Privacy Policy
This policy describes what we do with personal information we collect from you and the ways in which we may collect that information.
For the purpose of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, the data controller is Swihart-Rees Property Lettings and Management, 13 Upper William Street, Llanelli, SA15 1SL.
Data Protection Officer
Our Data Protection Officer can be contacted at info@swihartrees.co.uk.
Use of Cookies
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How We Collect Information
We may collect information from you through your use of our website, when you request information from us or engage our services.
Sources of Personal Data
We may collect personal data about you from:
- You directly.
- Employers or clients when you apply for a role or are considered for an opportunity.
- Referees, where relevant and permitted.
- Publicly available sources, for example professional networking sites, business websites, and public records.
- Credit reference agencies (CRAs), where required for consumer credit, identity, or affordability checks.
- Third-party service providers used to support recruitment, screening, and compliance processes.
Categories of Personal Data We Process
We may collect and process the following categories of personal data, as necessary to provide our services and meet our legal, contractual, and security obligations:
- Identity data – including name, date of birth, title, username, or other identifiers.
- Contact data – including postal address, email address, and telephone number.
- Account and access data – including user IDs, login details, access permissions, and authentication information.
- Professional or employment data – including job title, employer name, and business contact details.
- Financial and transactional data – including payment details, billing information, and transaction records, where applicable.
- Technical and usage data – including IP address, device information, browser type, operating system, access logs, and usage activity.
- Security and audit data – including system logs, monitoring records, access records, and incident-related information.
- Communications data – including correspondence, emails, and records of interactions with us.
- Compliance and risk data – including records required for regulatory, audit, or due diligence purposes.
Legal Basis for Processing Personal Data
Personal data is processed in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Depending on the activity, we rely on the following lawful bases:
- Performance of a contract – where processing is necessary to deliver services or meet contractual obligations, including obligations involving TransUnion.
- Legal obligation – where processing is required to comply with applicable laws, regulatory requirements, or statutory obligations.
- Legitimate interests – where processing is necessary for legitimate business purposes such as system security, fraud prevention, risk management, audit, and compliance, and where such interests do not override the rights and freedoms of individuals.
- Consent – where required by law, and where individuals have been provided with a clear choice and the ability to withdraw consent at any time.
Where legitimate interests are relied upon, appropriate assessments are conducted to ensure that the rights and freedoms of data subjects are protected.
Legitimate Interests
Our legitimate interests include operating our business, fulfilling contractual obligations, ensuring system and data security, preventing fraud, supporting audit and compliance activities, and protecting TransUnion data. These interests are balanced against the rights and freedoms of individuals, with appropriate safeguards in place.
Uses Made of the Information
What we use your personal information for:
- To provide and improve this website.
- To provide and improve our services to you and to our clients, including handling personal information of others on behalf of our clients.
- To provide you with the information and services that you request from us.
- To provide you with information about other services that are similar to those that you have already enquired about.
- To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
- To compile anonymous statistics, for example, website usage statistics.
- To market our services.
- To notify you about changes to our service.
- To manage our relationship with you.
- To fulfil our legal obligations.
- For other legitimate business purposes.
Recipients of Personal Data
We do not sell, rent, distribute or otherwise make personal information commercially available to any third party, except as described in this policy or with your prior permission.
We may share personal data with:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
- Business partners for the performance of any contract we enter into with them or you.
- Third parties who assist us in processing your information, as well as prospective employers or clients for the purpose of recruitment.
- Customers or business partners.
- Regulators or law enforcement bodies, where required.
- Professional advisers.
Where data is shared outside the UK, appropriate safeguards will apply.
International Data Transfers
We may transfer personal data to recipients or service providers located outside the UK and/or the European Economic Area (EEA).
Where such transfers take place, we ensure appropriate safeguards are in place to protect personal data in accordance with applicable data protection laws. These safeguards may include the use of approved standard contractual clauses, international data transfer agreements, or transfers to countries that have been recognised as providing an adequate level of data protection.
Where We Store Your Personal Data
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Data Retention
We keep personal data only for as long as necessary for its purpose and to meet legal or regulatory obligations. Data used for credit reference or affordability checks is retained only for as long as required and then securely deleted.
Protection of Your Information
We apply the highest standard of security when it comes to hosting and protecting information.
Legal Requirements
While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.
Your Rights
Under UK data protection law, you have the following rights in relation to your personal data:
- Right of access – You have the right to request a copy of the personal data we hold about you and information about how it is used.
- Right to rectification – You have the right to request that inaccurate or incomplete personal data is corrected.
- Right to erasure (“right to be forgotten”) – You have the right to request that we delete your personal data where there is no lawful reason for us to continue processing it.
- Right to restrict processing – You have the right to request that we limit how we use your personal data in certain circumstances.
- Right to data portability – You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that we transfer it to another organisation where technically feasible.
- Right to object – You have the right to object to the processing of your personal data where we rely on legitimate interests or where data is used for direct marketing.
You can exercise any of these rights by contacting us at Swihart-Rees, 13 Upper William Street, Llanelli, SA15 1SL or by emailing info@swihartrees.co.uk.
Right to Lodge a Complaint
You have the right to complain to the UK Information Commissioner’s Office (ICO) or another relevant data protection authority if you are dissatisfied with how we manage your personal data. The ICO can be contacted at ico.org.uk.
Provision of Personal Data
The provision of certain personal data is primarily contractual and, in some circumstances, required to meet legal and regulatory obligations. Personal data is required to:
- Enter into and perform contracts with customers, suppliers, or business partners.
- Process orders, manage accounts, and deliver goods and services.
- Verify identity and prevent fraud.
- Comply with applicable legal, regulatory, accounting, and tax obligations.
If you choose not to provide the personal data we request:
- We may be unable to enter into a contract with you.
- We may be unable to fulfil orders, supply goods, or provide services.
- We may be unable to conduct necessary verification, compliance, or fraud prevention checks.
- As a result, our services may be delayed, restricted, or declined.
Where personal data is requested for optional purposes, such as marketing communications, providing this data is not mandatory, and you may withdraw your consent at any time without affecting your ability to receive goods or services from us.
Automated Decision Making and Profiling
We may use automated systems and tools to support certain business processes, such as risk assessment, fraud prevention, affordability checks, identity verification, or record management. These tools may analyse personal data using predefined criteria or rules to generate indicators, scores, or recommendations. However, we do not make decisions that have a legal or similarly significant effect on individuals based solely on automated processing. Any such decisions are subject to meaningful human review.
The use of these tools may influence the speed or level of review applied to an application or request, but individuals will not be subject to automatic rejection or adverse decisions without human involvement.
Credit Reference and Affordability Checks
To help us assess applications, prevent fraud, and meet our legal and regulatory obligations, we may obtain information about you from credit reference agencies (CRAs). We obtain this information via Creditsafe, which uses its data partner TransUnion to supply consumer credit and identity data.
- Creditsafe Business Solutions Limited is authorised and regulated by the Financial Conduct Authority (FCA Firm Reference Number: 742313).
- TransUnion International UK Limited is authorised and regulated by the Financial Conduct Authority (FCA Firm Reference Number: 805757).
The information we receive may include data relating to your identity, credit commitments, payment history, and public record information. This data is used solely for legitimate business purposes, including creditworthiness assessment, identity verification, and fraud prevention, in accordance with applicable data protection laws.
Further information about how Creditsafe and TransUnion process your personal data can be found in their respective privacy notices:
- Creditsafe Privacy / Transparency Notice: Transparency Notice | Customers & Suppliers
- TransUnion CRAIN (Credit Reference Agency Information Notice): https://www.transunion.co.uk/legal/privacy-centre/pc-credit-reference
- TransUnion Bureau Privacy Notice: https://www.transunion.co.uk/legal/privacy-centre/pc-bureau
Links to Other Websites
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Changes to Our Privacy Policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@swihartrees.co.uk or by writing to Swihart-Rees, 13 Upper William Street, Llanelli, SA15 1SL.