Privacy Policy

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.

1. 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 2nd Floor, 5220 Valiant Court, Gloucester Business Park, Brockworth, Gloucester, GL3 4FE

Pennington Choices may be a Controller or Processor for the data we process. 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.

2. 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.

• Recruitment information (including copies of right to work documentation, proof of address, references and other information included in a CV or cover letter or as part of the application process).

• Information about your race or ethnicity, religious beliefs, sexual orientation, and political opinions.

• Information about your health, including any disability, medical condition, health, and sickness records.

• Information about criminal convictions and offences.

• 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.

3. 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 collect personal information about job applicants through the recruitment process, either directly from applicants or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.

• 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.

• We may use cookies (small text files which we and other website operators store on your computer or device when you visit our website) to deliver a better and more personalised interaction. They enable us to recognise you when you return to our website, store information about your preferences and improve the way your searches are processed. They also enable us to generate anonymised statistics about the number of visitors we have and how they use our website and the internet. You can set your browser to reject non-essential cookies if you wish (you should consult your browser help section for details); this might restrict your use of our website and other websites. For more information about cookies, please see our cookie policy.

4. 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.

• Where we need to perform our recruitment process.

• Where we need to comply with a legal obligation.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Ensure your health and safety in the workplace and assess your fitness to work including processing information about your physical or mental health, or disability status.

• Ensure meaningful equal opportunity monitoring and reporting information about your race or national or ethnic origin, religious, philosophical, or moral beliefs, or your sexual life or sexual orientation.

• 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.

5. The lawful basis for which we process personal information are:

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.

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;

Vital Interests - We may share your personal information where we are compelled by law to do so.

6. Where we store your personal information

All our information is stored electronically on secure servers located within the United Kingdom, the EEA or the USA.

We endeavour to only instruct suppliers that can provide the same level of data security that we have here in the UK and where it is necessary to transfer your personal information to a country outside of the UK which has not been approved by the ICO, we will ensure that appropriate safeguards are in place. This will ordinarily be through the use of approved standard contractual clauses or an approved framework, which are designed to help safeguard your privacy rights and give you remedies in the event of your information being misused.

7. How we may share personal information

We share your personal information across Pennington Choices group of companies and with Mears Group PLC (our parent company) and its subsidiaries 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.

Examples of data processors are:

• Our website and customer management system
• Our Asbestos Management system
• Our Project Management system
• Fire Safety system
• Energy Surveying system
• Self-Serve system to provide appointment bookings

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.

We do not sell or share personal information with third parties for the purposes of marketing. However, we may use your personal information to inform you about services offered by other companies within Mears Group PLC. Also 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 or where another lawful basis applies.

Consent can be withdrawn at any time by contacting us here or by unsubscribing via the link in the respective message.

8. How we protect personal information

We will keep your personal information secure and have appropriate organisational and technical measures in place to prevent information being accidently lost, stolen, accessed, or disclosed in an unauthorised way.

We limit access to your information to those with a genuine business need to see it so those processing your information will do so in an authorised manner and subject to a duty of confidentiality.

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.

9. How long we keep personal information

We will keep your information for as long as is necessary to provide services to you, to fulfil our legitimate business interests or to meet our legal obligations. To meet our legal obligations, it may be that we need to keep your information even when you are no longer actively receiving services from us.

To determine the appropriate retention period for personal information, we consider the nature and sensitivity of the information, the purposes for which we were originally processing it, the potential risk of harm from its unauthorised disclosure or loss and any legitimate interests or legal obligations its retention may be required to meet.

10. Your rights

• You have a right to know what personal data we hold, who we acquired it from, how we process it, the logic involved in any automatic processing and to whom we disclose it.

• 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 in section 13.

• You can find out more about your rights from the Information Commissioner, who regulates data protection and privacy.

11. Complaints

We operate our own internal complaints policy; if you have any concerns about the way we collect, or handle data please contact us on Data.protection@mearsgroup.co.uk. 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.

12. 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.