Jump to section:
- IMPORTANT INFORMATION
- WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- HOW TO CONTACT US AND COMPLAINTS
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our website is generally intended for use by property professionals (including, for example but without limitation, CIE members and Industry Partners, search companies, estate agents, conveyancers, solicitors, and surveyors) (“property professionals”). Such property professionals will in turn be acting for and on behalf of their own customers and clients who may be individuals. Where you are such a property professional or a member of staff of a property professional, you will be responsible for how you use your clients’ and customers’ personal data and for providing them with information on how their personal data will be used. We are not responsible or liable for how property professionals use data relating to clients and the services provided by property professionals.
Who we are
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, email address or similar identifier, and title.
- Contact Data includes postal address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your email address, purchases, orders for membership invoicing, your preferences, downloading of material, feedback, and survey responses.
- Usage Data includes information about how you use our website and membership services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you or your clients or customers (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you with Membership or other services). In this case, we may have to cancel your membership or service you have with us, but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Apply to become a Member of CIE
- request marketing to be sent to you;
- complete a survey;
- submit an enquiry, give us feedback or contact us.
How we use your personal data
We will only use your personal data when the law allows us to. The types of lawful basis for processing personal data that we rely on are:
- Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
- Consent means agreement which must be freely given, specific, informed and be an unambiguous indication of your wishes by which you, by a statement or by a clear positive action, signify agreement to the processing of personal data relating to you.
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Type of data
|Lawful basis for processing including basis of legitimate interest
|To register you as a new member and maintain membership
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to provide services, updates and recover debts due to us)
|(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(c) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how members / others use our services)
|To enable you to complete a survey
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how members/others use our services, to develop them and support our members)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content to you and measure or understand the effectiveness of our advertising
(f) Marketing and Communications
|Necessary for our legitimate interests (to study how members/users of website use our services, to develop them, to support our members and to inform our marketing strategy)
|To improve the services we provide to members.
|Necessary for our legitimate interests (to study how members /others use our services, to develop them, to support our members and to inform our marketing strategy
|To use data analytics to improve our website, services, marketing, customer relationships and experiences
|Necessary for our legitimate interests (to define types of members for our services, to keep our website updated and relevant, to support our members and to inform our marketing strategy)
We may use your Identity, Contact, Technical, Transaction, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
We may use external marketing agents to help us with such marketing communications. The legal basis on which we process personal data for marketing purposes is our respective legitimate interest to develop and market products and services and grow business, or, because you have provided your consent for us to contract you.
You can ask us to stop sending you marketing communications at any time by contacting us (please see the ‘CONTACT US AND COMPLAINTS’ section) or, where relevant, by following the unsubscribe link in any marketing communication you receive from us. Where you opt out of receiving these marketing communications, this will not apply to personal data provided to us as a result of a product or service purchase or other transaction.
Change of purpose
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Internal Third Parties. Your personal data may be shared with members of CIE (who are based in the United Kingdom).
- External Third Parties such as service providers who provide IT and system administration services (such as hosting service providers, payment service providers, cloud based email and CRM system providers); professional advisors including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, legal, banking, accounting and insurance services; marketing and public relations agencies; or HM Revenue & Customs, regulators or their authorities based in the United Kingdom who require reporting of processing in certain activities.
Disclosures of your property data
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We will generally retain our members’ data for a period of twelve (12) months after membership has ended, to ensure that we are able to assist you should you have any questions or feedback in relation to our products or services or to protect, or to defend our legal rights, or for tax purposes.
We have processed your personal data to provide you with marketing communications with consent, we may contact you at least every 12 (twelve) months to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our marketing lists (but will be added to a “do not contact” list).
Where we have processed your data for any other reason (such as where you have contacted us with a question in connection with services or in relation to membership), we will retain your data for 12 (twelve) months.
In some circumstances, you can ask us to delete your data; please see “Your Legal Rights” for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us directly (please see the CONTACT US AND COMPLAINTS’ section).
- No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
- 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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
- Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
CONTACT US AND COMPLAINTS
Full name of legal entity: Conveyancing Information Executive Limited
Email address: email@example.com
Postal address: Alpha House, 4 Greek Street, Stockport, Cheshire, United Kingdom, SK3 8AB.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.