BPF Website Privacy Notice
The British Property Federation ("BPF", "we" and "us") is committed to protecting the privacy of those with whom we interact, and we recognise the need to respect and protect information that is collected or disclosed to us (called "Personal Information", explained below). If you are accessing this policy via www.scottishpropertyfederation.org.uk, "we", "our" and "us" means, in the remainder of this policy, the Scottish Property Federation ("SPF").
This Privacy Notice is intended to tell you how we use your Personal Information, and we've tried to explain what we do in enough detail to give you the information you need at a glance, with the option of following a link if you want to find out more. If you still can't find the information you need, you can email us at firstname.lastname@example.org.
This Privacy Notice applies to BPF websites and services that refer to or link to the Privacy Notice and will apply whether you access our services using a computer, mobile phone, tablet, TV, or other device.
Who are we?
We are the data controller of the Personal Information (explained below) that we collect about you. We have a current registration (number Z2804820) in the Data Protection Register and we have appointed a Data Protection Manager who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the Data Protection Manager using the details set out below.
Full contact details
British Property Federation
Title: Data Protection Manager
Email address: email@example.com
St Albans House
1. What is Personal Information and what Personal Information does BPF collect about you?
For the purposes of this Privacy Notice "Personal Information" consists of any information that relates to you and/or information from which you can be identified, directly or indirectly. For example, information which identifies you may consist of your name, address, telephone number, photographs, location data, an online identifier (e.g. cookies identifiers and your IP address) or to one or more factors specific to your physical, economic, cultural or social identity.
We may collect use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:
• Identity and Contact Data includes first name, last name, company, position, address (whether business or individual), email address, telephone number and photograph.
• Payment Data includes your payment details such as credit or debit card.
• Technical and Usage Data includes internet protocol (IP) addresses, the type of browser used while visiting our website and the numbers of users who visit our website, usage session dates and duration, page views, and how you use our website.
2. How is your Personal Information collected?
BPF collects information when a user visits our website, when a customer becomes a member or purchases our services, and when a customer contacts us whether by the telephone, email or post. We use different methods to collect data from and about you including:
A. Personal Information you provide directly. You may give us your Identity and Contact Data by corresponding with us by email, phone or otherwise. This includes Personal Information that you provide when you:
B. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies and other similar technologies. Please see section 9 below.
C. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
3. How do we use your information?
We may use the Personal Information that we collect for the following purposes:
I. Deliver our Membership Package, and our other Services - as well as to administer systems and accounts;
II. Analysis Purposes - for assessment and analysis of the real estate market, customers, and other services;
III. Statistical Purposes – for research, statistical and behavioral analysis;
IV. Membership and Website Improvement – to enhance our membership and services, to ensure content from our website is presented in the most effective manner for you and your computer, to enhance the user experience, and to develop new services;
V. Customer Support Services - to provide customer support services;
VI. Business Purposes - for business monitoring and internal record keeping including maintaining our accounts, complying with good practice and for other administrative, operational and security reasons;
VII. Legal Obligations - to comply with our legal and regulatory obligations; and
VIII. Updates - to communicate with you, including communicating with you about your transactions with us, giving you important information about your membership, sending you notices about any material changes to our Privacy Notice, and, where permitted by you and applicable laws, marketing, sending you offers and promotions for our services.
The law allows us to use the Personal Information as set out above on the basis that the processing is necessary for the performance of a contract with you, or we are acting in our "legitimate interests" in the promotion and efficient running of our business.
When you become a member of our organisation, purchase any of our services, request information on our website or otherwise communicate with us, we may use your Identity and Contact Data to send you marketing-related correspondence by email related to our services.
When we process your Personal Information for marketing purposes, we do so on the basis that it is in our legitimate interests to do so, in promoting our organisation and to personalise and to target more effectively our marketing communications to ensure, to the extent possible, that any marketing-related correspondence is relevant to you
If you are currently receiving regular mailings from the BPF or SPF and would like this to stop, you can opt out and ask for your information to be removed from our database. To opt out of receiving marketing-related correspondence from BPF, please click "Unsubscribe" from any marketing or promotional email you receive from us. This will ensure that we will not send you regular mailings of that sort again unless you opt back in, but we will still have your email information.
Gathering insight from members strengthens the BPF’s ability to represent and promote the real estate industry among government and regulators.
4. To whom do we disclose your information?
We will only use your Personal Information for our internal business purposes, some of which are mentioned above. We may disclose your information to the following entities:
We may disclose your Personal Information to the SPF in order to provide you with full access to our services.
We run events with our partners, and may share your Personal Information with such partners for event management purposes if you wish to attend an event.
III. Service Providers
We use third party service providers to help us to administer certain activities and services on our behalf, such as providing our website, providing payroll services, and analysing usage of our Services. We may share Personal Information about you with such third party service providers solely for the purpose of enabling them to perform services on our behalf and they will operate only in accordance with our instructions. Here are examples of third-party service providers we use:
a. IT and Software Providers – we use IT and software providers to provide our website and other IT services. We currently use Utilize and Tincan.
b. Market research providers– We currently work with Grosvenor and Ipsos Mori to provide sentiment analysis of BPF members. The purpose is to strengthen the BPF’s ability to represent and promote the real estate industry among government and regulators.
c. Payment processor – if you wish to make a booking for one of our events with a credit card, we use Worldpay to process your payment. All credit card details are immediately destroyed following payment.
d. CRM provider – we use Iris' client relationship manager to assist us in developing our relationship with you.
e. MailChimp – we use MailChimp to assist us in sending you our marketing communications.
f. Analytics Service Providers – analytics providers are used to assist us in understanding the usage of our website and other services and to enable us to improve our services. The analytics provider we currently use is Google Analytics and ShareThis. For further information see section 10 below.
IV. Third parties when required by Law or to Protect our Services
We will disclose your Personal Information to comply with applicable law or respond to valid legal process, including from our regulators, law enforcement or other government agencies; to protect our customers (e.g. to prevent spam or attempts to defraud users of our services); to operate and maintain the security of our website (e.g. to prevent or stop an attack on our systems or networks); or to protect the rights or property of BPF, including enforcing any terms or agreements governing the use of our services.
V. Other Parties in Connection with Corporate Transactions
We may disclose your Personal Information to a third party in the event that all or substantially all of our business or assets are or are intended to be sold or otherwise assigned to another entity.
VI. Other Parties At Your Direction
We may share Personal Information about you with third parties when you request such sharing.
5. What do we do to keep your information secure?
We have put in place appropriate physical and technical measures to safeguard the Personal Information that we collect in connection with our services. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality. However, please note that although we take appropriate steps to protect your Personal Information, no website, device, online application or transmission of data, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your Personal Information.
International Transfer of Data
The Personal Information that we collect from you may be stored and processed in your region, or transferred to, stored at or otherwise processed outside the European Economic Area ("EEA"), including but not limited to the United States of America (where, Inc, and MailChimp are based) or in any other country where BPF's service providers maintain facilities.
By using or participating in any Service and/or providing us with your Personal Information, you acknowledge that we will collect, transfer, store and process your information outside the EEA. We will take all steps reasonably necessary to ensure that your Personal Information is kept secure and treated in accordance with this Privacy Notice and the requirements of applicable law wherever the data is located.
Where we transfer your Personal Information outside the EEA to other third parties, we will ensure that appropriate transfer agreements and mechanisms, such as the EU Standard Contractual Clauses, are in place to help ensure that our third party service providers provide an adequate level of protection to your Personal Information. Inc and MailChimp are certified under the EU/US Privacy Shield, which ensures adequate protection is provided to your personal data. We will only transfer your Personal Information outside the EEA in accordance with applicable laws or where you have given us your consent to do so.
6. Data Retention – How long we will store/keep your Personal Information
BPF retains Personal Information for as long as necessary to fulfil the purposes for which your Personal Information has been collected as outlined in this Privacy Notice unless a longer retention period is required by law. When your Personal Information is no longer required for the purpose it was collected or as required by applicable law, it will be deleted and/or returned to you in accordance with applicable law.
We have a document retention schedule that sets out how long we keep different types of information. Please contact firstname.lastname@example.org if you would like further information.
7. Accessing your Personal Information and other rights you have
BPF will collect, store and process your Personal Information in accordance with your rights under any applicable data protection laws. Under certain circumstances, you have the following rights in relation to your Personal Information:
I. Subject Access - you have the right to request details of the Personal Information which we hold about you and copies of such Personal Information.
II. Right to Withdraw Consent – where you have consented to our processing of your Personal Information, you have the right to withdraw such consent at any time. In the event you wish to withdraw your consent to processing, please contact us using the details provided in section 12.
III. Data Portability – you may, in certain circumstances, request us to port (i.e. transmit) your Personal Information directly to another organisation.
IV. Rectification – we want to ensure that the Personal Information about you that we hold is accurate and up to date. If you think that any information we have about you is incorrect or incomplete, please let us know. To the extent required by applicable laws, we will rectify or update any incorrect or inaccurate Personal Information about you.
V. Erasure ('right to be forgotten') - you have the right to have your Personal Information 'erased' in certain specified situations.
VI. Restriction of processing – you have the right in certain specified situations to require us to stop processing your Personal Information.
VII. Object to processing – You have the right to object to specific types of processing of your Personal Information, such as, where we are processing your Personal Information for the purposes of direct marketing.
VIII. Prevent automated decision-taking – in certain circumstances, you have the right not to be subject to decision being taken solely on the basis of automated processing.
Enforcing your rights
If you wish to enforce any of your rights under applicable data protection laws, then please see section 11 below. We will respond to your request without undue delay and by no later than one month from receipt of any such request, unless a longer period is permitted by applicable data protection laws, and we may charge a reasonable fee for dealing with your request which we will notify to you. Please note that we will only charge a fee where we are permitted to do so by applicable data protection laws.
If you are concerned that we have not complied with your legal rights under applicable data protection laws, you may contact the Information Commissioner's Office (www.ico.gov.uk) which is the data protection regulator in the UK which is where BPF is located. Alternatively, if you are based outside the UK, you may contact your local data protection supervisory authority.
8. Third-Party Links on Our Website
Our website may contain links to other third party websites that are not operated by BPF. These linked sites and applications are not under BPF's control and as such, we are not responsible for the privacy practices or the content of any linked websites and online applications. If you choose to use any third party websites, any Personal Information collected by the third party’s website will be controlled by the Privacy Notice of that third party. We strongly recommend that you take the time to review the privacy policies of any third parties to which you provide Personal Information. In particular, our partner events are not covered by this Privacy Notice. Please refer to the third-party organiser's privacy notice when booking a place at one of our partner events.
What are cookies?
Further information on cookies
10. Changes to this Privacy Notice
It also is important that you check back often for updates to the Privacy Notice, as we may change this Privacy Notice from time to time. The “Date last updated” legend at the bottom of this page states when the notice was last updated and any changes will become effective upon our posting of the revised Privacy Notice.
We will provide notice to you if these changes are material and, where required by applicable law, we will seek your consent. We will provide this notice by email or by posting notice of the changes on the BPF website or through any relevant Services.
11. Contact Us / Further Information
If you have any questions regarding the collection, processing, or use of your Personal Information or if you wish to correct, block, rectify, object, access, revoke your consent to any applicable aspect of this Privacy Notice or delete any of your Personal Information, please contact us:
I. By mail:
Data Protection Manager
The British Property Federation
St Albans House
II. By email: email@example.com
III. By telephone: 020 7802 0100 (Monday to Friday, 9.30am – 5.30pm)
Date last updated: 31 July 2018