Privacy Statement
Carty Property Advisor’s Privacy Information Notice for Clients, Contractors, Suppliers and Business Contacts
POLICY STATEMENT
Carty Property Advisor’s is committed to protecting and respecting the privacy of all of our clients. This Policy adopted by Carty Property Advisor’s explains when and why personal information is collected, how it is used, the conditions under which it may be disclosed to others and the choices clients have with regards to data collection and storage.
This policy relates to all data collected throughout all business activities and has been adopted in compliance with the EU General Data Protection Regulations (GDPR). Supplementary Privacy Information Notices may be issued for specific business activities.
Carty Property Advisor’s is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you and explaining it clearly to you.
This notice applies to prospective, existing and former customers of Carty Property Advisor’s(including employees and representatives of our customers); individual and business contacts and prospects; referrers; individuals who request information from us; any person who provides services to us, either as an individual or as the employee or representative of a corporate service provider; third parties acting for our customer.
Carty Property Advisor’s reserve the right to update this notice at any time. Should any substantial updates be made, we will notify you. We may also notify you in other ways from time to time about the processing of your personal information.
Any questions regarding this Policy and our privacy practices should be sent by email to the office for the attention of Marie Carty using the contact details in Clause 11 below.
1. Who are Carty Property Advisor’s
Carty Property Advisor’s is a sole
trader company providing Estate Agency Services.
The company registration number: 215283
VAT registration number: 5050054A
The registered address: Lower Bridge Street,
Athboy, Co. Meath
Further details can be found via the company website: www.carty.ie
Carty Property Advisor’s is regulated by PSR, Firm number: 001548
2. How do we collect information?
Carty Property Advisor’s collects personal information direct from Clients, Contractors, Suppliers and Business Contacts upon enquiry about services and throughout the engagement.
The method of collecting information would depend on the nature of the enquiry and the route that the query has taken. Should a third party have been used, for example an external property website, their terms and conditions would stand.
Carty Property Advisor’s accepts consent for an individual’s contact details by way of a telephone call.
We may collect information from other third parties, such as from referrers and from credit reference agencies or other background check agencies.
We also may collect your personal data when you or your organisation engage us or inquire about engaging us to provide property advice or property services;
We may also collect information about Clients, Contractors, Suppliers and Business Contacts from public sources, such as Companies Registration Office, from an online search or from social media sites.
Personal data, or personal information, means any information about an individual from which that person can be identified.
Carty Property Advisor’s will collect different information depending on your relationship with us and the type of engagement.
Typical information collected, processed and stored on file could be as follows:
For marketing, business operation and relationship management purposes, we will collect and process Personal Data including:
We use your personal information for the purposes of fulfilling our obligations to you to let or sell your property or, if you are a buyer or tenant, for the purposes of arranging a contract for sale or a lease for you.
Carty property Advisor’s does not gather sensitive personal data (e.g. health, genetic, biometric data; racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sexual orientation, and criminal convictions) within day to day business.
For Anti-Money Laundering Regulations, details of any political connections will be requested, and risk assessed within certain circumstances to comply with our legal obligations.
Carty Property Advisor’s services are not directed to children under the age of 13. If it is suspected that a child under the age of 13 has provided Carty Property Advisor’s with personal information, please notify Carty Property Advisor’s.
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
We may also use your personal information when deemed in the public interest, which is likely to be rare.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
We will only use your personal information for the purposes for which we collected it, as outlined above, 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 any unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Carty Property Advisor’s will not sell or rent client information to third parties.
Carty Property Advisor’s also will not share client information with third parties for marketing purposes. Carty Property Advisor’s may however, pass client information to third party service providers who have been engaged for the purpose of completing tasks and providing services on Carty Property Advisor’s behalf. We disclose only the personal information that is necessary to deliver the service.
Carty Property Advisor’s uses a number of third party companies to assist with fulfilling contractual obligations, dependant on the type of work. As each agency or consultancy engagements differ by their nature, a typical list of third parties have been listed in the table below.
The following table outlines the personal data Carty Property Advisor’s collects and for what purpose. The table also outlines the third parties that the data is processed by or shared with, and how long the data is stored for.
From time to time we may transfer Personal Data to countries outside the EEA which may not have the same or equivalent Data Protection Law as Ireland. If such transfer occurs we will ensure that such processing of your Personal Data is in compliance with GDPR and , in particular, that appropriate measures are in place such as entering into Model Contractual Clauses (as published by the European Commission) or ensuring that the recipient is Privacy Shield certified, if appropriate. For further information about these transfers and to request details of the safeguards in place, please contact us using the details in Clause
11.
| Data Type | Description of Data | Legal Ground | Purpose for Collecting | Third Parties Involved | Data Retention |
| Contact Details | Contact details of perspective and ongoing clients. | Contract | To enable ongoing communication with clients and third parties. | Vebra message stream hosts the emails. | Until request for deletion. |
| Electronic (and hand printed hardcopies on file where necessary) communications of ongoing discussions. | Contract | To enable ongoing communication with clients and third parties. | Vebra message stream hosts the emails. | Until request for deletion. | |
| Back up of Emails | History of email conversations | Contract | Cloud backup to ensure business continuity | Vebra message stream hosts the email backup. | Until request for deletion. |
| Letters | Written communication between parties. | Contract | To enable ongoing contact with clients and third parties including requests for information. | Third parties would vary however could include: Solicitors Surveyors Planners, Other Companies or agencies such as highways agencies. | All communications would stay on file until archived. Data retention periods are dependent on the type of transaction, for example a property sale or purchase would be held for 5 years after the end of business relationship in accordance with Money Laundering Regulations. |
| Identification | Copies of documents which confirm identification of Clients. | Legal Obligation | To Comply with money Laundering Regulations. | None as currently undertaken in house. | 5 years after the end of the business relationship. |
| Reports and / or surveys | Copies of reports or surveys as commissioned by Carty Property Advisors for reference. | Contract | To complete the engagement as per request of the Client. | As per letters above. | All reports would stay on file. See retention details under letters above. |
| Legal Documents. | Copies of documents in reference to the engagement. | Contract | To complete the engagement as per request of the Client. | Typically originated from surveyors, planners or Government departments. | All reports would stay on file. See retention details under letters above. |
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies.
Carty Property Advisor’s do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with our instructions.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
We shall keep the personal data we process for a minimum period of 7.5 years after the client in question ceases to be our client. We retain the personal data so that we may fulfil our obligation to protect our client’s interests, to protect our own interests and as is required by legal and regulatory obligations to which we are subject.
If we are required to retain your information longer than our standard retention periods, we will let you know (unless we are prevented by law from doing so.)
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
If you are a customer, we share your personal information with other data controllers where required by law, or to meet our regulatory requirements or as required by our insurers.
We may share personal information with:
Where we share information with other data controllers, they are responsible to you for their use of your information and compliance with the law.
You have rights concerning the information held under the GDPR, these rights are set out below. Should you wish to exercise these rights, please contact us using the contact details in Clause 11.
Upon request, Carty Property Advisor’s will provide a statement regarding the personal data held in relation to an individual or company.
The accuracy of personal information held is important to Carty Property Advisor’s. Please keep us informed if your personal information changes during the course of our engagement with you.
You have the right to request erasure of personal information. Unless there is a compelling reason for the data not to be erased (for example, Carty Property Advisor’s may be required to keep personal data to fulfil contractual or legal obligations. An example could be that data would be kept for compliance of Anti-money laundering regulations), personal data will be deleted upon request.
Under certain circumstances, you have the right to object to the processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Under certain circumstances, you have the right to request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Under certain circumstances, you have the right to request the transfer of your personal information to another party.
Under certain circumstances, you have the right to withdraw consent in the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we are required to continue to process your information in accordance with another lawful basis which has been notified to you.
Carty Property Advisor’s do not use any personal information for automated decision making or profiling.
Carty Property Advisor’s takes data security seriously. In order to protect client personal data from loss, misuse or unauthorised access or disclosure we have put in place methods to safeguard and secure information collected.
These steps include:
Carty Property Advisor’s internal ICT and Data Protection Policy includes a clear process for handing a personal data breach, should one occur.
Any data breaches that are discovered externally should be reported to the us immediately, using the contact details set out in Clause 11. Where appropriate, Carty Property Advisor’s will promptly notify any clients should any unauthorised access to their personal information have occurred.
Like many other websites Carty Property Advisor’s website uses cookies. Cookies are small pieces of information that are stored on your computer or mobile device when you visit a website. The cookies used are ‘1st party’ cookies – these do not track behaviour across a range of websites that could result in targeted advertising.
We use Google Analytics which sets cookies to help us accurately estimate the number of visitors to the website and what content is most popular. This helps to ensure that our website is responding to your needs in the best way possible.
By using and browsing Carty Property Advisor’s website, you consent to cookies being used in accordance with this Policy.
If you do not consent, you must turn off cookies or refrain from using the site. Most browsers allow you to turn off cookies. To do this, look at the ‘help’ menu on your browser. Switching off cookies should not noticeably restrict your use of the website.
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Should a client wish to make a complaint regarding personal information held, matters should be raised with us in the first instance using the details in Clause 11 below.
Should the response not be satisfactory, or if there are suspicions that Carty Property Advisor’s are not processing a client’s information in accordance with the law, complaints are to be made to the Data Protection Commissioners.
For further information about this Privacy Policy and/or the processing of your personal data, or to make a complaint, please email cartyproperty@carty.ie.