal data you give to us
· Let Easy London needs to know certain information about you in order to provide a tailored service. This will enable us to provide you with the best opportunities, and should save you time.
· There are numerous ways you can share your information with us. It all depends on what suits you. These may include:
. Entering your details into an email having been directed from the Let Easy London website
. Leaving a hard copy form at a Let Easy London or office;. Emailing your completed form to a Let Easy London consultant or being interviewed by them.
Personal data we receive from other sources
· We also receive personal data about Candidate from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:
. Your referees may disclose personal information about you;
. Our Clients may share personal information about you with us; ----------------------
· CLIENT DATA: There are two main ways in which we collect your personal data:
1 Directly from you; and
2 From third parties (e.g. our Candidates) and other limited sources (e.g. online and offline media).
Personal data that we receive directly from you
· We both share the same goal – to make sure that you have the best staff for your organisation. We will receive data directly from you in two ways:- Where you contact us proactively, usually by phone or email; and/or- Where we contact you, either by phone or email, or through our consultants' business development activities more generally.
Personal data we receive from other sources
· Where appropriate and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:
- From third party market research and by analysing online and offline media (which we may do ourselves, or employ other organisations to do for us);
- From delegate lists at relevant events; and
- From other limited sources and third parties (for example from our Candidates to the extent that they provide us with your details to act as a referee for them).
· SUPPLIER DATA: We collect your personal data during the course of our work with you.
· To the extent that you send us an email, we may also collect certain data.
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: We collect your contact details only where a Candidates or a member of our Staff puts you down as their emergency contact or where a Candidate gives them to us in order for you to serve as a referee.
How do we use your personal data?
· CANDIDATE DATA: The main reason for using your personal details is to help you find your place of rent that might be suitable for you. The more information we have about you, the more bespoke we can make our service.
· We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests. If you want to know more about what this means, please go to OUR LEGAL BASIS FOR PROCESSING YOUR DATA later in this notice. If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do by contacting your supervisory authority – see Annex 2.
· Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please see Annex 2
· We may periodically send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with properties. In particular, we may wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive. To enable us to develop and market other products and services;
· We may in the future need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we'll ask for this via an opt-in or soft-opt-in at that time (and which we explain further below). Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please [go to Annex 3].
· Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a form, or instructing us on a search). Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other opportunities to you alongside the specific one we approached you for, significantly increasing the likelihood of us finding you a new position.
· If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time and can find out more about how to do so by contacting us or your supervisory authority. We want to let you know that even if you have opted out from our marketing communications it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn't happen, but if it does, we're sorry. We'd just ask that in those circumstances you opt out again.
To help us to establish, exercise or defend legal claims
· In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
· Although at present all our property letting activities involve human-decision making during the process, we may in the future use fully automated technologies such as expert systems or machine learning to complete a Candidate selection process from end-to-end, where appropriate and in accordance with any local laws and requirements.
· Where appropriate, we will seek your consent to carry out some or all of these activities. If you do not provide consent to profiling, your application will continue to be reviewed manually for opportunities you apply for, but your profile will not be automatically considered for alternative roles. This is likely to decrease the likelihood of us successfully finding you a new home.
· You have the right to withdraw that consent at any time and can find out more about how to do so contact us at email@example.com
· CLIENT DATA: The main reason for using information about Clients is to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly. This may involve:
(i) identifying Candidates who we think will be the right fit for you or your organisation;
(ii) identifying individuals or teams we believe may be of value to your business
(iii) Identifying potential acquisition targets we believe may be of value to your business
The more information we have, the more bespoke we can make our service.
· We use Client information for:-Property Search Activities;- Introducing speculative opportunities; and- To help us to establish, exercise and or defend legal claims.
· SUPPLIER DATA: The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements. However, we realise that you're probably busy, and don't want us to be contacting you about all sorts of things. To find the right balance, we will only use your information:
- To store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements;
- To offer services to you or to obtain support and services from you;
- To perform certain legal obligations;
- In more unusual circumstances, to help us to establish, exercise or defend legal claims.
· We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.
· PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: We use referees’ personal data to help our Candidates to find properties which is suited to them. If we are able to verify their details and references, we can make sure that they are well matched with prospective landlords. We may also use referees' personal data to contact them in relation to recruitment activities that may be of interest to them. We use the personal details of a Staff member's emergency contacts in the case of an accident or emergency affecting that member of Staff. So, for example:
- If our Staff members put you down on our form as an emergency contact, we'll contact you in the case of an accident or emergency affecting them; or
- If you were put down by a prospective member of Staff as a referee, we will contact you in order to take up a reference.
- If you were put down by a prospective member of Staff as a referee, we may sometimes use your details to contact you in relation to recruitment activities that we think may be of interest to you, in which case we will use your data for the same purposes for which we use the data of Clients. We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.
· If you are not happy about this, you have the right to object and can find out more about how to do so by contacting us at firstname.lastname@example.org.
Who do we share your personal data with?
· CANDIDATE DATA: Primarily we will share your information with prospective employers to increase your chances of securing the job you want.
· We may share with the following categories of people:
- Any of our group companies;
- Individuals and organisations who hold information related to your reference or application to work with us.
- Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
- Third party service providers who perform functions on our behalf (including external consultants, business associates and professional tradesman such as builders, engineers, lawyers, and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
- Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
- In the case of Candidates: potential employers
- In the case of Candidates and our Candidates' and prospective members of Staff referees: third parties who we have retained to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws;
- If Let Easy London merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.
· CLIENT DATA: We will only share your data with your express permission:
· SUPPLIER DATA: Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services.
How do we safeguard your personal data?
· We care about protecting your information. That's why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
· If you suspect any misuse or loss of or unauthorised access to your personal information, please let us know immediately at email@example.com.
How long do we keep your personal data for?How can you access, amend or take back the personal data that you have given to us?
· Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
· This right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interest; (ii) to enable us to perform a task in the public interest or exercise official authority;
· The "legitimate interests" category above is the most likely to apply to our Candidates, Clients and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
- we can show that we have compelling legitimate grounds for processing which overrides your interests; or
- we are processing your data for the establishment, exercise or defence of a legal claim.
· If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
· Right to withdraw consent: Where we have obtained your consent to process your personal data, you may withdraw your consent at any time.
· Data Subject Access Requests (DSAR): Just so it's clear, you have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or Delete such information. At this point we may comply with your request or, additionally do one of the following:
- we may ask you to verify your identity, or ask for more information about your request; and
- where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.
· At this time we may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
· Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject access requests and may refuse your request in accordance with such laws. For more information in relation to your jurisdiction, please go to Annex 3.
· Right to erasure: In certain situations, (for example, where we have processed your data unlawfully), you have the right to request us to "erase" your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will Delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
· Your right to request that we erase your personal data in certain circumstances must normally meet one of the following criteria:
- the data are no longer necessary for the purpose for which we originally collected and/or processed them;
- where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
- the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
- it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
- if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
· Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject right to erasure and may refuse your request in accordance with local laws. For more information in relation to your jurisdiction, please got to Annex 3.
· We would only be entitled to refuse to comply with your request for one of the following reasons:
- to exercise the right of freedom of expression and information;
- to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
- for public health reasons in the public interest;
- for archival, research or statistical purposes; or
- to exercise or defend a legal claim.
· When complying with a valid request for the erasure of data we will take all reasonably practicable steps to Delete the relevant data.
· Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this – either by directly transferring your data for you, or by providing you with a copy in a commonly used machine-readable format. In effect, this means that you are able to transfer your Let Easy London account details to another data controller. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we may directly transfer the data for you. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfill a contract.
· Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority, details of which can be found Annex 2.
· Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defense of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
· The circumstances in which you are entitled to request that we restrict the processing of your personal data are: - where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
- where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;- where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
- where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
· If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
· Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision. · It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.
· If your interests or requirements change let us know by emailing us at firstname.lastname@example.org
How do we store and transfer your data internationally?
· Let Easy London is a global organisation
– this is what enables us to offer the level of services that we do. In order for us to continue operating in this way, we may have to transfer or store your data internationally.
- between and within Let Easy London entities;
- to overseas Clients;
- to Clients within your country who may, in turn, transfer your data internationally;
- to a cloud-based storage provider;
· We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
- by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
- by signing up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions; or
- transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country's levels of data protection via its legislation; or- where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a Client of ours); or- where you have consented to the data transfer.
· To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.
Who is responsible for processing your personal data on the Let Easy London website?
· Let Easy London controls the processing of personal data on its website(s) but it does not retain any personal data at this time. If this changes we will update this section of this notice
OUR LEGAL BASIS FOR PROCESSING YOUR DATALEGITIMATE INTERESTS
· Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."
· We don't think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service, so everyone's a winner! However, you do have the right to object to us processing your personal data on this basis.
· Please note that in certain of the jurisdictions in which we operate, a different legal basis for data processing might apply in certain cases. For more information in relation to your jurisdiction, please got to Annex 3
· CANDIDATE DATA:
· We consider it reasonable to expect that if you are interested in a letting a property we have presented to you, you are happy for us to collect and otherwise use your personal data and share that information with prospective Landlords. Your prospective Landlord may also want to double check any information you've given us or to confirm your references, to the extent that this is appropriate and in accordance with local laws.
· SUPPLIER DATA:
· We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our Suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.
· PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS:
· If you have been put down by a Candidate or a prospective member of Staff as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests.
· If a Staff member has given us your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency. This is a vital element of our people-orientated organisation, and necessary for our legitimate interests.
· In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.
· Article 4(11) of the GDPR states that (opt-in) consent is "any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her." In plain language, this means that:
- you have to give us your consent freely, without us putting you under any type of pressure;
- you have to know what you are consenting to – so we'll make sure we give you enough information;- you should have control over which processing activities you consent to and which you don’t.
- you need to take positive and affirmative action in giving us your consent We will keep records of any consents that you have given.
· Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding consenting to receive marketing materials. For more information in relation to your jurisdiction, please go to Annex 3.
ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS
· Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing "is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity".
· This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.
ANNEX 1 – HOW TO CONTACT US
Country in which you use Let Easy London' services or supply Let Easy London with services: UK
The Let Easy London entity responsible for processing the personal data of Candidates, Clients, Suppliers and the emergency contacts and referees of Candidates and Let Easy London' Staff will depend on which of the below companies is the counter party associated with the relevant arrangement:
· Let Easy London How you can get in touch with us:
· You can write to us at the following address: Let Easy London, 4 Norbreck Gardens, London, NW10 7HS
. Alternatively, you can send an email to: email@example.com
ANNEX 2 – HOW TO CONTACT YOUR LOCAL SUPERVISORY AUTHORITY
Country in which you use Let Easy London' services or supply Let Easy London with services: UK
Details of your local supervisory authority: The Information Commissioner's Office. You can contact them in the following ways:
· Post: Information Commissioner's Office Property Redress Scheme
Alternatively, you can send an email to:firstname.lastname@example.org
v.3.0 May 2018 Edited & customised by: Easy Let London Ltd, London