Privacy Policy – Moving Forward Sales and Lettings

Privacy Policy

Our contact details

Moving Forward
67a Upper St John Street,
Lichfield,
WS14 9DU.

0333 444 8421

privacy@wearemovingforward.co.uk

What type of information we have

Personal data means any information relating to a living individual who can be identified (directly or indirectly) in particular by reference to an identifier (e.g. name, NI number, employee number, email address, physical features). It can be factual (e.g. contact details or date of birth), an opinion about an individual’s actions or behaviour, or information that may otherwise impact that individual in a personal, or business capacity.

Data protection law divides personal data into two categories: ordinary personal data and special category data. Any personal data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health conditions, sexual life or sexual orientation, or biometric or genetic data that is used to identify an individual is known as special category data. (The rest is ordinary personal data).

Categories of personal information collected and processed by Moving Forward include, but are not limited, to:

  • Name
  • Gender
  • Residential status – including present and past addresses
  • Date of Birth
  • Marital status
  • Residential status
  • Dependent information
  • National Insurance number
  • Employment history – including current and former employer information
  • Copies of identification
  • Financial information – such as salary, bank details, mortgage statements, credit card details, load details
  • Contact information
  • Third party contact information
  • Online identifier information

Moving Forward may also collect and process special category and criminal offence data, including, but not limited to:

  • Health and medical history
  • Ethnicity and race
  • Criminal offences / convictions
  • Child data

How we get the information

Personal information we process about you may be directly provided to us by yourself in the course of you:

  • Using or applying for a Moving Forward product or service
  • Making a complaint or enquiry to ourselves
  • Subscribing or unsubscribing to marketing material
  • Participating in a promotion, offer or programme
  • Entering or attempting to enter into a business or employment relationship with ourselves
  • Call recordings or participation in shared online web conferencing facilities Information may also be provided to us indirectly by, including but not limited, to:
    • Next of kin / delegated authorities
    • Business associates
    • Employers
    • ‘Trusted Sources’:
      • Government / Land / Police registers
      • Credit / Default Agencies o Financial Institutes (Banks, Building Societies, Loan Agencies, Credit Card   companies)
      • Insurance Companies
      • Other Law firms
      • Health providers
      • Third party service affiliates or suppliers who have sought your consent

This information may be provided via the use of:

  • Forms and documentation
  • Branches
  • Online submission portals
  • Email, postal or telephone correspondence

We will always attempt to provide you with our Privacy Notice in regards to information received from other sources than yourself if it is not deemed to be disproportionate or prejudicial.

We, our service providers and partners collect certain information by using automated means, such as cookies, when you interact with our advertisements, mobile applications, or visit our websites, pages or other digital assets. The information we collect in this manner may include:

  • IP address
  • Browser type
  • Operating system
  • Referring URLs and information on actions taken or interaction with our digital assets.

Why we collect, use and hold your information

Generally, we will collect, use and hold your information for the purposes of:

  • Assessing applications for and providing Moving Forward products and services
  • Conducting business and developing relationships with Moving Forward and affiliates
  • Processing payments
  • Protecting against and preventing fraud, unauthorised transactions, money laundering, tax evasion, claims and other liabilities
  • Creating and managing any accounts or associated authentication criteria (such as ID logons and passwords) you may have with us
  • Communicating and marketing Moving Forward products, services, offers, programs and promotions
  • Compiling business directories, including business contact information
  • Operating, monitoring and improving our products, services, websites, mobile applications and other digital assets as well as developing new products and services
  • Processing job applications
  • Enforcing Moving Forward “Terms of Use” and other legal rights as may be required by applicable laws and regulations or requested by any judicial process or governmental agency having or claiming jurisdiction over Moving Forward or its affiliates.
  • Complying with industry standards and internal policies.
  • Processing complaints, enquiries and data subject rights requests.
  • For training, communication and awareness.
  • Confirming appointments and meetings.
  • Publishing of customer feedback and reviews.

What we do with the information

We do not sell or otherwise disclose personal information we collect about you, except as described in this Privacy Notice or as indicated via the consent process at the time the data is collected. We may share the information we collect, where applicable, with:

  • Landlords and landlord associates and sub processors
  • Vetted affiliates and partners.
  • Financial Institutions.
  • Insurance Companies.
  • Formally contracted service providers for:
  • Hosting Data centres, Infrastructure and Applications development and support,
  • Cloud Services
  • Helpdesk and Call Centres etc.
  • Councils, local authorities, and health and care providers
  • Water and other utility companies
  • Law firms and EPC providers
  • Credit agencies
  • Land Registry Office
  • Her Majesty’s Revenue and Customs (HMRC),
  • Relevant regulatory bodies and authorities

Moving Forward may also disclose personal information to other employees in the course of providing you with our services. Moving Forward does not permit these parties to use such information for any other purpose than to perform the services they have been instructed to provide by us.

We may also share information about you, if required legally, to prevent harm or financial / reputation loss, for investigation of suspected or actual fraudulent or illegal activities.

We contractually require service providers and processors to safeguard the privacy and security of personal information they process on our behalf in line with data protection obligations and authorise them to use or disclose the information only as necessary to perform services on our behalf and under our instruction or to comply with legal obligations and requirements.

On websites, features can be accessed where we partner with other entities that are not affiliated with Moving Forward. These include social networking and geo-location tools etc. and are operated by third parties who may use or share personal information in accordance with their own privacy policies. It is recommended that you review the third parties’ privacy notice if you use the relevant features.

In the event of a sale or transfer of our business or assets (wholly or partly) Moving Forward reserves the right to transfer your information to the acquirer. You can exercise your rights and gain clarification concerning the protection and processing of your information by the acquirer by contacting them directly.

How we store your information

We keep your personal information in line with our Data Retention & Destruction Policy. In certain circumstances we have a statutory obligation to keep your personal information for a set period of time, for example, financial information (normally 7 years) for financial auditing purposes. Information is always retained in line with its purpose of processing and only for as long as necessary usually, information is kept for 7 years after last contact with you. However, this period may be extended dependent upon any legal or contractual obligations Moving Forward may be required to comply with, as well as any overriding business legitimate interests.

Your data protection rights

Your rights and choices

Under Data Protection law and regulation, you have a number of rights. The applicability of these rights is dependent upon our purpose and lawful basis of processing, therefore not all of these rights may be available to you.

You can exercise your rights either verbally or in writing. However, should you make a request verbally we recommend that you follow this up in writing to provide a clear correspondence trail.

We have an obligation to respond within one month of receiving your request. Should we deem the request to be complex the response time can be extended by up to two months. Should this be required, you will be informed of the extended response date, alongside an explanation, within the original one-month time frame.

Should we feel the need to verify your identity, identification will be requested within the one-month time frame and only limited to what is necessary for confirmation. Once we are satisfied, we will then process your request.

Should we refuse to comply with a request we will inform you of this within the one month time frame and provide an explanation outlining our justification, our internal complaints procedure and your right to complain to a supervisory authority and to enforce your rights through a judicial remedy.

Your right of access:

You have the right to request and receive copies of the personal information we hold that directly relates to you. This right is always applicable; however, due to exemptions within the legislation you may not always receive all the information we process. If this is applicable an explanation will be provided to you within our response.

If you are requesting information on behalf of someone else, we require you to provide proof that you are entitled to act on behalf of the data subject and will require written confirmation of this authority. If we are not satisfied you have the right to act as a delegated authority, we reserve the right to refuse the request.

Your right to rectification:

You have the right to request that inaccurate information is rectified, and incomplete information completed. Please provide an overview of the information you wish to be rectified / completed. Upon receipt of your request an investigation will be undertaken and a response determining our decision will be provided to. Please be aware that we

may need to take certain steps to verify the accuracy of the new information before the change can be applied.

Your right to erasure

You have the right to request your personal information is deleted by us; however, this only applies in certain circumstances. To exercise this right, please provide us with an overview of the information you would like deleted and your reasoning. Upon receipt this matter will be investigated and a response determining our decision provided to you.

In certain circumstances we may be unable to physically delete your data, however, we may put in place steps to ensure the data is ‘put beyond use’, anonymised or pseudonymised and you will be notified of this.

Your right to restrict processing:

You have the right to request we restrict the processing of your personal information; however, this only applies in certain circumstances. To exercise this right please provide us with an overview of the information you would like restricted and your reasoning for this request. Upon receipt this matter will be investigated, and our decision provided to you. Processing of your personal data will not resume without you being notified that the restriction is to be lifted.


Your right to object

You have the right to object to us processing your data whereby we are processing your information in the public interest or for our legitimate interests. To exercise this right, please provide us with an overview of the information you are objecting to and your reasoning for this. Upon receipt, this matter will be investigated, and our decision provided to you.

You also have an absolute right to object to us using your data for direct marketing. You can exercise this right by:

Cookies policy

Moving Forward operate a Cookie Policy. Some of our service providers and partners may collect information about your online activities over time and across third-party websites to customise and target our adverts.

You can opt out collection of personal information by automated means e.g. when visiting our website or visit third-party websites and interact with our adverts, by using the Cookie Consent tool displayed in the website (the browser you use may provide options on how to opt out of receiving certain types of cookies). However, without cookies you may not be able to use all of the website features and/or online services.

Your right to data portability:

You have the right to request us to transfer the information you have provided to us to another organisation or to you directly. This right only applies if we are processing information based on your consent or in regard to a contract and the processing is automated. Requests to exercise this right will be reviewed and a decision provided to you.

Your right to automated decision making and profiling

If automated decision making and profiling have been used, you have a right to obtain human intervention and challenge a decision made as a result of this process. Requests to exercise this right will be investigated and a decision provided to you.

Withdrawal of consent:

If we obtain your information by consent you have the right to withdraw your consent at any time. However, the right to consent removal may be limited in some circumstances by local law requirements. Should this apply you will be informed appropriately.

How to complain

You can exercise your rights, raise a query or concern, report a breach or make a complaint by contacting the applicable business unit or:

Emailing – privacy@wearemovingforward.co.uk

writing to –

67a Upper St. John Street, Lichfield, WS14 9DU

To assist us in responding to your request in a timely and satisfactory manner please provide as much detail as possible during your contact with us.

Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:

(a) Your consent. You are able to remove your consent at any time. You can do this by contacting:

– privacy@wearemovingforward.co.uk

(b) We have a contractual obligation.

(c) We have a legal obligation.

(d) We have a vital interest.

(e) We need it to perform a public task.

(f) We have a legitimate interest.

What we do with the information we have

We use the information that you have given us in order to provide services, protection against fraud, money laundering, tax evasion etc, process payments, complying with industry standards, enforcing ‘terms of use’, training and improvement, confirming appointments, feedback and creating / managing accounts.

We may share this information with affiliated sites and external partners.

How we store your information

We keep personal information such as names, contact details for a maximum of 7 years and / or until it is no longer required for example after a completion of a transaction. We will then dispose your information by closing files down and erasing them from the system.

Your data protection rights


Under data protection law, you have rights including:

Your right of access
You have the right to ask us for copies of your personal information.

Your right to rectification
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure
You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing
You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to object to processing
You have the right to object to the processing of your personal data in certain circumstances.

Your right to data portability
You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us if you wish to make a request.

How to complain

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:            

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113