Privacy and Your Personal Information
At LRG, we are passionate about safeguarding the personal data of all stakeholders – our valued customers, dedicated employees, and trusted partners. We believe that data protection is not just a legal requirement, but a moral imperative. That’s why we go above and beyond to implement the most robust and state-of-the-art security measures to protect all personal data entrusted to us. We are committed to compliance with all relevant laws and regulations and will only use personal data for lawful business purposes. We strive to ensure that the data we collect is accurate, complete, and up-to-date, and that it is kept safe from unauthorised access, loss or damage. Data protection is at the core of our values, and we believe everyone has a right to privacy.
Legislation
- General Data Protection Regulations (UK) (GDPR UK)
- Data Protection Act 2018 (DPA)Human Rights Act 1998 (Article 8) (HRA)
- Privacy and Electronic Communications Regulations 2003 & 2011 (PECR)
- Money Laundering Regulations 2017
- Proceeds of Crime Act 2002
- The Data Protection, Privacy and Electronic Communications (Amendments etc.)(EU Exit) Regs 2019
- Telecommunications (Lawful Business Practice)(Interception of Communications) Regulations 2000
- Regulation of Investigatory Powers Act 2000 (RIPA)
1. Who we are
Alexander & Co, Alexander & Co Financial Services, And Co Group, Bode Insurance Solutions, Boyer, Dunlop Heywood, First For Auctions, , GCS Estate Management, Gibbs Gillespie, Glide Property Management, Hose Rhodes Dickson, Island Holiday Homes, Leaders, Moginie James, Mortgage Scout, Peter Ball & Co, Portico, Relocate UK, Romans, Scott Fraser, SOWN, SPL Property Management, Stirling Ackroyd Group, Stirling Ackroyd Surveyors, Three Sixty Inventories, Three Sixty Space and The Acorn Group trading as Acorn Limited and its subsidiaries and associated businesses which includes: Acorn Estate Agents, Acorn Estate Management, Acorn Land & Commercial, Acorn Property Management, John Payne Estate Agents, Langford Russell Estate Agents, MAP Surveyors, Start Financial Services, Start Inventory Services, Start Lease Extensions, Unique.
The Leaders Romans Group Limited is the overall Data Controller and we have a legal duty to protect any information we collect from you. The phrases ‘us’, ‘we’ or ‘our’ will mean those businesses listed above which form the Leaders Romans Group Limited.
Our statutory Data Protection Officer is Zara Harrington. She can be contacted by email at dataprotection@lrg.co.uk or in writing at Crowthorne House, Nine Mile Ride, Wokingham, RG40 3GZ.
2. Information covered by this Privacy Notice
Personal data. This is information, or any combination of separate pieces of information, that could be used to identify you. This includes your name, address, contact details etc.
“Special category” personal data. This sensitive personal information is given more protection in law. For example, details of your health or nationality.
For more details of these definitions see below.
Personal data is any information about an identified or identifiable natural person “a data subject”; an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as their name, alias, address, national insurance number, telephone number, email, address, contact information, financial information, IP address. It can include information in different formats including electronic data, hand-written notes, voice recordings, photographs, CCTV footage.
Special category personal information is personal information which reveals racial or ethnic origin, political opinions, religious/spiritual/philosophical beliefs, trade union membership, genetic or biometric data, physical or mental health data, sex life or sexual orientation data, criminal or alleged criminal offences.
3. Where do we get Personal Information From
The majority of the personal information we collect will have been provided by you during the course of your relationship with us either through face to face contact, by telephone, email or electronic communication such as messaging, on-line forms or emails.
However, we may also obtain your personal data from other sources including:
- information we collect when you visit our websites, please see our Cookies Policy here
- other Leaders Romans Group companies, for example our mortgage brokering service
- companies which support advertising services that promote our services including online property portals (such as Rightmove and Zoopla), social media and networking sites (such as Facebook and Twitter) and online advertising platforms
- information provided to us by other third parties, such as your solicitor
- other publicly available sources such as the Electoral Roll and Land Registry
4. What information do we collect?
Information we may collect directly from you
Why we collect it
If you ask us to provide you with life, critical illness, or landlord insurance and we may need to gather “special category” personal information, we treat this sensitive information in accordance with the additional protection it is given under the Data Protection Act 2018 and GDPR.
Information we collect when you visit our websites
We may collect personal information in connection with your use of our website, such as:
- your name, email address, telephone number and property address when you register to arrange a viewing, register for property alerts, request a valuation, lettings appointment, book a mortgage appointment, book a holiday rental or submit an enquiry
- data sent from your browser may include, the date, time and length of your visit, the site from which you have come (for example Google, Firefox etc.) and your IP address
Information obtained from third party online portals
Information obtained from third parties
Criminal disclosures
CCTV & Telephone Call recording
We may record incoming telephone calls at our call centre, property management centres or branches for training and monitoring purposes only. Acorn Group Companies may also record some outgoing calls. You will hear a notification to advise you the call may be recorded however, not all calls will be recorded. Any recordings made are kept for 1-2 months before being over-written. Acorn Group companies may keep recordings for 6 months before being over-written.
5. How we use your information
To provide estate agency services, including marketing your property, valuing your property, arrange and carry out accompanied viewings, selling your property and helping you search for a new home
To provide a full lettings service for tenants, prospective tenants and landlords
To provide full property management and maintenance services
To provide holiday rental booking services, such as marketing your property, holiday reservations
To advise on financial products, such as mortgages, insurance and protection products To provide property auction services To carry out regulatory checks to prevent fraud, unauthorised transactions, money laundering, tax evasion etc.
To register a tenant’s deposit with a deposit protection scheme
To process payments of rent, and maintenance for you if a property is being let
To arrange an energy performance certificate or home report/survey inspections for you
To offer an inventory and check in/check out service for rented properties
To liaise with utility companies and local authorities regarding property servicesTo carry out tenant referencing and credit reference checks
To monitor and improve our products and services
Customer Surveys
Prize draws and Competitions.
If you are entered into a prize draw or competition, you will be provided with specific terms and conditions that will apply and these will include details about how to opt in or out.
We do not use a third party to administer our prize draws or competitions and all prize draws and competitions will be administered by the Leaders Romans Group. We will let you know if we do decide to use a third party at any time in the future.
Credit scoring & Automated Decisions
6. Lawful basis of processing your personal information
Consent Article 6 (1)(a) GDPR – if we process information under consent we will seek your clear and affirmative consent before processing your data, for example, to receive marketing information of properties for sale or to let.
Performance of a contract Article 6 (1)(b) GDPR – this is where the collection and processing of your data is necessary for the performance of a contract to which you are a party.
Legal obligation Article 6 (1)(c) GDPR- where the collection and processing of your personal data is necessary for compliance with a legal obligation, for example, to comply with the Data Protection Act, verify your identity, for fraud and money laundering prevention.
Processing is necessary for the performance of a task carried out in the public interest Article 6 (1)(e) for example carrying out money laundering checks.
Legitimate interests Article 6 (1)(f) GDPR – some personal information is processed by the Leaders Romans Group as part of its legitimate interests which includes direct marketing, web analytics, sales and lettings.
The lawful basis for processing “special category” personal information
Explicit Consent Article 9 (2)(a) GDPR – is freely given, specific and unambiguous consent before the processing of your data. For example, your health information will be needed to process an application for critical illness insurance.
Data that has been made public Article 9 (2)(e)
Establishing, exercising or defending a legal claim Article 9 (2)(f) GDPR – for advice on underwriting, arranging or administering an insurance contract (Schedule 1 Part 2 of Data Protection Act 2018) or on the suspicion of money laundering in line with the Proceeds of Crime Act 2002 (Section 339ZB)
You may want to inform us of your “special category” data voluntarily to enable us to offer you appropriate products or services. For example, you may have a health condition that means you are unable to climb stairs. We will record your needs/preferences without recording your medical/health conditions in most cases.
Withdrawing Consent
Children’s privacy
7. Who we share your information with
Third Party service providers
Please see below third party organisations we share your information with and why,
Third Party
Why we share your personal information
8. How long we keep your information for
- For lettings we keep your information for 6 years + 1 after you have stopped using our service.
- For property sales we keep your information for 6 years + 1 year after the sale has been completed.
- For property auctions we keep your information for 8 years after the sale has been completed.
- For planning advice and design, we keep your information for 4 years.
- For financial records, we keep your information for 8 years if your application is successful.
- For insurance policies we keep your information for 6 years + 1 year after the policy expiry date.
- For mortgages and records, we keep your information for 30 years.
- For general enquiries and marketing, we will keep your information for 2 years.
- Any copies of ID documents needed to verify your identity will be kept on file for anti-money laundering for 5 years. For tenancy reference checks we will keep your information for 1 year.
9. Our marketing services
We will only send you promotional emails, mail, text messages or contact you by telephone, if you agree to each method of communication. You can stop receiving promotional mail, text messages or telephone calls by contacting your local branch. If you would like to unsubscribe from our email service, please contact unsubscribe@lrg.co.uk We aim to stop emails within 3 working days, but this may be extended to 10 working days over public holidays and to cover staff absence within the Data Protection Team.
Where you contact us via our website, in branch, by phone, or via online portals such Rightmove or Zoopla for help searching for a property to buy or rent, we will use the details you have supplied to us to provide you with property details by email. You can choose to unsubscribe at any time by contacting unsubscribe@lrg.co.uk.
10. Your statutory rights
- ask us for access to a copy of your personal information we hold about you. This is called a data subject access request. We may ask you to provide ID to verify your identity.
- ask us to correct your personal information if it is inaccurate. We may ask you to provide confirmation to ensure the information we hold is accurate.
- ask us to delete your personal information. We are unable to delete your information if the law requires us to keep it for a statutory period or there is a lawful reason we must keep the information. We will always investigate any request and advise you, if we are unable to erase your data.
- withdraw your consent to use your personal information. Where you have provided consent for our processing of your personal data, you may withdraw that consent at any time by simply contacting the branch or team you have been speaking to.
- ask us to restrict the use of your personal data, including direct marketing.
- object to our use of your personal data for our legitimate business interests. You have an absolute right to object to our use of your data for direct marketing.
- object to an automated decision.
Your right to access (known as Subject Access Request)
Further information on the request process and a subject access request form is available from dataprotection@lrg.co.uk
If you have registered on our Sales, Tenancy or Landlord Portals, in some cases it will be quicker to log in to your account to access the information. For example, if you want a copy of your tenancy documents, Landlord Terms of Business Agreement or rent statements.
Exemptions within the legislation could mean that you may not receive all the information we process. If this is applicable an explanation will be provided to you within our response.
Information relating to a service complaint will not be within the scope of a Subject Access Request. We have an internal complaints procedure for general service complaints and tenancy issues. Our Customer Service team can be contacted by emailing Customercare@lrg.co.uk and they will be better placed to help resolve your problem quickly.
If you would like a form to assist you with making your request, please email the data protection team at dataprotection@lrg.co.uk
11. How we protect your information
In accordance with the law we have strict security procedures to ensure that personal information is not damaged, destroyed or misused, and to prevent unauthorised access to your information. We have an internal breach reporting system to record all information security incidents and breaches. Serious data breaches are reported to the ICO within 72 hours, in accordance with the GDPR UK and the Data Protection Act 2018.
12. Data Transfers
Whilst we always strive to keep our data in the UK and limit data transfers, we do use a cloud services provider for our customer data. Data back-ups are held outside the UK in accordance with GDPR for business continuity reasons. As with most global cloud service providers, the use of global back-up systems is common place.
13. Links to Other Websites
14. Who to contact make a complaint
We ask you to state in your complaint, the following information to enable an independent investigation:-
- Your name, contact email address and the address of the property (if regarding a tenancy, a sale, maintenance issue, mortgage or insurance policy)
- The business trading name (see below), branch location and names of any staff members
- A description of the complaint, time period or relevant dates, and
- Please attach details if your issue relates to a letter, property description, copy of email etc.
Information Commissioner’s Office Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Website: https://ico.org.uk/ Email: casework@ico.org.uk Telephone: 0303 123 1113
15. Legal Information about the Leaders Romans Group
- The ICO registration for The Leaders Romans Group Ltd is ZA781332.
- The Leaders Romans Group Limited is a registered company. Our registered office address is Crowthorne House, Nine Mile Ride, Wokingham, Berkshire RG40 3GZ. Our registered number is 09939099.
- Further information regarding the Leaders Romans Group can be found by visiting https://www.lrg.co.uk
- These companies have the following regulatory status:
- Bode Insurance Solutions Limited is authorised and regulated by the Financial Conduct Authority
- The Romans Group (UK) Limited is an introducer appointed representative of Bode Insurance Solutions Limited
- Leaders Limited is an introducer appointed representative of Bode Insurance Solutions Limited
- LRG Financial Services Limited is an appointed representative of Mortgage Advice Bureau Limited and Mortgage Advice Bureau (Derby) Limited
- Mortgage Scout is an appointed representative of Mortgage Advice Bureau Limited and Mortgage Advice Bureau (Derby) Limited
- Start Financial Services is an appointed representative of Mortgage Advice Bureau Limited and Mortgage Advice Bureau (Derby) Limited