Pennington Choices (“We”) are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting http://pennington.org.uk/ you are accepting and consenting to the practices described in this policy.
Who we are
In these Terms, ‘group’, ‘we’, ‘us’ and ‘our’ mean Pennington Choices, an organisation which provides property surveying and consultancy to the social housing sector.
It comprises the companies listed below:• Pennington Choices - a limited company by guarantee (registered in England under number 03945920)
• The registered office for this company is at Brookfield House, Tarporley Road, Norcott Brook, Cheshire WA4 4EA
Pennington Choices is acting as the data controller and determines the purposes for which, and the way in which, your personal data is processed. In this Privacy Notice, ‘our website’ means http://www.pennington.org.uk/
We are committed to protecting your privacy and aim to be clear when we collect your information and use it only as you would reasonably expect. You can contact us at firstname.lastname@example.org, by telephone on 0800 883 0334, or by writing to the registered office above.
This privacy notice sets out the relationship between Pennington Choices and you as a prospective, current, or former customer (‘you’, ‘your’). It tells you how and why we collect information about you, how it is used and stored and who it is shared with, so we are open with you about what information we hold and what we do with it.
We act according to the law to protect your rights and ensure the security of the data we hold about you. This Privacy Notice sets out the information we are obliged to give you under the UK General Data Protection Regulation.
We therefore collect, process and store personal data both to help us promote the interests of customers, to educate them, keep them up to date, and to provide products and services, as well as administering Pennington Choices services.
We are careful when selecting the persons with whom we share data and do not share data with third parties except with your consent or where we tell you in advance that this will happen. Data is shared across Pennington Choices between the companies within the group.
The information we hold about you
We collect and handle the following information about you:
• Your personal information and contact details. This includes title, name, month and year of birth, address, email address and other contact information.
• Your cookie and website preferences on how you would like to be contacted and what about and your activity on our website e.g. pages visited and emails received and read.
• Website visits, including technical information such as how you accessed the site, how you engaged with us during the visit, etc.
• Any information you have provided to us about your properties, tenancies, and tenants that you manage. This includes any documentation you have uploaded to us for the purpose of providing our services.
• Payment information and history.
• Bank and direct debit details.
• Products and services supplied/enquired about, including from third parties.
• Training courses and other events/conferences enquired about or attended.
• Communications between us, including emails and audio recordings of calls made to and from us, including complaints.
• Research and material gathered from you.
• Profiling information that has been obtained from reliable 3rd parties.
How we collect personal information
We collect the following personal information about you:• Directly through our website, via our partner websites, over the phone, through surveys, research and sometimes paper forms.
• Via third-party intermediaries and our representatives who may provide us with your personal information when they register you for their services.
• We may collect information about the software on your computer or device (your browser version etc.) and your IP address (your connection with the internet) to improve your interaction with our website and for our records. This may happen automatically without you being aware of it.
How we use your personal information
We will not use your personal information unless we have first told you how we will use it, or it is obvious how we will use it. We may need to collect and use your personal information for:• Managing your customer account
• Processing customer administration, including payment, contract renewals, providing event/conference information and delivery of training exercises.
• Customer administration by post, telephone, email, and other electronic means. Delivering any relevant communications.
• Keeping a record of individuals and/or organisations may have been terminated as customers; including but not limited to name, address, email address, telephone number, date that service was terminated and relevant notes.
• Appointments of directors.
• Monitoring use of, and satisfaction with services, and communications.
• Carrying out our own surveys or research and forwarding these and consultations run by other organisations with whom we collaborate.
• Facilitating interactions with or partners or third-party providers.
• Receiving information about you from a third party. In some instances, where you request a product or service or benefit via one of our selected providers, the provider will inform us of this request.
• Processing conference applications, registrations, administration and informing people about our conferences.
• Keeping a record of individuals and or organisations who have booked or registered to attend a Pennington Choices event/conferences, meetings, or course and administering their attendance at these.
• Providing services and/or fulfilling orders for services. General administration and marketing.
• Keeping a record of your consent to receive marketing emails.
• Targeting display advertising to users that have previously visited our website and shown interest in our products and services.
• Understanding the use of our website, including details of your visits to our website; this might include traffic data, location data, weblogs and other communication data and the resources that you access.
• Recording information about visitors to our premises.
• Developing profiling or segmentation models to allow us to be more targeted in our marketing.
• Applicant, employee, and contractor administration.
• Our legal basis for processing personal information.
The purposes for which we process personal information are:
Contractual - The performance of our contract with you to provide information, services, facilitation of appointments; Legitimate interests – Informing customers of the activities of Pennington Choices in the sector we serve; Consent - Providing you with targeted offers and marketing from us or our partners. We process personal information to define customer types and serve relevant messaging to users who could be interested in our products and services.
The law allows us to collect and use personal data if it is necessary for our legitimate business interest and so long as its use is fair, balanced and does not unduly impact your rights. In many situations, the best approach is to process personal data because of our contract with you and our legitimate interests as a trading company, rather than through consent. However, we will ask for your consent to send you marketing emails and text messages. You can withdraw your consent at any time.
In certain instances, we are required by law to process personal data. This includes doing so when arranging and conducting services or training exercises. In extreme situations, we may share your personal details with the emergency services if we believe it is in your ‘vital interests’ to do so. We may also share your personal information where we are compelled by law to do so.
Special Category Data
Special category data (also known as sensitive personal data) is data which requires higher levels of protection. We need to have further justification for collecting and handling this kind of personal information. Special category data includes:
We rely on additional legal gateways allowing the processing of special category data as follows:• In limited circumstances with your explicit consent.
• In our own legitimate interests as a trading business. This enables us to process information about and normally this will be anonymised. This is done during our legitimate activities with appropriate safeguards and for the purposes of conducting business.
Special category data is processed by us as follows:• We may collect and handle special category personal data. It may be shared with us to enable us to serve our customers.
• We process special category data in our own legitimate interests.
Where we store your personal information
All our information is stored electronically on secure servers located within the United Kingdom, the EEA or the US and is encrypted whilst not being used. Telephone conversations are recorded electronically for monitoring, auditing, and training purposes. This includes advice given to you over the telephone by our contact centre representatives.
By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice. All information you provide to us is stored on our, or our partners’, secure servers.
Any payment transactions are encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
How we may share personal information
We share your personal information across Pennington Choices group of companies to carry out different activities and provide our services.
We may share some of your personal information with organisations that carry out processing operations on our behalf, such as web services companies and mailing organisations.
We carry out checks on these companies before we work with them and put a contract and data sharing agreement in place that sets out our expectations and requirements, especially regarding how they manage the personal information that we give to them.
Our primary data processors are:• Hubspot who provide our website and customer management system
• Mark One to provide our Asbestos Management system
• Simpro to provide our Project Management system
• Safety Culture to provide Fire Safety reports
• EPC portal to provide Energy Surveying reports
• Self-Serve system (B2B) to provide appointment bookings
We do not sell or share personal information with third parties for the purposes of marketing. But if we run an event in partnership with another named organisation, your details may need to be shared with them. We will be very clear what will happen to your personal information if you register for such an event.
We will not sell personal information other than as part of a sale of a substantial part of our assets. We may disclose it to a prospective purchaser, but only for use in connection with that sale. We may, however, need to disclose your details, if required, to the police, regulatory bodies, or legal advisors.
We will only ever share your data in other circumstances if we have your explicit and informed consent.
How we protect personal information
We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff and contractors. We also provide guidance and regular data protection training to our staff.
We ensure there are appropriate technical controls in place to protect your personal details, for example, our computer network and servers are protected and routinely monitored to industry standards of good practice (Cyber Essentials).
We store all personal information you supply on secured servers or in secured paper files. For your protection, any payment details you provide to us will be encrypted using SSL (Secure Sockets Layers) technology. Unfortunately, the transmission of information over the internet can never be completely secure. Although we will do our best to ensure that your personal information is protected, we cannot guarantee the security of your data transmitted to the website. Any transmission of your personal information by you is, therefore, at your own risk.
How long we keep personal information
We will only keep personal information for as long as we have a valid reason for keeping it. After that, we delete or dispose of the information securely.
We keep personal information about:• Our customers for seven years after ceasing to be a customer.
• Complaints and feedback for two years.
• Event applications, registrations, and administration for two years until after the event has taken place.
• Analytics information for three years.
• Job applications for twelve months.
• Employees for the duration of their employment and seven years after employment ceases in accordance with the law.
• You have a right to ask us not to process your personal data for direct marketing purposes.
• You have a right to ask us not to make decisions based solely on the automatic processing of your personal information.
• You have a right to ask us not to process your personal information in a way that is likely to cause unwarranted and substantial damage or distress.
• You have a right to ask us to erase your personal information.
• These statutory rights are qualified by exceptions and exemptions. To exercise any of these rights, please contact us using the details shown at the start of this Privacy Notice.
• You can find out more about your rights from the Information Commissioner, who regulates data protection and privacy.
We operate our own internal complaints policy; if you have any concerns about the way we collect, or handle data please contact us. You can find out more information on this process on our website. Additionally, you have the right to lodge a complaint with the Supervisory Authority at The Information Commissioner, Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF www.ico.org.uk.
Changes to this policy
We may change this Privacy Notice from time to time. If we make any significant changes in the way we treat your personal information, we will make this clear on our website or by contacting you directly.