This Data Protection privacy notice is effective as and from the 25th May 2018.
This is your guide as to how your personal data is managed by Andrews & Robertson (A&R). Data privacy is taken very seriously by us. This document outlines our approach under the General Data Protection Regulation 2018 (GDPR). In this notice, we explain how we collect personal information about you, how we use it and how you can interact with us about it.
This privacy notice applies to personal information processed by or on behalf of Andrews & Robertson.
Who are Andrews & Robertson?
Andrews & Robertson is the trading name for Andrews & Robertson (Auctions) Limited, a property auctioneering company. Registered office: 75 Camberwell Church Street, London SE5 8TU.
Please use the links below to find out more about how we use your personal information
The type of information that we may collect from you includes:
- Your identity & contact name, copies of ID (which may include your date of birth), your home address, NI number (or foreign equivalent), online user identifiers (such as your log on details), IP addresses, cookie identifiers, email addresses and contact phone numbers.
- Bank account details, credit/debit card details, authorised signatory details, information relating to power of attorney arrangements.
- Information you provide to us about others or others provide to us about you. An example relates to information concerning bidder and purchaser details for a property when somebody is registering to bid at an auction. Before you disclose information to us about another person, you need to be sure that you have their agreement to do so. You must ensure that this other person confirms that they know you are sharing their personal information with us.
- Sensitive categories of data - we may hold information about you which includes sensitive personal data. We will only hold this data when we need to for the purposes of the service we provide to you or where we have a legal obligation to do so. We are required to process sensitive personal data when we process your passport ID or driving licence ID in the context of compliance with our anti-money laundering obligations.
- Information which you have consented to us using such as allowing us to contact and send you property related communications on a periodic basis. We also collect information about your internet activity using technology known as cookies which can often be controlled through internet browsers. A cookie is a little piece of text that our server places on your device when you visit any of our websites or apps. A cookie helps us make our website work better for you.
- We collect information about your internet browser settings or Internet Protocol (IP) address and other relevant information to help us identify your geographic location when providing you with our services.
- We may also collect CCTV images at our office locations (but only for security reasons and to help prevent fraud or crime)
There are a number of reasons for Andrews & Robertson doing so. We need to:
- Know how to contact you
- Be certain of your identity and
- Understand your circumstances so we can offer you the best possible customer experience.
We collect information about you in a number of different ways. Some examples include:
- When you set up an account with us online.
- When you register with us to participate in an auction.
- When you use our website.
- When you or others give us information verbally or in writing. This information may be by way of registration forms, viewing attendee sheets, through correspondence with us or if you make a complaint.
- From your online activities with third parties where you have given us your consent (e.g. by consenting to our use of certain cookies or tracking pixels.
We may use your personal data in a variety of ways, for example:
- To confirm your identity to help us in the processing of an application for one of our services or to improve your customer experience with us.
- To manage and administer your account and process transactions that are payable to you or by you. For example, if you have provided us with your credit or debit card information (Visa or Mastercard) or if you have provided us with your bank account details.
- To contact you by post, phone, text message, email or social media using our website or other means but not in a way that is contrary to your instructions to us, legitimate interest or contrary to law. We may monitor and record our conversations when we speak on the telephone (to check your instructions to us and for training and quality purposes) but will advise you if we are doing so.
- To manage our business for our legitimate interests, this may include marketing activities such as direct marketing (provided that you have not objected to us using your details in this way) and research, including customer surveys, analytics and related activities.
- To carry out strategic planning and business portfolio management. This could include compiling and processing your information for audit, statistical or research purposes (including, in some instances, making your data anonymous) in order to help us understand trends in our customer behaviour and to understand our risks better, including providing management information, operational and data risk management.
- To manage and administer legal and compliance matters within A&R, including compliance with regulatory, legislative and voluntary codes of practice to which we have committed. We use your data to comply with your information rights, to establish your identity and to comply with laws and regulations concerning the prevention of money laundering, fraud and terrorist financing. As a result, we may need to disclose information to government and other statutory bodies. Your data may be used to comply with binding court orders, search warrants, requests to assist the police with the investigation or prevention of an offence and orders relating to requests for mutual legal assistance in criminal matters received from foreign law enforcement agencies.
Andrews & Robertson may in the future wish to sell, transfer or merge part or all of its business or assets or to buy a new business or the assets of another business or enter into a merger with another business. If so, we may disclose your personal information under strict duties of confidentiality to a potential buyer, transferee, merger partner or seller and their advisers, so long as they agree to keep it confidential and to use it only to consider the possible transaction.
We protect your information with security measures under laws that apply and we meet international standards in doing so. We keep our computers, files and buildings secure. Personal data could be used to prevent and detect fraud, dishonesty and other this could include using CCTV at our office premises or auction venue.
We do not use automated processing in relation to the information we collect from you as part of our business.
Andrews & Robertson use google analytics for statistical purposes. This enables us to make more informed business decisions, including improving the quality of services we can offer.
We only share your information with a certain number of other parties and only as necessary. Examples of information sharing here include:
- Your authorised representatives. This would include your Attorney (under a Power of Attorney) and any other party authorised by you to receive your personal data e.g a solicitor acting on your behalf in the sale or purchase of a property.
- Third parties we need to share your information with in order to facilitate payments (for example, stripe, SWIFT, credit card issuers and merchant banks) and those you ask us to share your information with.
- Companies that provide support services for the purposes of protecting our legitimate interests. Your personal information remains protected when our service providers use it. We only permit service providers to use your information in accordance with our instructions, they have appropriate measures in place to protect your information.
- Statutory and regulatory bodies (including central and local government) and law enforcement authorities.
The length of time we hold your data depends on a number of factors, such as regulatory and statutory requirements. Other considerations are the type of data we hold about you, whether the data is required for a legal dispute and whether you or a regulatory authority asks us to keep it for a valid reason.
As a general rule, we keep your information for a period of 7 years. However, if you request that A&R delete your data prior to this period elapsing, we shall process your request unless there is a valid reason not to delete the data (such as a requirement to hold onto your data due to a legal obligation to do so).
Sharing information with us is in both your interest and ours. We need your information in order to provide our services to you, to fulfil any contracts we have with you, to manage our business for our legitimate interests and to comply with our legal obligations.
You can choose not to share information with us but must understand that this may limit the services we are able to provide to you.
We will use your data and may share that data where:
- Its use is necessary in relation to a service or a contract that you have entered into or because you have asked for something to be done so that you can enter into a contract with us or so that we can provide a service to you.
- Its use is in accordance with our legitimate interests. Where we process your information for our legitimate interests, we ensure that there is a fair balance between our legitimate interest and your fundamental rights and freedoms. We may use your personal information to manage our everyday business needs including internal reporting, market research, to progress and respond to legal claims, to ensure appropriate IT security and to prevent fraud. Our legitimate interest here is the effective management of our business. We may use your personal information for marketing reasons, i.e. to update you in regarding to property related matters. Our legitimate interest here is to connect with you and to update you on properties and services we provide which may be of interest to you.
- Its use is necessary because of a legal obligation that applies to us.
- You have consented to the using of your data (including special categories of data) in a specific way.
- Where you have made clearly sensitive categories of data about yourself public.
- Where the processing of special categories of data is necessary for the establishment, exercise or defence of legal claims.
Your information is stored on secure systems within the premises of A&R and with providers of secure information storage. A&R do not transfer information about you outside the EEA.
We may however allow the transfer of information about you outside the EEA by our service providers, but only if they agree to act solely on our instructions and to protect your information to the same standard that applies in the EEA.
You should tell us so that we can update our records using the details in the Contact Us section of our website. We will then update our records accordingly.
You have several rights in relation to how we use your information and we have significant obligations in this regard.
You have the right to:
- Find out if we use your information, to access your information and to receive copies of the information we have about you. When you contact us to ask about your information, we may ask you to identify yourself. This is to help protect your data. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you ask us otherwise.
- Request that inaccurate information is corrected and incomplete information updated.
- Object to particular uses of your personal data where the legal basis for our use of your data is our legitimate business interests. However, doing so may have an impact on the services we can / are willing to provide.
- Object to the use of your personal data for direct marketing purposes.
- Have your data deleted or its use restricted – you have a right to this under certain circumstances.
- Obtain a transferable copy of certain data which can be transferred to another provider, known as "the right to data portability". This right applies where personal information is being processed based on consent or for performance of a contract and the processing is carried out by automated means. You are not able to obtain through the data portability right all of the personal information that you can obtain through the right of access. The right also permits the transfer of data directly to another provider where technically feasible. Therefore, depending on the technology involved, we may not be able to receive personal data transferred to us and we will not be responsible for the accuracy of same.
- Withdraw consent at any time, where any processing is based on consent. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.
- Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.
We shall process your request without undue delay. In most instances, we will respond within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar month period. Should this be necessary, we will explain the reasons why.
You have the right to complain to Andrews & Robertson or to raise your concerns with the Information Commissioner’s Office. If you have a complaint about the use of your personal information, please let us know and we shall seek to resolve your issue as soon as possible. If you wish to make a complaint to us you may do so in person, by telephone, in writing or by email. Please be assured that all complaints received by us will be fully investigated. We ask that you supply as much information as possible to help us to resolve your complaint quickly.
If you have any questions about how your personal data is gathered, stored, shared or used, or if you wish to exercise any of your data rights, please contact our Data Protection Officer at:
Online: www.a-r.co.uk using the Contact Us section on our website
Telephone: 020 7703 4401
Postal Address: 8-10 Pollen Street, Mayfair, London, W1S 1NG
If you are dissatisfied with how A&R have handled your information rights concern, you can raise your concerns with the Information Commissioner’s Office.
Web address: ico.org.uk
Telephone: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number
Fax: 01625 524 510
Postal Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
We will update this data privacy notice from time to time. Any changes will be made available on this page.