Privacy and Your Personal Information | Portfolio Investments

Mission Statement

At The Leaders Romans Group, we are passionate about safeguarding the personal data of all stakeholders - our valued customers, dedicated employees, and trusted partners. We believe that data protection is not just a legal requirement, but a moral imperative. That's why we go above and beyond to implement the most robust and state-of-the-art security measures to protect all personal data entrusted to us. We are committed to compliance with all relevant laws and regulations and will only use personal data for lawful business purposes. We strive to ensure that the data we collect is accurate, complete, and up-to-date, and that it is kept safe from unauthorised access, loss or damage. Data protection is at the core of our values, and we believe everyone has a right to privacy.

Legislation

The Leaders Romans Group must look after your personal information by law. The main legislation that applies to protecting your information is:

• General Data Protection Regulations (UK) (GDPR UK)
• Data Protection Act 2018 (DPA)
• Human Rights Act 1998 (Article 8) (HRA)
• Privacy and Electronic Communications Regulations 2003 & 2011 (PECR)
• Money Laundering Regulations 2017
• Proceeds of Crime Act 2002
• The Data Protection, Privacy and Electronic Communications (Amendments etc.)(EU Exit) Regs 2019
• Telecommunications (Lawful Business Practice)(Interception of Communications) Regulations 2000
• Regulation of Investigatory Powers Act 2000 (RIPA)

This Privacy Notice applies to the use and processing of personal information collected under our trading names:

Alexander & Co, Alexander & Co Financial Services, And Co Group, Bode Insurance Solutions, Boyer, Dunlop Heywood, First For Auctions, GCS Estate Management, Gibbs Gillespie, Glide Property Management, Hose Rhodes Dickson, Island Holiday Homes, Leaders, Moginie James, Mortgage Scout, Peter Ball & Co, Portico, Relocate UK, Romans, Scott Fraser, SOWN, SPL Property Management, Stirling Ackroyd Group, Stirling Ackroyd Surveyors, Three Sixty Inventories, Three Sixty Space and The Acorn Group trading as Acorn Limited and its subsidiaries and associated businesses which includes: Acorn Estate Agents, Acorn Estate Management, Acorn Land & Commercial, Acorn Property Management, John Payne Estate Agents, Langford Russell Estate Agents, MAP Surveyors, Start Financial Services, Start Inventory Services, Start Lease Extensions, Unique.

The Leaders Romans Group Limited is the overall Data Controller and we have a legal duty to protect any information we collect from you. The phrases ‘us’, ‘we’ or ‘our’ will mean those businesses listed above which form the Leaders Romans Group Limited.

Our statutory Data Protection Officer is Zara Harrington. She can be contacted by email at dataprotection@lrg.co.uk or in writing at Crowthorne House, Nine Mile Ride, Wokingham, RG40 3GZ.

This Privacy Notice covers use of personal information as defined in GDPR UK & the Data Protection Act 2018.

Personal data. This is information, or any combination of separate pieces of information, that could be used to identify you. This includes your name, address, contact details etc.

“Special category” personal data. This sensitive personal information is given more protection in law. For example, details of your health or nationality.
For more details of these definitions see below.

When you enquire or register for products and services provided by the Leaders Romans Group Limited we may collect personal information from a variety of sources.

The majority of the personal information we collect will have been provided by you during the course of your relationship with us either through face to face contact, by telephone, email or electronic communication such as messaging, on-line forms or emails.

However, we may also obtain your personal data from other sources including:

• information we collect when you visit our websites, please see our Cookies Policy here
• other Leaders Romans Group companies, for example our mortgage brokering service
• companies which support advertising services that promote our services including online property portals (such as Rightmove and Zoopla), social media and networking sites (such as Facebook and Twitter) and online advertising platforms
• information provided to us by other third parties, such as your solicitor
• other publicly available sources such as the Electoral Roll and Land Registry

We collect your personal information based on the service or services we are offering you. We will only collect the information needed. We will not sell your personal information to anyone. Some examples of information we may collect directly from you, can be found here:-

We may request additional information from you which is relevant to the provision of specific services. If we do this, we will always tell you why the information is needed.

If you ask us to provide you with life, critical illness, or landlord insurance and we may need to gather “special category” personal information, we treat this sensitive information in accordance with the additional protection it is given under the Data Protection Act 2018 and GDPR.

Information we collect when you visit our websites
We use cookies and other technologies to collect information when you visit our web sites, including when you make use of our online chat.

We may collect personal information in connection with your use of our website, such as:

• your name, email address, telephone number and property address when you register to arrange a viewing, register for property alerts, request a valuation, lettings appointment, book a mortgage appointment, book a holiday rental or submit an enquiry.
• data sent from your browser may include, the date, time and length of your visit, the site from which you have come (for example Google, Firefox etc.) and your IP address

Information obtained from third party online portals
Where you contact us via online portals such as Rightmove or Zoopla, we will use your contact details to enable us to communicate with you and offer the services you have enquired about.

Information obtained from third parties
Where we are required by law, or for legitimate business needs, we will obtain information about you from third parties, but only after we have your consent to do so. For example, the third parties we may need to contact include: credit reference agencies, employers, banks, solicitors, etc. in order to obtain references, verify your identity and confirm your income.

Criminal disclosures
Certain types of insurance may involve disclosure by you of information relating to historic or current criminal convictions or offences. When we process any criminal records checks we do so in accordance with The Data Protection Act 2018 (Schedule 1, Part 3, Paragraph 33) and Article 10 GDPR UK. We will only carry out such checks where they are necessary.

CCTV & Telephone Call recording
We currently have CCTV installed in some branches for the prevention and detection of crime and to protect our business assets. All our cameras are overt and visible. Appropriate signage is displayed if CCTV is installed. Please ask branch staff if you have any concerns. CCTV may also be installed in some block management properties. CCTV signs will always be displayed.

We may record incoming telephone calls at our call centre, property management centres or branches for training and monitoring purposes only. Acorn Group Companies may also record some outgoing calls. You will hear a notification to advise you the call may be recorded however, not all calls will be recorded. Any recordings made are kept for one month before being over-written. Acorn Group companies may keep recordings for 6 months before being over-written.

We will process the information you provide or we obtain from other sources to provide you with products and services and answer any questions you may have.

The following are examples of how we use the information we collect:

• To provide estate agency services, including marketing your property, valuing your property, arrange and carry out accompanied viewings, selling your property and helping you search for a new home
• To provide a full lettings service for tenants, prospective tenants and landlords
• To provide full property management and maintenance services
• To provide holiday rental booking services, such as marketing your property, holiday reservations
• To advise on financial products, such as mortgages, insurance and protection products
• To provide property auction services
• To carry out regulatory checks to prevent fraud, unauthorised transactions, money laundering, tax evasion etc.
• To register a tenant’s deposit with a deposit protection scheme
• To process payments of rent, and maintenance for you if a property is being let
• To arrange an energy performance certificate or home report/survey inspections for you
• To offer an inventory and check in/check out service for rented properties
• To liaise with utility companies and local authorities regarding property services
• To carry out tenant referencing and credit reference checks
• To carry out guarantor referencing and affordability checks
• To monitor and improve our products and services
• To enable you to take part in a prize draw, competition or complete a survey

Customer Surveys
We may invite you to participate in surveys from time to time to help us gather feedback on our products and services, to make improvements. We may use a third party company to carry out these surveys on our behalf.

Prize draws and Competitions.
We may from time to time use your personal data to enable you to take part in a prize draw or competition and to contact you if you win a prize.

If you are entered into a prize draw or competition, you will be provided with specific terms and conditions that will apply and these will include details about how to opt in or out.

We do not use a third party to administer our prize draws or competitions and all prize draws and competitions will be administered by the Leaders Romans Group. We will let you know if we do decide to use a third party at any time in the future.

Credit scoring & Automated Decisions
Some of the services provided by third parties may involve an automated decision or credit scoring to determine whether we are able to provide a service or product. You have a right to challenge an automated decision and ask for the issue to be considered by human intervention.

The Leaders Romans Group processes your personal information under any of the following lawful conditions:

Consent Article 6 (1)(a) GDPR - if we process information under consent we will seek your clear and affirmative consent before processing your data, for example, to receive marketing information of properties for sale or to let.

Performance of a contract Article 6 (1)(b) GDPR - this is where the collection and processing of your data is necessary for the performance of a contract to which you are a party.

Legal obligation Article 6 (1)(c) GDPR - where the collection and processing of your personal data is necessary for compliance with a legal obligation, for example, to comply with the Data Protection Act, verify your identity, for fraud and money laundering prevention.

Processing is necessary for the performance of a task carried out in the public interest Article 6 (1)(e) for example carrying out money laundering checks.

Legitimate interests Article 6 (1)(f) GDPR - some personal information is processed by the Leaders Romans Group as part of its legitimate interests which includes direct marketing, web analytics, sales and lettings.

The lawful basis for processing “special category” personal information
The Leaders Romans Group processes “special category” information only when it is necessary. The lawful basis we use to process your “special category” information is:

Explicit Consent Article 9 (2)(a) GDPR – is freely given, specific and unambiguous consent before the processing of your data. For example, your health information will be needed to process an application for critical illness insurance.

Data that has been made public Article 9 (2)(e)

Establishing, exercising or defending a legal claim Article 9 (2)(f) GDPR – for advice on underwriting, arranging or administering an insurance contract (Schedule 1 Part 2 of Data Protection Act 2018) or on the suspicion of money laundering in line with the Proceeds of Crime Act 2002 (Section 339ZB) You may want to inform us of your “special category” data voluntarily to enable us to offer you appropriate products or services. For example, you may have a health condition that means you are unable to climb stairs. We will record your needs/preferences without recording your medical/health conditions in most cases.

Withdrawing consent
You have the right to withdraw your consent at any time. Please contact the branch or office you have been dealing with.

Children’s privacy
We do not offer any products or services to children (defined as under the age of 16 in GDPR UK). In some circumstances, for example a mortgage application, we may be required by the mortgage provider to collect the names and dates of birth your dependent children or other adults who may reside with you.

We may share information within the Leaders Romans Group to provide you with an agreed product or service, for example planning advice or mortgage services or for any other purpose agreed by you.

If you have opted in to our scheme to plant a tree in your name, your name will be shared with GreentheUK who manages a number of tree planting projects around the UK.

Third Party service providers
Where we engage third party service providers to provide products (such as mortgages, home/contents insurance or utility services) or business services, (such as credit reference checks) we provide them with the minimum personal information needed to perform the service or provide the product we have requested. We ensure all third party service providers understand they are required to protect your information, and not to use it for any other purpose.

Please see below third party organisations we share your information with and why,:-

We are required to keep your information for as long as is reasonably necessary to fulfil our legal and regulatory obligations. We have a Retention and Destruction Schedule to ensure we comply with the relevant legislation when processing your information.

• For lettings we keep your information for 6 years + 1 after you have stopped using our service.
• For property sales we keep your information for 6 years + 1 year after the sale has been completed.
• For property auctions we keep your information for 8 years after the sale has been completed.
• For planning advice and design, we keep your information for 4 years.
• For financial records, we keep your information for 8 years if your application is successful.
• For insurance policies we keep your information for 6 years + 1 year after the policy expiry date.
• For mortgages and records, we keep your information for 30 years.
• For general enquiries and marketing, we will keep your information for 2 years.
• For block management we will keep your information for 7 years + 1 after you have stopped using our service.
• Any copies of ID documents needed to verify your identity will be kept on file for anti-money laundering for 5 years. For tenancy reference checks we will keep your information for 1 year.

Anonymised information on properties and geographical areas may be kept for longer to assist us with property market forecasting and trends. Anonymised information is not subject to privacy legislation or the Data Protection Act 2018 and may be kept for as long as it is needed.

We may use your personal information for direct marketing purposes to contact you about our products and services available throughout the Leaders Romans Group of companies which we believe may be of interest to you. More details can be found in our Direct Marketing Policy - CLICK HERE.

We will only send you promotional emails, mail, text messages or contact you by telephone, if you agree to each method of communication. You can stop receiving promotional mail, text messages or telephone calls by contacting your local branch.

If you would like to unsubscribe from our email service, please contact unsubscribe@lrg.co.uk. We aim to stop emails within 3 working days, but this may be extended to 10 working days over public holidays and to cover staff absence within the Data Protection Team.

Where you contact us via our website, in branch, by phone, or via online portals such Rightmove or Zoopla for help searching for a property to buy or rent, we will use the details you have supplied to us to provide you with property details by email. You can choose to unsubscribe at any time by contacting unsubscribe@lrg.co.uk.

You have a number of rights concerning the personal information we process about you. You have the right to:

• ask us for access to a copy of your personal information we hold about you. This is called a data subject access request. We may ask you to provide ID to verify your identity.
• ask us to correct your personal information if it is inaccurate. We may ask you to provide confirmation to ensure the information we hold is accurate.
• ask us to delete your personal information. We are unable to delete your information if the law requires us to keep it for a statutory period or there is a lawful reason we must keep the information. We will always investigate any request and advise you, if we are unable to erase your data.
• ask us to transfer your data if your information is processed by automated means.
• withdraw your consent to use your personal information. Where you have provided consent for our processing of your personal data, you may withdraw that consent at any time by simply contacting the branch or team you have been speaking to.
• ask us to restrict the use of your personal data, including direct marketing.
• object to our use of your personal data for our legitimate business interests. You have an absolute right to object to our use of your data for direct marketing.
• object to an automated decision.

Your right of access (known as a Subject Access Request)
If you wish to make a request for access to a copy of your personal data (ie information we hold specifically about you), or to exercise any of your other rights, please write to your local branch in the first instance. You will need to provide sufficient details to be able to locate the information you need. We may also need to verify your identity.

Further information on the request process and a subject access request form is available from dataprotection@lrg.co.uk

If you have registered on our Sales, Tenancy or Landlord Portals, in some cases it will be quicker to log in to your account to access the information. For example, if you want a copy of your tenancy documents, Landlord Terms of Business Agreement or rent statements.

Exemptions within the legislation could mean that you may not receive all the information we process. If this is applicable an explanation will be provided to you within our response.

Information relating to a service complaint will not be within the scope of a Subject Access Request. We have an internal complaints procedure for general service complaints and tenancy issues. Our Customer Service team can be contacted by emailing Customercare@lrg.co.uk and they will be better placed to help resolve your problem quickly.

If you would like a form to assist you with making your request, please email the data protection team at dataprotection@lrg.co.uk

We store your personal information on our electronic computer systems and in our paper filing systems. In accordance with the law we have strict security procedures to ensure that personal information is not damaged, destroyed or misused, and to prevent unauthorised access to your information. We have an internal breach reporting system to record all information security incidents and breaches. Serious data breaches are reported to the ICO within 72 hours, in accordance with the GDPR UK and the Data Protection Act 2018.
We have our own internal IT Department and Cyber Security Team to monitor our systems and networks. Our Cyber Security Team is solely focussed on protecting our data and works closely with our Data Protection Team to comply with Article 32 of UK GDPR.

The GDPR UK applies to the UK only. GDPR UK is based on the GDPR EU which applies all countries within the EU and European Economic Area (EEA). The EU and the UK have agreed adequacy status for the continued free-flow of personal data within the UK, EU and EEA. We will ensure that there is adequate security and comparable legislation in place before sending your information to other countries outside the EEA. In accordance with the Data Protection Act 2018 and UK GDPR, if we need to transfer data outside the EEA and the country it’s transferred to is not on an approved list for having adequate security controls in place, we will limit the amount of personal data we send. We will also impose contractual obligations (standard contractual clauses) in accordance with the EDPB (European Data Protection Board) (as approved by the ICO) from the recipients to ensure the security and confidentiality of your personal data to safeguard your information.

Whilst we always strive to keep our data in the UK and limit data transfers, we do use a cloud services provider for our customer data. Data back-ups are held outside the UK in accordance with GDPR for business continuity reasons. As with most global cloud service providers, the use of global back-up systems is common place.

Our websites and communications with you may provide links to other websites for your convenience and information. These websites operate independently from us and have their own privacy notices or policies, which we strongly suggest you review. Where linked websites are not owned by the Leaders Romans Group, we are not responsible for their compliance with the GDPR UK, the Data Protection Act 2018 or other privacy legislation.

If you wish to make a complaint about our compliance with UK GDPR or data protection, please write to our statutory Data Protection Officer Zara Harrington, at dataprotection@lrg.co.uk

We ask you to state in your complaint, the following information to enable an independent investigation:-

• Your name, contact email address and the address of the property (if regarding a tenancy, a sale, maintenance issue, mortgage or insurance policy)
• The business trading name (see below), branch location and names of any staff members
• A description of the complaint, time period or relevant dates, and
• Please attach details if your issue relates to a letter, property description, copy of email etc.

Once we have the information above, an investigation will be carried out by the Data Protection Team. We aim to respond to your complaint as soon as possible, but no later than 10 days from receipt. If you remain dissatisfied following a complaint to our Data Protection Officer, you can submit a complaint about data protection, privacy and data sharing issues directly to the Information Commissioner’s Office (ICO) at:

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

Website: https://ico.org.uk/ Email: casework@ico.org.uk Telephone: 0303 123 1113

• The ICO registration for The Leaders Romans Group Ltd is ZA781332.
• The Leaders Romans Group Limited is a registered company. Our registered office address is Crowthorne House, Nine Mile Ride, Wokingham, Berkshire RG40 3GZ. Our registered number is 09939099.
• Further information regarding the Leaders Romans Group can be found by visiting https://www.lrg.co.uk
• These companies have the following regulatory status:
  • Bode Insurance Solutions Limited is authorised and regulated by the Financial Conduct Authority
  • The Romans Group (UK) Limited is an introducer appointed representative of Bode Insurance Solutions Limited
  • Leaders Limited is an introducer appointed representative of Bode Insurance Solutions Limited
  • LRG Financial Services Limited is an appointed representative of Mortgage Advice Bureau Limited and Mortgage Advice Bureau (Derby) Limited
  • Mortgage Scout is an appointed representative of Mortgage Advice Bureau Limited and Mortgage Advice Bureau (Derby) Limited
  • Start Financial Services is an appointed representative of Mortgage Advice Bureau Limited and Mortgage Advice Bureau (Derby) Limited

We reserve the right to amend and update this Privacy Notice as required, therefore it is advisable you review this notice at regular intervals.

This Privacy Notice was last updated: 1 March 2024.