General Privacy Notice
We are David English Ltd. We’re a company registered in England and Wales with company number 12813540, whose registered address is at 100 Bollo Lane, London W4 5LX. In this privacy notice, we will refer to ourselves as we, us, or our. We are the Data Controller of the personal information we collect, hold and use about you, as explained in this notice.
You can contact us in any of the following ways:
by phoning us on 0203 758 4490;
by emailing us at [email protected]; or
by writing to us at the above address.
We take the privacy, including the security, of Personal Information we hold about you seriously. This privacy notice tells you how we collect Personal Information about you and how we use that Personal Information. You should read this privacy notice carefully so that you know and can understand why and how we use the Personal Information we collect and hold about you.
We do not have a data protection officer, but if you have any questions about this privacy notice or issues arising from it you should contact David English (Director), who is responsible for matters relating to data protection at our organisation, including any matters in this privacy notice. You can contact them using the details set out above.
We may update this privacy notice from time to time. This version was last updated on 15th January 2025.
1. Key definitions
a. The key terms used in this privacy notice are defined below, for ease:
b. Data Controller: the organisation or person responsible for deciding how Personal Information is collected, stored, and used.
c. Data Processor: a Data Controller may appoint another organisation or person to carry out certain tasks on its behalf in relation to the Personal Information. This might be the hosting of a site containing Personal Information, for example, or providing an email marketing service that facilitates mass distribution of marketing material to a Data Controller’s customer base.
d. Personal Information: any information from which a living individual can be identified. It does not apply to information that has been anonymised.
e. Special Information: certain very sensitive Personal Information requires extra protection under data protection law. Sensitive data includes information relating to health, racial and ethnic origin, political opinions, religious and similar beliefs, trade union membership, sex life, and sexual orientation. It also includes genetic information and biometric information.
2. Details of Personal Information that we collect and hold about you
a. Set out below are the general categories and in each case the types of Personal Information that we collect, use and hold about you:
| General Category | Types of Personal Information in that Category | Retention Periods |
Identity Information | Name, date of birth, photo ID (e.g., passport, driving license), proof of address (e.g., utility bills). | 6 years after the end of your relationship with us, in line with legal and regulatory requirements. |
Contact Information | Address, phone numbers, email addresses. | 6 years after the end of your relationship with us, unless otherwise required by law. |
Financial Information | Bank details, payment records, credit checks, proof of funds, mortgage details. | 6 years after the transaction is complete, or longer if required by financial regulations. |
Transaction Information | Property details, tenancy agreements, sales contracts, payment history, correspondence related to your transaction. | 6 years after the transaction is complete. |
Client Correspondence | Emails, letters, phone call records, meeting notes, and complaint details. | 6 years after the last interaction, or longer for unresolved disputes. |
Tenancy Information | Tenancy application forms, references, guarantor details, tenancy agreements, inventory reports, and deposit information. | 6 years after the tenancy ends. |
Marketing Preferences | Consent records for marketing communications, preferences for email, phone, or postal communications. | Until you withdraw consent or 6 years after the last marketing interaction. |
Legal and Compliance Information | Anti-money laundering (AML) checks, right-to-rent checks, proof of ownership, regulatory and statutory records. | 5 years after the transaction or relationship ends, as required by AML regulations. |
Website Usage Data | IP addresses, browser type, device information, cookies, and analytics data. | Typically 2 years or as per cookie policy. |
b. We have set out above the details of our retention periods for different types of data. You can find them in this Section 2 and also in Section 3 below. We will only hold your Personal Information for as long as is necessary. How long is necessary will depend upon the purposes for which we collected the Personal Information (see Section 4 above) and whether we are under any legal obligation to keep it (for example, for accounting or auditing records or for tax reasons). We may also need to keep Personal Information in case of any legal claims, including in relation to any guarantees or warranties that we have provided with the goods services digital content.
c. You can contact us (using the details at the beginning of this notice) to request a copy of our retention policy, which sets out how long different types of Personal Information will be kept for.
d. The types of personal data we collect about you may differ from person to person, depending on who you are and the relationship between us.
3. Details of Special Information that we collect and hold about you
a. Special information is explained in Section 1 above. We do not collect or hold any Special Information about you.
b. We do not collect information from you relating to criminal convictions or offences.
4. Details of how and why we use Personal Information
a. We are only able to use your Personal Information for certain legal reasons set out in data protection law. There are legal reasons under data protection law other than those listed below; but, in most cases, we will use your Personal Information for the following legal reasons:
i. Contract Reason: this is in order to perform our obligations to you under a contract we have entered into with you;
ii. Legitimate Interests Reason: this is where the use of your Personal Information is necessary for our (or a third party’s) legitimate interests, so long as that legitimate interest does not override your fundamental rights, freedoms, or interests;
iii. Legal Obligation Reason: this is where we have to use your Personal Information in order to perform a legal obligation by which we are bound; and
iv. Consent Reason: this is where you have given us your consent to use your Personal Information for a specific reason or specific reasons.
b. So that we are able to provide you with services, we will need your Personal Information. If you do not provide us with the required personal information, we may be prevented from supplying the services to you.
c. It is important that you keep your Personal Information up to date. If any of your Personal Information changes, please contact us as soon as possible to let us know. If you do not contact us to keep your information updated, we may be prevented from supplying the services to you.
d. Where we rely on consent for a specific purpose as the legal reason for processing your Personal Information, you have the right under data protection law to withdraw your consent at any time. If you wish to withdraw your consent, please contact us using the details set out at the beginning of this notice. If we receive a request from you withdrawing your consent to a specific purpose, we will stop processing your Personal Information for that purpose, unless we have another legal reason for processing your Personal Information – in which case, we will confirm that reason to you.
e. We explain below the different purposes for which we use your Personal Information and, in each case, the legal reason(s) allowing us to use your Personal Information. Please also note the following:
– i. If we rely on the Legitimate Interests Reason as the legal reason for which we can use your Personal Information, we have also explained what that legitimate interest is.
– ii. For some of the purposes, we may have listed more than one legal reason on which we can use your Personal Information, because the legal reason may be different in different circumstances. If you need confirmation of the specific legal reason that we are relying on to use your Personal Information for that purpose, please contact us using the contact details set out at the start of this privacy notice.
| Purpose | Legal Reason(s) for Using the Personal Information |
Providing property services (sales, lettings, management and block management) | Contract Reason, Legitimate Interests Reason (ensuring smooth service delivery), Legal Obligation Reason (compliance with regulatory requirements). |
Communicating with clients and responding to inquiries | Contract Reason, Legitimate Interests Reason (effective customer service and relationship management). |
Conducting anti-money laundering (AML) and right-to-rent checks | Legal Obligation Reason (compliance with AML regulations and other legal requirements). |
Processing payments and managing financial transactions | Contract Reason, Legal Obligation Reason (compliance with financial regulations), Legitimate Interests Reason (ensuring accurate and efficient payment handling). |
Managing tenancies, including preparing agreements and handling deposits | Contract Reason, Legal Obligation Reason (e.g., tenancy deposit protection), Legitimate Interests Reason (ensuring smooth tenancy operations). |
Maintaining records for tax, accounting, and auditing purposes | Legal Obligation Reason (complying with tax laws and accounting standards). |
Sending marketing communications (where consent has been given) | Consent Reason. |
Improving our services and understanding client needs | Legitimate Interests Reason (enhancing customer satisfaction and service quality). |
Handling complaints and resolving disputes | Contract Reason, Legitimate Interests Reason (ensuring resolution of disputes), Legal Obligation Reason (adhering to redress scheme requirements). |
f. Sometimes we may anonymise information you provide to us, so that you can no longer be identified from it, and use this for our own purposes. In addition, sometimes we may use some of the information you provide to us together with other people’s information to give us statistical data for our own purposes. Because this is grouped together with other Personal Information and you are not identifiable from that combined data, we are able to use this.
g. Under data protection laws, we can only use your Personal Information for the purposes we have told you about, unless we consider that the new purpose is compatible with the purpose(s) we told you about. If we want to use your Personal Information for a different purpose that we do not think is compatible with the purpose(s) we told you about, we will contact you to explain this and provide you with a supplementary privacy notice.
5. Details of how we collect Personal Information and Special Information
a. We collect identity information, contact information, payment information, transaction information, tenancy information, and marketing preferences directly from you. This may occur when you:
i. Complete a form, survey, or questionnaire on our website or in person.
ii. Purchase services from us, such as property management or letting services.
iii. Contact us by email, phone, in writing, or otherwise.
iv. Subscribe to our mailing list or provide consent for marketing communications.
b. We may also receive some of your Personal Information from third parties or publicly available sources, including:
i. Property portals: For example, Rightmove or Zoopla, where you have inquired about a property we manage.
ii. Professional references: Such as employer or landlord references provided as part of tenancy applications.
iii. Government bodies or public records: Such as Companies House, the Land Registry, or the Electoral Roll.
iv. Credit reference agencies: For tenancy or financial checks.
v. Other property professionals: Such as solicitors, mortgage brokers, or surveyors involved in your property transaction.
6. Details about who Personal Information may be shared with
a. We may need to share your Personal Information with other organisations or individuals to provide our services. These include:
i. Third-Party Providers and Suppliers
IT support and software providers: For example, companies providing our bespoke property management software.
Payment processors: To facilitate secure financial transactions.
Marketing agencies and email platforms: To manage newsletters or campaigns (e.g., Mailchimp).
Maintenance contractors: Tenant contact information may be shared with trusted contractors to arrange access for property repairs, maintenance, or compliance checks.
ii. Regulatory and Legal Entities
Government bodies and regulatory organisations: Such as HMRC, The Property Ombudsman, ARLA Propertymark, or the Information Commissioner’s Office (ICO).
Fraud prevention agencies: To comply with anti-money laundering (AML) requirements.
iii. Professional Advisers
Lawyers, accountants, auditors, and insurers: For legal, compliance, or financial advice.
iv. Other Entities
Credit reference agencies: For tenancy or affordability checks.
Banks: For managing client accounts or processing refunds/deposits.
Potential buyers: If our business or assets are proposed for sale, subject to confidentiality agreements.
b. Depending on the circumstances, the organisations or individuals we share your Personal Information with may act as either Data Controllers or Data Processors. When sharing information with Data Processors, we ensure appropriate contracts are in place to outline responsibilities, obligations, and security measures for handling Personal Information.
c. We do not sell or trade any of the Personal Information that you have provided to us.
7. Details about transfers to countries outside of the EEA
We do not transfer your Personal Information outside of the EEA.
8. Automated decision-making
a. Automated decision-making is where a decision is automatically made without any human involvement. Under data protection legislation, this includes profiling. Profiling is the automated processing of Personal Information to evaluate or analyse certain personal aspects of a person (such as their behaviour, characteristics, interests, and preferences).
b. Data protection laws place restrictions upon us if we carry out any automated decision-making (including profiling) that produces a legal effect or similarly significant effect on you.
c. We do not carry out any automated decision-making (including profiling) that produces a legal effect or similarly significant effect on you. If we decide to do this, we will notify you and we will inform you of the legal reason we are able to do this.
9. Your rights under data protection law
a. Under data protection laws, you have certain rights in relation to your Personal Information, as follows:
Right to request access: (this is often called “subject access”). This is the right to obtain from us a copy of the Personal Information that we hold about you. We must also provide you with certain other information in response to these requests to help you understand how your Personal Information is being used.
Right to correction: this is the right to request that any incorrect Personal Information is corrected and that any incomplete Personal Information is completed.
Right to erasure: (this is often called the “right to be forgotten”). This right only applies in certain circumstances. Where it applies, you have the right to request that we erase all your Personal Information.
Right to restrict processing: this right only applies in certain circumstances. Where it applies, you have the right to request that we restrict the processing of your Personal Information.
Right to data portability: this right allows you to request that we transfer your Personal Information to someone else.
Right to object: you have the right to object to us processing your Personal Information for direct marketing purposes. You also have the right to object to us processing Personal Information where our legal reason for doing so is the legitimate interests reason (see Section 4 above) and there is something about your particular situation that means you want to object to us processing your Personal Information. In certain circumstances you have the right to object to processing, where such processing consists of profiling (including profiling for direct marketing).
b. In addition to the rights set out in this section, where we rely on consent as the legal reason for using your Personal Information, you have the right to withdraw your consent. Further details about this are set out in Section 4.
c. If you want to exercise any of the above rights in relation to your Personal Information, please contact us using the details set out at the beginning of this notice. If you make a request, please note:
we may need certain information from you so that we can verify your identity;
we do not charge a fee for exercising your rights unless your request is unfounded or excessive; and
if your request is unfounded or excessive, then we may refuse to deal with your request.
10. Marketing
a. You may receive marketing from us about similar goods and services, where either you have consented to this or we have another legal reason by which we can contact you for marketing purposes.
b. However, we will give you the opportunity to manage how or if we market to you. In any email that we send you, we provide a link to either unsubscribe or opt out, or to change your marketing preferences. To change your marketing preferences and/or to request that we stop processing your Personal Information for marketing purposes, you can always contact us using the details set out at the beginning of this notice.
c. If you request that we stop marketing to you, this will not prevent us from sending communications to you that are not to do with marketing (for example, in relation to services that you have purchased from us).
d. We do not pass your Personal Information on to any third parties for marketing purposes.
11. Complaints
a. If you are unhappy about the way that we have handled or used your Personal Information, you have the right to complain to the UK supervisory authority for data protection, which is the Information Commissioner’s Office (ICO). Please do contact us in the first instance if you wish to raise any queries or make a complaint in respect of our handling or use of your personal information, so that we have the opportunity to discuss this with you and to take steps to resolve the position. You can contact us using the details set out at the beginning of this privacy notice.