This is an important notice regarding your privacy and the way in which Cove Construction Limited (referred to as “we”, “our” or “us” in this policy) collects and makes use of your personal data. We want to be open and transparent with you, and therefore encourage you to contact us if you have any questions about this policy or the ways in which we use your personal data.
This policy applies to individuals outside of our organisation, for example, applicants for vacancies, customers, employees of our clients and suppliers, and the general public. We take our privacy responsibilities seriously and 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.
For the purpose of applicable privacy legislation, the data controller is Cove Construction Limited of 1 Alpha Road, North Lane, Aldershot, Hampshire, GU12 4RG. Our company registration number is 01145104.
Questions regarding this policy should be directed to our Data Protection Compliance Manager. The Data Protection Compliance Manager is responsible for ensuring compliance with relevant data protection legislation and with this policy. The Data Protection Compliance Manager can be contacted at firstname.lastname@example.org. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Data Protection Compliance Manager.
1. What information do we hold about you?
- Personal contact details such as the name, title, address, telephone number and e-mail address;
- Recruitment information (including, for example, your driving licence, passport or visa information, the information provided to us and other personal information included in an application form, CV or cover letter (obtained as part of your application for employment with us);
- Personal information provided to us by our recruitment partners in relation to your application for employment with us;
- Personal information gathered during your application process.
Employees of our suppliers
- Contact details such as your name, title, business telephone number and business e-mail address.
- Information you provide or we collect during our interactions with you or your employer, such as how long we have done business with you or how long you have worked at your company.
- Personal details such as your name, title, personal telephone and e-mail address and address.
- Payment information such as debit card number, expiration date, security code, name as it appears on the card, the address that the card is registered to and where you opt to submit payments to us by standing order sort code, account name and account number.
- Copies of property transaction related documents which will contain your personal details.
- Personal information provided to us by the third party service providers we work with, for example, analytics providers and third party companies and / or estate agents providing us with marketing assistance.
- If you visit our premises, images and videos are recorded by the CCTV in operation onsite.
- Any personal information gathered when you visit our premises via our visitor sign-in process, including your name, company name and vehicle registration where requested.
- Any personal information you provide to us via our website, for example, by using the “Contact” page on our website.
- Any personal information you provide to us during your interactions with us.
- Information provided to us by third party service providers we work with, for example, payment service or analytics providers.
2. How long will we use your personal information and what is the legal ground we rely on for doing so?
We will only use your personal information when the law allows us to. When we use your personal information, we must have a legal ground for doing so. The following are (amongst others) the legal grounds by which we can use your personal information:
- Where you have provided us with your consent for us to do so.
- Where we need to perform the contract we have entered into with you or to take steps to enter into a contract with you.
- Where we need to comply with a legal obligation to which we are subject.
- Where it is in pursuit of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
More specifically, we will use your personal information in the following circumstances:
- To evaluate and progress your application for employment with us – to perform the contract with you or to take steps to enter into a contract with you, and in pursuit of our legitimate interests to verify your suitability for our vacancies.
- To keep a record of your application – in pursuit of our legitimate interests in the event we wish to offer to place you in another role within our organisation.
- To carry out right to work checks – to comply with a legal obligation to which we are subject.
Employees of our suppliers:
- Your contact details – in pursuit of our legitimate interests to facilitate business between your organisation and ours.
- Your contact details to provide you with further information on our products and services. This may include technical information and/or marketing information – in pursuit of our legitimate interests (keeping you informed about our products, services and business updates).
- Your contact details – to perform the contract with you or to take steps to enter into a contract with you.
- Copies of property transaction related documents – to perform the contract with you.
- Your contact details to provide you with information on our products and services which may include marketing information – where you have provided us with your consent for us to do so.
- To ensure our premises are kept secure – in pursuit of our legitimate interests (site security and evidence).
- Health and safety purposes – to comply with a legal obligation.
- To administer our website and for internal operations, including troubleshooting, data analysist, testing, research, statistical and survey purposes – in pursuit of our legitimate interests (to better understand how people interact with our website and solve any issues it may have).
- To improve our website to ensure that content is presented in the most effective manner for you and your computer – in pursuit of our legitimate interests (to improve our content and your experience).
- To transfer to third party service providers – in pursuit of our legitimate interests (outsourcing for effectiveness and efficiency).
- To contact you if we wish to use your personal information for a purpose not set out in this policy – to comply with a legal obligation.
3. What happens if there is a change of purpose?
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
4. Which type of third parties might we share your personal information with?
We require third parties to respect the security of your personal information and to treat it in accordance with the law. For example, where we instruct third party service providers, we carry out due diligence on those providers to ensure they treat your personal information as seriously as we do.
We may share your personal information with the following types of third parties:
- Recruitment partners assisting us with employment related matters, for example, recruitment agencies and job boards.
- Professional advisers such as lawyers, accountants and business analysts.
- Providers who assist us in our disaster recovery procedures, for example, back up centres.
- Providers which help us collate and organise information effectively and securely.
- Providers which help us with logistics and delivery solutions.
- Third parties who assist us with marketing for example, third party estate agencies.
5. Data retention
How long will you use my personal information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for.
We assess the appropriate retention period for different information based on the size, volume, nature and sensitivity of that information, the potential risk of harm to you from unauthorised use or disclosure of that information, the purposes for which we are using that information, applicable legal requirements for holding that information, and whether we can achieve those purpose(s) through other means in accordance with our obligations under the laws and regulations that we are subject to.
- Where your application for employment with us is successful, we will provide further information during the course of your employment as to how we use your personal information.
- Where your application for employment with us is unsuccessful, we will keep your personal information for 12 months only.
Employees of our suppliers
- Where we have collected your personal information during the course of your and our organisations doing business, we will keep your information for as long as this business carries on, or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future.
- Where we have collected your personal information during the course of you purchasing goods or utilising our services, we will keep your information for as long we have a commercial interest in holding your personal information.
- Copies of property transactional documents relating to you will be retained for a period of 25 years following the completion of the transaction. Where we are holding original signed documents, these will be retained for as long as we have a commercial interest in holding your personal information.
- If you have consented to receiving marketing information, we will keep your personal information for as long as we still have your consent.
- In relation to property sales conducted with Homes England and Help to Buy, we will delete any copies we hold of the Property Information Form, Authority to Proceed, Authority to Exchange and the Confirmation to Provider once the purchase has completed.
6. Where we store your personal information
Electronic versions of your personal information are stored on our servers which are currently located in in our head office in Aldershot, Hampshire and on our back up servers for disaster recovery purposes which are currently provided by Clunk Click in a data centre in the UK. We have taken steps to ensure that our I.T service providers respect your personal information and treat it in accordance with the law.
Where we use third party service providers to assist us, your personal information may also be stored in accordance with their practices and procedures. We require third parties to respect your personal information and to treat it in accordance with the law.
7. Rights of access, correction, erasure and restriction
Your rights in connection with your personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request the erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
8. No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
9. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to another person who has no right to receive it.
Where we are providing you with marketing information, you can also change your marketing preferences by using the unsubscribe button at the bottom of our marketing e-mails to you.
11. What happens if you fail to provide personal information?
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing you with our products or services), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of visitors to our offices).
12. Right to complain
You have a right to make a complaint if you wish to do so. The organisation with oversight of our processing is the Information Commissioner’s Office which can be contacted in writing at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, by telephone (0303 123 1113) or by e-mail (email@example.com).