08 May 2019

Privacy Notice

How we use your information

This privacy notice tells you what to expect when Harness Property Intelligence Ltd ("Us", "We", "HARNESS") collects personal information. It applies to information we collect about:

  • visitors to our websites;
  • people who use our services, eg who subscribe to one of our newsletters or request information from us;
  • job applicants and our current and former employees.

It also has information about how we may utilise Internet (including Social Media) advertising.

The data we use 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, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes home address, email addresses and telephone numbers.
  • 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.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

How is your personal data collected?

We use different methods to collect data from and about you including:

FROM YOU DIRECTLY:

  • Filling in details whilst creating a property listing enquiry or creating an account on our websites
  • Email
  • Applying for a job with Us

INDIRECTLY FROM THIRD PARTIES OR PUBLICLY AVAILABLE:

  • Candidate referrals from UK based recruitment agencies
  • Where your personal information is contained on publicly available websites for example

NB: We do not collect personal data from any automated technologies

Visitors to our site

When someone visits www.harnessproperty.com we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

COOKIES

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies are used by Us as an essential part of our website registration or login process.

All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular areas or functions of our website.

For more information on cookies you can read the guidance at All About Cookies (opens in a new tab).

We do not store any personal data in cookies.

TYPES OF COOKIE USED

When someone visits www.harnessproperty.com we store the following cookies:

| Provider | Type| Purpose|
|---|---|---|
| harnessproperty.com | Session | <ul><li>Retain the search filters you have used and which page of results you are looking at</li><li>Store which listings you have shortlisted</li><li>Store your current login status</li></ul> |
| harnessproperty.com | Permanent | <li>That you have dismissed the cookie warning banner </li> |
| Google Analytics | Session & Permanent | <ul><li>We use Google Analytics to aggregate anonymous statistics about visitors to our website and the pages.</li><li>We use Google Analytics to monitor the performance of paid Google advertising we subscribe to.</li><li>We use Google Analytics to enable retargeting of Google adverts.</li><li>We do not provide Google with any of your Personal Data.</li><li>We do not receive any of your Personal Data or Google settings from Google.</li></ul> Please refer to Google's information: [https://policies.google.com/technologies/partner-sites](https://policies.google.com/technologies/partner-sites) (opens in a new tab)|

Search Engine

Our website search engine is powered by our own databases and algorithms. All data is transmitted over an encrypted communication protocol.

Search queries, results and search performance statistics are stored so we can build anonymised, aggregated statistics products and to monitor the performance of our website. We do not link any personal data to these records without your explicit consent.

SECURITY AND PERFORMANCE

We are committed to maintaining a secure and performant website. We log and process the IP addresses of visitors to enable us to understand performance and trends. We delete all logs after 14 days.

We gather information about your computer for our services, and to provide statistical information regarding the use of our website. This statistical data does not identify any personal details whatsoever. It is used by us to analyse how visitors interact with our website so that we can continue to develop and improve our services.

People who call us or an agent partner

When searching our website you can request to contact Us or one of our commercial partners by telephone. We provide you with a telephone number that has been provided by a third party provider. When you call a telephone number provided by our website we collect Calling Line Identification (CLI) information. We use this information to help improve our efficiency and to monitor the performance of our commercial partner. The third-party provider may also store CLI information for the purpose of monitoring performance, regulatory compliance and for billing.

When you call a telephone number provided by our website for one of our commercial partners you will be connected directly to the stated commercial partner. You will not be connected to Us and the commercial partner will not know any of your personal information unless you choose to disclose it.

People who make an online enquiry

When you submit an enquiry form provided by our website we store the information provided by you in our database. We will not ask for personal data or information unless it is relevant to the purpose. We store your personal data securely to help improve our efficiency and to monitor the performance of any commercial partner. If you are enquiring about one (or many) commercial property/ies your personal data and relevant information about your property search criteria are forwarded to the stated commercial partner. The commercial partner is not permitted to use your personal data for any purposes other than to fulfil your specific enquiry requirements.

We delete all personal data obtained from a property listing enquiry 3 months after the last communication or website interaction from you.

People who email us

We use Transport Layer Security (TLS) to encrypt and protect email traffic. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.

We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

Business Contacts

We retain the personal data of commercial partner contacts and prospective commercial partner contacts in our Customer Relationship Management tool. All personal data is securely stored and only made available to our business development and executive management team.

PROSPECTIVE CLIENT RELATIONSHIPS

Where a direct personal relationship is held between one of our employees or consultants and a data subject (eg you), we will not store any personal data until contact has been made and consent to explore a commercial relationship has been given by the data subject.

Where we obtain personal data from prospective client websites or publicly available reputable sources we will store the personal data within our CRM product.

WHERE A COMMERCIAL RELATIONSHIP IS NOT AGREED

Personal data related to companies who have not agreed to be recorded will be deleted within 3 months.

WHERE A COMMERCIAL RELATIONSHIP IS AGREED

Personal data related to companies where all parties agree to a commercial relationship may be retained for up to 2 years after the relationship ends. This data will be reviewed within 3 months of the relationship ending to ensure we only retain personal data for role-based contacts necessary for Us to satisfy UK business accounting requirements.

LAWFUL BASIS

In processing your personal data for the purposes described above we rely on the lawful basis of its being necessary for our legitimate interests (to progress your commercial property enquiries, to define types of customers and for our business administration). 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).

DISCLOSURES OF PERSONAL DATA

Apart from the third parties identified above, we may share your personal data with the following third parties below for the purposes described in this privacy notice:

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
  • Professional advisers, including lawyers, retained HR consultants, auditors (other)

We will not transfer any of your information outside of the European Economic Area.

Job applicants, current and former employees and contractors

WHAT WILL WE DO WITH THE INFORMATION YOU PROVIDE TO US?

All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.

We will not share any of the information you provide with any third parties for marketing purposes or store or transfer any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.

We retain the services of a Professional Human Resources consultancy, based in London UK. We share our employee database with that firm under a Data Processing Agreement. The personal data is used to ensure We are meeting all employee/employment obligations.

EMPLOYEE POLICIES

Our Company Handbook contains a range of policy documents including those relating to Personal Data. These document are available to all our employees and are reviewed periodically. If you are applying for a role with us you may ask for copies of any of our policy documents.

WHAT INFORMATION DO WE ASK FOR, AND WHY?

We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.

If you are applying for a job, the information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t.

RECRUITMENT AGENCIES

We often work with third party recruitment/employment agencies. Your personal data may be sent to Us by one of these agencies. We will respect any such data in the same way as if it were sent to us directly by you.

THIRD PARTY HR SYSTEMS

We use a third party HR management service called CharlieHR (https://www.charliehr.com/hr-online/security/data-protection opens in a new tab). If you are offered and accept a role with us, whether as an employee or as a contractor, we will require you to enter relevant personal data onto the CharlieHR platform.

HOW LONG IS THE INFORMATION RETAINED FOR?

If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any security checks and references.

If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the campaign.

Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the campaign.

Equal opportunities information is retained for 6 months following the closure of the campaign whether you are successful or not.

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.

Your Rights

Under the General Data Protection Regulation (effective from May 25, 2018) you have rights as an individual which you can exercise in relation to the information we hold about you. You can read more about these rights here - https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/ (opens in a new tab).

The GDPR provides the following rights for individuals:

  1. The right to be informed (opens in a new tab)
  2. The right of access (opens in a new tab)
  3. The right to rectification (opens in a new tab)
  4. The right to erasure (opens in a new tab)
  5. The right to restrict processing (opens in a new tab)
  6. The right to data portability (opens in a new tab)
  7. The right to object (opens in a new tab)
  8. Rights in relation to automated decision making and profiling. (opens in a new tab)
  9. The right to withdraw consent

We respect all of your rights and will respond to all reasonable enquiries or requests without delay, or, at the latest, within one month of receipt.

You also 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 opens in a new tab). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Links to other websites

This privacy notice does not cover the links within this site linking to other websites. We do not control these third party websites and therefore we encourage you to read the privacy statements on the other websites you visit.

Changes to this Privacy Policy

We keep our privacy notice under regular review. This privacy notice was last updated on 14th August 2018 .

Contact Us

We welcome any queries, comments or requests you may have regarding this policy please do not hesitate to contact us at governance@harnessproperty.com

If you would prefer to write to us then our contact address is:

Harness Property Intelligence Ltd. c/o Mercer & Hole 21 Lombard Street London EC3V 9AH