Privacy Policy (GDPR)

Privacy Statement – Forsyth Residential Lettings

This document outlines how your personal data is managed by Forsyth Residential Lettings. Its purpose is also to assure you that we treat data protection issues with the utmost importance. This document complies with General Data Protection Regulation (GDPR) May 2018.

1. About Us

The registered office of Forsyth Residential Lettings is located at 13 Killeen Crescent, Malahide, County Dublin K36 YD74. Our PRSA licence number is 002955, CRO No.  279024.

      B.) How do you collect information about me? When will you do so?

We collect information about you in different ways. Examples include:

• When you register with us to receive updates on lettings

• When you use our website www.spiderweb.ie

• When you or others provide us with information verbally or in writing

1. Why do you collect information about me? What information will you collect?

There are a multitude of reasons why Forsyth Residential Lettings collects information. We need to know how to contact you, to be certain of your identity and to fully understand your personal circumstances. This is to ensure the most the appropriate services are offered to you so that you enjoy the best possible customer experience from us.

The type of information that Forsyth Residential Lettings may request or collect from you includes:

• Your name, contact phone number(s), email address(es), IP address(es), cookie identifiers, copies of ID (which may include your date of birth) and PPS number (or foreign equivalent)
• 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. Before you disclose information to us about another individual you need to be sure that you have their full and unequivocal permission to do so
• Information about you which may include sensitive personal data. We will only hold this data when and for as long as we need to for the purposes of the letting service we provide to you or where we have a legal obligation to do so. We are required to treat and process this as ‘sensitive personal data’ when we seek proof of address, your passport ID or driving licence ID to fully comply with our anti-money laundering obligations
• Information which you have consented us to use such as allowing us to contact and send you property related communications on a periodic basis. Our IT system also collects information about your online interactions with us. These are known as cookies which can often be controlled through internet browsers. A cookie is a small piece of text that our server places on your device when you visit our website or app. A cookie helps us to make our website work better for you as a client of Forsyth Residential Lettings.

1. How do you use my information?

We may use your data to contact you by phone, text message or email. This will not be in a way that is contrary to your instructions to us, your legitimate interest or contrary to law.

We may use your personal data for matters such as confirming your identity, to help us in the processing of an application for lettings or to improve your customer experience with us.

Your data is used to manage and administer your file. Your data may also be used to process payments, e.g., if you have provided us with your credit or debit card information or bank account details.

Your data may also be used to respond to a complaint or appeal that you have.

We may also use your data to manage our business for our legitimate interests, such as direct marketing (provided you have not objected to us using your details in this way) and research, including customer surveys, analytics and related activities.

Your data may be used to carry out strategic planning and business portfolio management. This may include compiling and processing your information for audit, statistical or research purposes (including, in some instances, making your data anonymous). This is to help us understand trends in our customer behaviour and to understand our risks better, including providing management information, operational and data risk management.

We may use your data to protect our business, reputation, resources and equipment. We may also use it to manage network and information security (developing, testing and auditing our website and other systems, dealing with accidental events or unlawful or malicious actions that compromise the availability, authenticity, integrity and confidentiality of stored or transmitted personal data and the security of the related services).

Forsyth Residential Lettings protect your information with security measures under the relevant laws that are currently in effect, and we meet international standards in doing so. We also do our utmost to ensure our equipment, files and buildings are fully secure. Personal data could be used to prevent and detect fraud, dishonesty and other crimes (such as preventing someone trying to steal your identity – also known as identity theft).

In future, Forsyth Residential Lettings may wish to sell, transfer or merge part or all of its business or assets, 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 need to use your information to manage and administer legal and compliance matters within Forsyth Residential Lettings, 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 Gardaí 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.

1. Do you share my information with anyone else?

We only share your information with a certain number of parties and only as necessary. Examples of information sharing include:

• Authorised representatives – including your Solicitor (under a Power of Attorney) or any other party authorised by you to receive your personal data
• Third parties we may need to share your information with. This is to facilitate payments (e.g. banks / credit and card issuers etc.) as well as those you ask or give us permission to share your information with such as tradespeople working on behalf of FRL or our clients/owners.

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 and they will have appropriate measures in place to protect your information. Our service providers include marketing companies, IT and telecommunication service providers, software development contractors, data processors, debit/credit card companies, computer maintenance contractors, printing companies, property contractors, document storage and destruction companies, business advisers, debt collection agencies, auditors and other consultants including legal advisers.

Statutory and regulatory bodies (including central and local government) and law enforcement authorities. These bodies include the Data Protection Commissioner, the PSRA (Property Services Regulatory Authority), An Garda Síochána/police authorities/enforcement agencies, the Revenue Commissioners, the Criminal Assets Bureau and US, EU and other designated authorities in connection with combating financial and other serious crime.

1. What about links on your website to other sites and social media?

Our site (www.spiderweb.ie) may, from time to time, contain links to and from other websites and web platforms. In addition, third party websites may also provide links to our site. If you follow a link to any of these websites or web platforms, please note that these have their own privacy policies and it is therefore vitally important for you to understand that we do not accept any responsibility or liability for those policies. Please check these policies carefully before you submit any personal data. We do not accept and disclaim any responsibility for the privacy statements and information protection practices of any third-party website (whether or not such a website is linked on or to the site). These links are provided to you for convenience purposes only and you access them at your own risk. It is your responsibility to check the third-party website’s privacy statements before you submit any personal data to their websites.

G. How long do Forsyth Residential Lettings hold onto my information?

The length of time we hold your personal data depends on factors such as statutory and regulatory 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.

A general rule of thumb is that we keep your information for a period of 7 years. However, if you request that Forsyth Residential Lettings delete your data prior to this 7-year period elapsing we will process your request under the auspices that we do not have an obligation or legal reason to retain such information.

H.) What happens if I do not provide requested information to Forsyth Residential Lettings?

Sharing information with Forsyth Residential Lettings is in both your interest and ours. We need your information to provide our services to you, fulfil any contracts we have with you, to manage our business for our legitimate interests and to fully comply with our legal obligations.

You can choose not to share information with us, and are fully entitled to do so, but must understand that this may limit the services we are able to provide to you. We may not be able to provide you with certain services that you request if you do not provide certain information. For example, if you do not provide us with all requested information when registering for a letting, we may not be able to approve you for said letting.

I.) What is the legal basis for Forsyth Residential Lettings using my information?

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 an action to be taken so that you can enter into a contract with us or so that we can provide a particular service to you

or

• 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 these 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 such as to update you regarding property related matters. In this case our legitimate interest is to connect with you and to update you on properties and services we provide which may be of interest to you.

Other circumstances may include:

• Where the processing of special categories of data is necessary for the establishment, exercise or defence of legal claims

Or when:

• You have consented to the use of your data (including special categories of data) in a specific manner

Or where:

• You have made clearly sensitive categories of data about yourself public

• Its use is necessary because of a legal obligation that applies to Forsyth Residential Lettings

J.) Security

Your Personal Data is held on secure servers hosted by our ISP (Internet Service Provider).  The very nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us. No data transmission over the Internet can be guaranteed to be 100% secure. However, please be assured that Forsyth Residential Lettings will endeavour to take all reasonable steps (including appropriate organisational and technical measures) to protect your Personal Data.

K.) Does Forsyth Residential Lettings process my information outside the European Economic         Area (EEA)?

Your information is stored on secure systems within the premises of Forsyth Residential Lettings at Malahide, County Dublin and with providers of secure information storage. Forsyth Residential Lettings do not transfer information about you outside the EEA.

L.) What are my rights under GDPR?

You have several rights in relation to how Forsyth Residential Lettings uses your information. Indeed, we have significant obligations in this regard.

You have the right to:

• Be informed if we use and/or access your information and to request a copy 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, also provide the relevant information electronically unless you request another method of delivery

• Request that inaccurate information is made correct and incomplete information is updated

• Object to specific use(s) of your personal data where the legal basis for our use of your data is our legitimate business interests. However, it should be noted that in 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. This is 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 where the processing is carried out by automated means. The right also permits the transfer of data directly to another provider where technically feasible

• Withdraw consent at any time where any processing of information is based on consent. If you choose to withdraw your consent it will not affect the lawfulness of processing based on your consent before its withdrawal

• We shall process your request as quickly as is reasonably possible. 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 months. We will explain the reasons behind this decision should this be necessary

• You have the right to complain to Forsyth Residential Lettings, the Data Protection Commission or any other appropriate supervisory authority. If you have a complaint about the use of your personal information, please let us know and we shall endeavour to resolve your issue as quickly as possible. If you wish to make a complaint to Forsyth Residential Lettings you may do so by telephone, in person, in writing or by email. Please be assured that all complaints received by us will be taken seriously and will therefore be fully investigated. We ask that you supply as much information as possible to help us to resolve your complaint as quickly and as painlessly as possible.