Propertymark Privacy Policy 2018

Who we are

We are Propertymark Limited (company number 897907). We are the providers of the following websites (subsequently referred to collectively as our “Sites” throughout this document):

When we refer to “Propertymark”, subsequently throughout this document we are also talking about ARLA Propertymark, ARLA Inventories, NAEA Propertymark, NAEA Commercial and NAVA Propertymark.

Any reference to “You” or “Your” subsequently throughout this document, means a user of our Sites or any of our services.

Introduction

We believe it is very important to respect the privacy of individuals and to be transparent around the data we collect and why. This privacy policy (subsequently referred to as the “Policy” throughout this document) explains Propertymark’s approach in relation to how we collect, process and protect Your personal data when You visit our Sites.

This Policy covers:

  • What personal information do we collect and how do we use it?
  • Who will have access to Your personal information?
  • How long do we keep Your personal information for?
  • Cookies and tracking
  • International transfers
  • Security of Your personal information
  • Other websites
  • Your rights
  • How to contact us
  • Changes to this Policy

Propertymark is the ‘Controller’ of any personal information You provide when visiting our Sites. We will process Your personal information in accordance with all applicable laws, including the General Data Protection Regulation (GDPR) (EU) 2016/679.

WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?

We will only use the information You give us or that we collect for the original purpose for which we collected it, as specified in this Policy, subject to certain legal exemptions. This section outlines what types of information we collect, and how we process and use it.

Website visitors

When You visit our Sites we use a third party service, Google Analytics, to collect information from You. The type of information collected may include technical information with the potential to identify You, such as the Internet Protocol (IP) address Your computer uses to connect to the internet, Your browser type, time zone, browser plug-in types, operating system and platform. We may also collect information about Your visit, including which websites You click through to our Sites from, which websites You leave our site to go directly to, which pages You visit within our Sites, page response times, download errors, visit duration, pages You interact with (such as clicks or watching videos), and methods used to browse away from the page. We use this information to review and optimise how our Sites work, to ensure content is displaying to You correctly, to help to keep the Sites safe and secure, to check the Sites are free from errors, and to customise and enhance Your experience of our Sites.

Propertymark membership applicants

When applying to become a Propertymark member, we ask that You complete an online Membership Application Form and provide us with Your personal information, including Your name, address, personal email address, date of birth, home phone number, mobile number, employment details, any legal status as a company director, and qualifications. We also ask You to make various declarations to confirm Your suitability for membership. We use this information to initially assess Your application. (A paper-based form is available on request, the data from which will be processed by Propertymark into the membership system.)

If Your application is successful, we will continue to process the above information in order to administer Your membership and monitor Your obligations.

Propertymark members

As a Propertymark member, You are required to enter Your membership details and password in order to log into the Members’ Area of our Sites.

As part of Your membership contract, You will receive six copies of Property Professional Magazine each year by post. Your name and address from Your membership profile will be shared with third party publisher Holbrooks Printers Ltd, for them to send the magazine to You.

Periodically, our Membership or Regulation teams may contact You by SMS or email to facilitate membership compliance. Non-compliance may result in membership termination.

As part of Your membership package we will contact You with emails containing guidance, sector information, news and invites to participate in industry surveys. We may email you or use targeted Facebook and LinkedIn advertising, to let you know details of Propertymark events and training courses (which may be free to members or at additional cost), to help You to comply with your CPD requirements which form part of your membership. In addition, as part of Your membership we will email You with information about relevant external events or promotions from our Industry Suppliers, details of which can be found in Your member handbook.

You can unsubscribe from these emails at any time by clicking the unsubscribe link within one of the emails and choosing to opt out of the marketing list. You can opt out of advertising via Facebook and LinkedIn by emailing help@propertymark.co.uk

Occasionally, we will write to You by post for example, with an updated Members Handbook. To do this we work with third party printer Salvo Design and Print Limited. If You wish not to receive such items by post You can opt out by emailing help@propertymark.co.uk

We may also collect information, such as whether You have read an email sent by us, when and how many times. We use this information to tailor and provide You with a bespoke membership service.

Sometimes, we might use the information gained from an email campaign to contact You by phone and ask if You are interested in particular training opportunities. You can opt out of these calls by emailing help@propertymark.co.uk

As a member, You are required to adhere to our Conduct and Membership Rules. If an alleged breach of these rules has occurred, Your information will be processed for the purposes of investigating the allegation and any further action, where necessary. The outcome of a Disciplinary Tribunal Hearing may be published on the Propertymark website. Have a look at our Disciplinary Procedure and our Sanctions Policy for more detail.

As part of Your membership, You have access to an online shop to order leaflets and promotional materials for Your business. When You place an order with the shop, You will be asked to enter Your name, email, gender, date of birth, contact details. billing address and shipping address (for non-digital orders). Your name, address and email will then be passed to our third-party printer Salvo Design and Print Limited, so they can print and send the items directly to You. You can see all the information we hold in 'My Account' along with any orders you have placed.

Non-members booking courses or events

If You are not a member of Propertymark You may still attend Propertymark events and/or courses. To do this, You must register as a user on the appropriate Site, by entering Your name, email address and a password. If You decide to then book onto a course or event, You will be asked to enter Your telephone and address details. If You choose to pay online, You will also be asked to supply Your payment details to Worldpay. Propertymark is legally required to comply with the Payment Card Industry Data Security Standard because we offer credit/debit cards as a payment method for products and services.

Propertymark is rated as Self Assessment Questionnaire Grade A. This means that:

  1. Propertymark is an e-commerce or mail/telephone-order merchant (card-not-present), and does not store, process, or transmit any cardholder data in any format (electronic or otherwise) on their systems or premises;
  2. Propertymark accepts only card-not-present (e-commerce or mail/telephone-order) transactions;
  3. All payment acceptance and processing is entirely outsourced to PCI DSS validated third-party service providers;
  4. Propertymark has no direct control of the manner in which cardholder data is captured, processed, transmitted, or stored;
  5. Propertymark does not electronically store, process, or transmit any cardholder data on our systems or premises, but relies entirely on a third party(s) to handle all these functions;
  6. Propertymark has confirmed that all third party(s) handling acceptance, storage, processing, and/or transmission of cardholder data are PCI DSS compliant; and
  7. Propertymark retains only paper reports or receipts and these documents are not received electronically; and
  8. The entirety of all payment pages delivered to the consumer’s browser originates directly from a third-party PCI DSS validated service provider(s).

Complainants

If You submit a complaint to us about a Propertymark member, we will process the personal information You provide us within the Complaint Form. The personal information requested includes Your name, postal address, email address, phone number, details of complaint and Your preferred resolution. We will use this information to investigate and process Your complaint in accordance with our Conduct and Membership Rules.

If Your complaint results in a Disciplinary Tribunal Hearing the outcome may be published on the Propertymark website.

We may also process information about Your complaint for reporting or statistical purposes but, we will also ensure all personal information is removed and the data is anonymised.

WHO WILL HAVE ACCESS TO YOUR PERSONAL INFORMATION?

Propertymark membership applicants

As an applicant, Your personal information will be processed by Propertymark for the purposes of assessing Your suitability to become a Propertymark member. We may also share it with other bodies and public authorities such as, Trading Standards, Police, HMCTS, HMRC, government authorised redress schemes, government authorised deposit schemes, Experian for credit referencing purposes, Propertymark Qualifications and other Awarding Bodies. Subject to certain legal exemptions, we will not share Your information with any additional third parties, unless You have given Your express consent.

Propertymark members

As stated in the previous section (What personal information do we collect and how do we use it?), we engage third party data processors to print and deliver Property Professional magazine and other printed items such as membership handbooks, and orders from the online shop. These printers are Holbrooks Printers Ltd based at Norway Road, Hilsea, Portsmouth, Hants, PO3 5HX and Salvo Design and Print Limited based at Berrington Road, Sydenham, Leamington Spa, Warwickshire, CV31 1NB.

Subject to certain legal exemptions, we will not share Your information with any additional third parties, unless You have given Your express consent.

We may share Your name, company name and town with sponsors and exhibitors at any conferences and events that You attend. We respect Your privacy and understand if You wish for Your information not to be shared in this way; please contact events@propertymark.co.uk to let us know that You do not want Your information to be shared with sponsors or exhibitors.

To investigate complaints, allegations and to take action against You, we may share Your information with the bodies and public authorities listed under the Propertymark membership applicants section above.

Non-members booking courses or events

If You choose to pay for a course or event online, this will be processed by third party provider World Pay. You will also be asked to supply Your payment details to Worldpay Propertymark and its subsidiary companies are legally required to comply with the PCI DSS because we offer credit/debit cards as a payment method for products and services. Propertymark is rated as Self Assessment Questionnaire Grade A. This means that:

  1. Propertymark is an e-commerce or mail/telephone-order merchant (card-not-present), and does not store, process, or transmit any cardholder data in any format (electronic or otherwise) on their systems or premises;
  2. Propertymark accepts only card-not-present (e-commerce or mail/telephone-order) transactions;
  3. All payment acceptance and processing is entirely outsourced to PCI DSS validated third-party service providers;
  4. Propertymark has no direct control of the manner in which cardholder data is captured, processed, transmitted, or stored;
  5. Propertymark does not electronically store, process, or transmit any cardholder data on our systems or premises, but relies entirely on a third party(s) to handle all these functions;
  6. Propertymark has confirmed that all third party(s) handling acceptance, storage, processing, and/or transmission of cardholder data are PCI DSS compliant; and
  7. Propertymark retains only paper reports or receipts and these documents are not received electronically; and
  8. The entirety of all payment pages delivered to the consumer’s browser originates directly from a third-party PCI DSS validated service provider(s).

We may share Your name, company name and town with sponsors and exhibitors at any conferences and events that You attend. We respect Your privacy and understand if You wish for Your information not to be shared in this way; please contact events@propertymark.co.uk to let us know that You do not want Your information to be shared with sponsors or exhibitors.

Complainants

If You submit a complaint, Your personal information will be processed by Propertymark and will only be accessed by those involved in the complaint process and any subsequent investigation and/or action. We may also share Your information with the bodies and public authorities listed under the Propertymark membership applicants section above.

Subject to certain legal exemptions, we will not share Your information with any additional third parties, unless You have given Your express consent.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

Propertymark membership applicants

If Your application to become a Propertymark member is unsuccessful, we will keep Your Application Form for three months, following which it will be securely destroyed. We retain Your data for this period of time in the event that we need to follow up any aspect of your application.

Propertymark members

If You are a Propertymark member, we will keep Your personal information whilst You are a member and for six years after Your membership ceases. We retain Your data for this period of time in the event that we need to follow up on any complaint received or Client Money Protection claim that relates to Your period of membership.

Non-members booking courses or events

We will keep Your personal information for a maximum of one year beyond the end of Your relationship with us as a customer. We retain Your data to provide You with information about further continuing professional development opportunities that may be of interest.

Complainants

If You make a complaint to us about one of our members, we will keep Your personal information whilst Your complaint is being processed and for six years after Your case is closed. We retain Your data in order that we are able to follow up on any aspect of the complaint that becomes necessary.

COOKIES AND TRACKING

Cookies are small text files stored on Your computer when You visit certain websites. The information we get from cookies helps us enhance Your membership experience on our Sites and to give You best level of service. For example, cookies ensure that You do not need to re-enter Your details every time You order from us or visit our restricted member access site. This also assists us in creating custom made adverts tailored to Your membership.

You can set Your browser not to accept cookies and You can remove cookies from Your browser. However, this might result in some of our Sites functionality not performing at optimal levels. For independent information about cookies You can go to www.allaboutcookies.org.

INTERNATIONAL TRANSFERS

We will not transfer Your personal information outside the EU or European Economic Area (EEA). When the UK is no longer part of the EU, we will continue to ensure that appropriate technical and organisational measures are implemented to safeguard personal information.

SECURITY OF YOUR PERSONAL INFORMATION

In accordance with the requirements of the GDPR and all applicable laws, we take appropriate technical and organisational measures to safeguard Your personal information.

OTHER WEBSITES

This Privacy Policy applies only to Your use of the specified Sites. Our Site may contain links to other websites. Please note that we have no control over how Your data is collected, stored, or used by other websites and we advise You to check the relevant privacy policies of other websites.

YOUR RIGHTS

You have the right to request a copy of any personal information we hold about You. This is known as a Subject Access Request for which there is no charge, providing the requests are not manifestly unfounded or excessive. Your request needs to be made in writing and sent to the Data Protection Officer at the address given below under ‘How to contact us’. We will ask You to provide ID before processing the request. Once in receipt of this, we will process the request without undue delay and within one calendar month. If the matter is complex an extension of up to two months can be given.

You also have rights in relation to rectification, erasure, restriction, data portability, objection and automated decision making. If You would like more information or to exercise rights, within the context of Your relationship with Propertymark, or wish to exercise the above rights, please contact the Data Protection Officer using our contact details below.

If You would like to complain to Propertymark about the way Your personal information is processed, You have the right to do so. Please contact the Data Protection Officer using our contact details below. If You remain dissatisfied after pursuing the above remedy, You may also complain to the Information Commissioner’s Office. They can be contacted at:

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

www.ico.org.uk

How to contact us

If You require further assistance, would like to make a complaint or wish to access Your personal information please contact us;

Data Protection Officer (DPO)
Propertymark Arbon House
6 Tournament Court
Edgehill Drive
Warwick CV34 6LG
Phone 01926 496800

Email: dpo@propertymark.co.uk

Changes to this policy

We adopt a culture of continuous improvement and review our policies regularly. If we make any significant changes in the way we process Your personal information we will make this clear on our Sites or by contacting You directly.