1. Who we are

Hurford Salvi Carr Limited (HSC) is the data controller responsible for personal information processed in connection with our estate agency, lettings, property management and related services. This notice applies to prospective, current and former customers, applicants and other individuals whose information we handle in the course of our business.

Our Data Protection Officer can be contacted at Hurford Salvi Carr Limited, 1 Britton Street, London EC1M 5NW, or by email at [email protected].

2. What information we collect

Depending on your dealings with us, we may collect and use:

Names, addresses, contact details, dates of birth and property requirements.

Identity documents and information used for identity verification, Right to Rent, anti-money laundering, financial sanctions, fraud prevention and other risk assessments.

Property details, ownership information, valuations, viewings, offers, negotiations, contracts, tenancy and management records.

Financial information, bank details, deposits, rent records, completed tenant referencing reports, credit-check results and employment or affordability information. We may hold bank statements supplied as evidence of address or funds.

Correspondence, enquiries, complaints, transaction history, marketing preferences and records of our dealings with you.

Website enquiries and any technical information collected through our website or its service providers, where applicable.

3. Where we obtain information

We obtain information directly from you; from landlords, tenants, sellers, purchasers, guarantors and others involved in property matters; and from service providers such as referencing, identity verification and professional advisers. We may also use property portals, HM Land Registry and other official or publicly available property records, including for property research and identifying potential business opportunities.

We make this notice available on our website and provide or draw attention to privacy information in other appropriate communications, subject to applicable legal requirements.

4. How and why we use information

We process personal information for the following purposes, relying on the lawful basis appropriate to the circumstances:

Our legitimate interests include providing and improving our services, protecting our business and customers, preventing fraud and financial crime, maintaining records, researching property opportunities and communicating about relevant services. We assess whether these interests are overridden by individuals’ rights and interests.

Certain information is necessary for us to provide services, assess applications or comply with legal duties. If it is not supplied, we may be unable to proceed with a service or transaction, or may need to inform the relevant landlord or other party.

5. Marketing and property prospecting

We may use relevant enquiry, transaction and property information, including information from public records, to identify potential opportunities and contact existing or prospective customers by post, telephone, email or other means where permitted. We comply with applicable direct marketing requirements, including the Privacy and Electronic Communications Regulations. You can object to direct marketing at any time by contacting us; we will stop using your information for that purpose.

6. Who we share information with

Where appropriate and lawful, we share relevant information with parties involved in property transactions and management, including landlords, tenants, sellers, purchasers, solicitors, brokers, contractors, managing agents and utility providers. We also use referencing, identity verification, financial, deposit protection, technology and professional service providers, and may disclose information to regulators, public authorities or courts where required or permitted by law.

As part of tenancy administration, we share relevant tenant and property information with Ethical Introductions Limited, trading as Just Move In, to facilitate change-of-occupancy notifications and related administration. This may include tenants’ names, contact details, property addresses and relevant tenancy dates. We rely on our legitimate interests in administering tenancies and facilitating change-of-occupancy arrangements, subject to the relevant balancing assessment. Tenants are informed of this arrangement in our pre-tenancy documentation and agreements. Just Move In may also offer optional utility switching and other home-moving services, subject to tenants’ instructions and applicable legal requirements. Hurford Salvi Carr may receive a commission or referral fee in connection with services arranged through Just Move In.

We may use approved software and AI-assisted tools for research, analysis, administration and correspondence, applying appropriate safeguards and human oversight. We do not sell personal information to third parties for their independent marketing purposes.

7. International transfers

Hurford Salvi Carr Limited operates exclusively within the United Kingdom. Some technology and service providers may nevertheless store, access or process personal information outside the UK. Where international transfers are subject to UK data protection legislation, we comply with the applicable legal requirements.

8. How long we keep information

We keep personal information only for as long as reasonably necessary for the purpose for which it is held, taking account of legal duties, business requirements and potential claims. We generally retain relevant records of completed property transactions, tenancies and property management arrangements for a period of approximately six years after completion or the end of the relevant relationship, where appropriate. Some information may be retained for shorter or longer periods depending on its purpose and applicable requirements.

Identity verification, Right to Rent and applicable anti-money laundering records may be subject to different statutory requirements. Referencing reports and supporting records are retained where necessary to document checks and manage tenancies or claims. We also retain relevant customer and enquiry records while there is a continuing lawful purpose, reviewing them periodically. Information may be kept longer where necessary for an ongoing complaint, investigation or legal claim.

9. Your rights

Subject to applicable legal conditions and exemptions, you may request access to your personal information, correction of inaccuracies, erasure, restriction of processing or data portability, and may object to processing based on legitimate interests. You have an unconditional right to object to processing for direct marketing. Where we rely on consent, you may withdraw it at any time without affecting earlier lawful processing.

We do not ordinarily make solely automated decisions having legal or similarly significant effects. HSC reviews tenant referencing information and makes recommendations; landlords make the final decision on tenancy applications.

Please contact our Data Protection Officer to exercise your rights. We may need to verify your identity. We normally respond within one month, subject to permitted extensions or other legal provisions. Requests are normally free, although the law permits fees or refusal in limited circumstances.

If you are dissatisfied with how we handle your information, you may complain to the Information Commissioner’s Office (ICO) at www.ico.org.uk.

10. Website cookies and security

Our website may use cookies and similar technologies to operate and support its services. Some technologies may require consent or other controls under applicable law. We will provide appropriate information and choices where required. You may also manage cookies through your browser settings, although some website functions may be affected.

We use appropriate technical and organisational safeguards to protect personal information, restrict access according to business needs and review our security arrangements. We assess personal data breaches and make notifications where required by law.

11. Changes to this notice

We may update this notice to reflect changes in our activities or legal requirements.