Scott Owen Lettings Limited Privacy Notice
This privacy notice advises how we collect, use, secure, transfer and share
your information. We are Scott Owen Lettings Limited. We are registered in
England & Wales under company number 8647715. You can contact us in
writing at 45a High Street, Heathfield, East Sussex TN21 8HU, via email
or telephone us on 01435 868202.
Our Information Commissioner's Office Registration number is ZA020104
Who does this Privacy Notice apply to?
Tenants, Guarantors & Relevant Persons
- new, current or expired
- new, current or expired
Leaseholders, Property Owners or Block Tenants
- new, current or expired
Contractors, Suppliers and Service Providers
- new, current or expired
How we use your information & the lawful bases we use for
We process the minimum personal information required and only use your
information in ways that you would expect based on the services we are
providing to you.
Each processing purpose must be attributed to one of the 6 lawful bases
under GDPR - General Data Protection Regulation. The legal bases we apply
to our processing are:
Article 6 (1) (b) Contract -
The processing is necessary for a contract with the individual such as a
Landlord, a Leaseholder or a Supplier.
Article 6 (1) (c) Legal -
The processing is necessary to comply with the law such as relevant
legislation or compliance with industry standards.
Article 6 (1) (f) Legitimate Interests
- The processing is necessary for our legitimate interests to provide
services or the legitimate interests of a third party such as Tenants or
Why we process and store your information, the lawful basis & our
· Communication by email, contact form, text, phone & post - We
may collect your contact details from your correspondence method under our
legitimate interests to respond to enquiries, messages and keep a record of
· Prospective Tenant general incoming enquiries - Under our legitimate
interests we will record your enquiry and contact details. You will not be
added to any mailing lists or be marketed to for any other reason. If you
ask us to advise you of any appropriate upcoming properties we will contact
you only with that specific information. Our processing of your data will
be lawful, proportionate & will have minimal privacy impact. If you do
not progress to the application stage we will delete your data in line with
the retention policy confirmed in this privacy notice.
· Prospective Landlord incoming enquiries with potential property to
let - Under our legitimate interests we will record your enquiry and
contact details. You will not be added to any mailing lists or be marketed
to for any other reason. We will send you the information you require &
may make follow up contact with you within a reasonable time. Our
processing of your data will be lawful, proportionate & will have
minimal privacy impact. If you do not progress to appointing us we will
delete your data in line with the retention policy confirmed in this
· Collecting proof of Identity from Landlords - our legitimate
interests to ensure we have verified the identity of our Landlords and to
protect the legitimate interests of their prospective Tenants.
· Advertising our Landlord's available property to let on Rightmove
who will collect your contact data before referring leads to us - our
legitimate interests to fulfil our contract to find a Tenant for the
· Taking contact details & arranging viewings for prospective
Tenants on available properties - our legitimate interests and those of the
Tenant(s) to find a suitable property to live in.
· Assessing Tenant applications for property available to let
including obtaining references, from your chosen referees, and making
credit checks - our legitimate interests to secure a property for Tenants
with a view to them meeting the criteria to enter into a contract with a
· Collecting Right to Rent Identification - to comply with the Right
to Rent Immigration Act.
· Arranging a rental contract between Landlords and Tenants which
involves sharing their data with each other - our legitimate interests to
provide the service of setting up a rental contract between Landlords and
· Arranging Deposit Protection and providing Prescribed information
detailing both the Landlord(s), Tenant(s) and Relevant Persons personal
information as required under Tenancy Deposit Protection Law - to meet
· Responding to & arranging property maintenance & repairs
requests for Tenants - our legitimate interests to manage the property,
provide good quality housing & protect the interests of all parties.
· Arranging property maintenance & repairs for Property Owners
& Landlords - to fulfil contracts with Tenants, Contractors, Service
Providers or Suppliers.
· Processing Payments & accounting for Property Owners - to fulfil
contracts with Landlords, Leaseholders, Contractors and Suppliers.
· Processing Payments & accounting for Tenants - our legitimate
interests to record the rental history for Tenants and refund any
overpayments or expenses.
· To comply with all relevant rental property legislation and industry
standards - to meet legal obligations.
· To retain records in compliance with all relevant legislation - to
meet legal obligations
· Disclosure of information for legal reasons - to meet our
obligations to prevent crime, exercise our or our client's legal rights,
defend legal claims, resolve disputes, accounting and VAT investigations or
comply with all other legal obligations.
· When you provide us with goods and services - to fulfil our contract
Types of information we may collect about you:
· Full names, age and date of birth
· Present address, forward address or property to let address
· Telephone numbers & email addresses
· Marital status, Residential status, Employment status
· Guarantor details, Deposit Relevant Person details or Next of kin
· Referees, Previous Landlord details, Previous Renting history
· National Insurance number or other Identifying reference numbers
· Salary & Employers details
· Bank statements & bank details where necessary
· Right to Rent ID, Primary ID, Address ID
· Dependant(s) details with dates of birth and some lifestyle
preferences such as any pets or smokers.
· Rental history record whilst a customer with us
How we collect or obtain information about you:
In the general conduct of business Scott Owen Lettings Limited collects
information relevant to the services we are providing to you. We collect
this information from:
· Yourself, Your Spouse or Partner
· Employers & previous Landlords
· Referees & Reference Agencies
· Banking Records
· Throughout our business relationship with you
We collect this information through our website contact page, via email,
post, application forms, text, over the telephone, face to face or record
keeping. You may also agree to third parties disclosing information about
you to us that those third parties have collected.
Information we share with third parties:
We will only share personal information we collect about you where it is
absolutely necessary and lawfully disclosed. Your data may be shared with,
but not limited to:
· Advertising the property details on Rightmove or any other medium to
display properties to let to fulfil our contract with Landlords.
· Names, addresses & contact details between Landlord(s) and
Tenant(s) to facilitate the rental contract.
· Names, contact and any other details required by the Tenant(s)
chosen referees & our chosen reference agencies to exercise our
legitimate interests to facilitate a Tenant's application and suitability
for a rental property.
· Tenants Right to Rent ID may be passed to Landlords so that they can
demonstrate legal compliance.
· Statutory information shared between Landlords, Tenants and Relevant
Persons such as contact details which is submitted to The DPS (Deposit
Protection Service) and is required to comply with Tenancy Deposit
Protection law under legal obligations.
· Contact details between Landlord(s), Tenant(s), Leaseholders, Block
Management Companies, Tradesmen, Suppliers, Maintenance or Service
Contractors to meet contractual repairs & maintenance.
· Contact details shared with Gas Safe Engineers, Electricians,
Specialist Tradesmen, Inventory Clerks or EPC Assessors to meet good
practice and legal obligations.
· Statutory details required by The PRS (Property Redress Scheme) to
respond to enquiries or complaints under legal obligations.
· Payment details required by our Bank to facilitate payments &
meet contractual obligations.
· Tenancy details required by our Insurance providers, Legal
representatives or Solicitors to defend any legal claims and protect our
· Statutory details required by HMRC (Her Majesty's Revenue and
Customs), Land Registry, The Home Office, Local Authorities or other
relevant regulatory bodies to meet legal requirements.
· Names, contact & tenancy details of previous, current and new
tenants as required by Local Councils and Utility companies to ensure all
contractual liabilities are paid.
· Names, contact & tenancy details required by Solicitors, Law
firms, Courts, Guarantors, Tracing Agents or Debt Collectors under our
legitimate interests to ensure all Tenant contractual liabilities are met.
· Tenancy details and rental history to respond to future reference
requests with your written consent.
· We may also share information about you, if required legally, for
investigation of suspected or actual fraudulent or illegal activities.
We do not sell your information to any third parties.
Scott Owen Lettings Limited also reserve the right to transfer your
information in the event of a sale or transfer (wholly or partially) of our
business assets. We will make reasonable efforts to request that the new
owner processes and protects your information in line with this privacy
notice. Your rights will not be affected as detailed in the section below.
Transfers of your information to a Third Country or International
We may occasionally have to transfer personal information about you to
recipients in other countries such as Non-resident Landlords. We will
obtain your written consent in these circumstances & will record your
acceptable method of transfer in line with GDPR.
How long we retain your information:
We will keep your information for a reasonable amount of time after our
relationship ends with you in order to perform the purposes listed above.
Our retention time frames take into account all legal and tax year
retention periods for our trading years, typically 7 years, after which
your personal information will be securely deleted. For example:
· Non Progressing Tenant enquiries - deleted after 1 month.
· Non Progressing Landlord enquiries - deleted after 6 months.
· Right to Rent ID - kept for 1 year after the known end of your
· Managed tenancies - deleted with records for the trading year in
which the tenancy ended.
· Introduction only tenancies - deleted with records for the trading
year in which the tenancy started.
· All other services - deleted with records for the trading year in
which the services were provided.
· Accounts Records - deleted by trading year end, compliant with all
tax and retention laws.
We follow a strict retention schedule with monthly and annual data audits.
We ensure data is permanently deleted, shredded in-house or we use an
accredited data disposal firm who provide us with a certificate of
destruction after the data audit.
How we secure your information:
The security of your personal information is very important to us and we
take care to protect the information we collect.
We maintain administrative, physical and technical safeguards designed to
protect your personal information. Our main objectives are to protect
against accidental, unlawful or unauthorised destruction, loss, alteration,
access, disclosure or use.
These are the measures we have in place:
· Only lawfully sharing your information to the minimum extent
· Verifying the identity of any individual requesting access to your
· All networks, computers, devices and phones are password protected.
· Data files are stored on local PCs and are encrypted where
· Antivirus and firewalls are kept up to date.
· Client files are all stored away from the public domain &
visitors are not left unsupervised.
Security of Email Communication & Data Storage:
In some cases, such as email, the data we collect from you may be
transferred to, or stored on servers at a destination outside of the
European Economic Area - EEA. Territories outside of the EEA may not have
the equivalent legal protections to those that apply within the EEA. We use
trusted service providers to process emails, who we have checked to be
taking all the steps reasonably necessary to ensure your data is treated
securely and in line with GDPR.
Transmission of information over the internet is not entirely secure. If
you submit information to us over the internet then you do so entirely at
your own risk. By submitting your personal data to us you agree to this
transfer, storing and processing.
Your Individual Rights:
Subject to certain limitations on certain rights, you have the following
rights in relation to your information:
Right to Access:
You have the right to make a SAR (Subject Access Request) to us. We will
respond to your request within 1 month and there will be no charge for this
We will require proof of your identity with the Subject Access Request to
ensure that we do not release personal information to the wrong person. We
will only release YOUR personal information unless we have the explicit
written consent of any other person concerned.
We will provide you with:
· Confirmation that we hold personal information about you
· Copies of the personal information we hold about you
· Supplementary information such as the information in this privacy
Right to Rectification, Erasure or Restriction:
If you feel the information we hold about you is incorrect or should be
deleted please contact us advising what information you feel needs
attention. We will deal with your request or write to you with any reasons
why we are unable to process your request within 1 month.
Right to Portability:
If you would like to make a request for portability this right is limited
to contract or consent. Please make your request in writing and we will
respond within one month.
Right to Object:
If you would like to object to any processing of the information we hold
about you then please contact us advising what processing of information
you would like to object to. We will deal with your request or write to you
advising of any legitimate interests which may outweigh your request.
Automated Decision Making & profiling:
We do not carry out processing of this nature.
Sensitive personal Information and Special Category Data:
Under the Immigration Act Right to Rent legislation we have a duty to check
and keep a dated copy of the required ID confirming your right to rent in
the UK. We also request, from parents or guardians, the details and dates
of birth of any dependants under 18 at the start of the tenancy. We will
ask for proof of age ID for any dependant aged 16 or over.
Landlords will be required to provide Primary ID such as a passport or
photocard driving licence to prove their identity. We may also need to
collect required ID to satisfy Money Laundering Regulations.
This is collected directly from you during the application process
Is the Provision of your data a Statutory or Contractual Requirement?
The provision of your personal data will be either of a statutory or
contractual requirement or a requirement necessary to enter into a
contract. You are obliged to provide the personal data and if you fail to
provide the requested information you will not be able to rent a property
through us, use any of our services or enter into a contract with us.
How to contact us / complaints and feedback:
Please write to us with regard to any aspect of your Data protection or to
make a Subject Access Request.
You can contact us by writing to:
The Data Protection Officer, Scott Owen Lettings Limited, 45a High Street,
Heathfield, East Sussex TN21 8HU
Or you may email us:
please put FAO Data Protection Officer in the subject line
Complaining to a supervisory authority:
If you wish to advance your complaint further then the supervisory body in
the UK is the ICO - Information Commissioner's Office
ICO Contact details can be found on their website:
We will update this policy when required so we suggest that you review this
statement at regular intervals.
Last Updated: May 2018