Privacy Policy

The Data Protection Act 2018 (DPA 2018) sets out the data protection framework in the UK and

incorporates the Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”) into the

national law. Its purpose is to protect the “rights and freedoms” of natural persons (living

individuals), and to ensure that personal data is not processed without their knowledge, and,

wherever possible, that it is processed with their consent.

Anchor Property’ Privacy Policy covers the way in which we use and disclose personal information that

customers, applicants, employees, and any other third parties may provide us with.

Personal information includes any information that identifies you personally, such as your name,

address, email address, internet protocol address or telephone number.

Under the DPA 2018 and the GDPR, Anchor Property, is defined as the Data Controller and therefore has

a legal duty to protect any information we collect from you. We use appropriate technologies to

safeguard your details and keep to strict security standards to prevent unauthorised access to it.

We recognise that your privacy is very important and so we want you to be confident with the way

Anchor Property and any of its subsidiaries, branches or representative offices and applicable 3rd

Parties, handle your personal information. We have outlined below how Anchor Property collects, uses,

discloses, and protects this information.

Anchor Property Group and its affiliates (Anchor Property), is a leading provider of property management

products and services, operating in over 1,200 locations across more than 50 brands, with over

11,000 employees within the UK and Ireland.

The Anchor Property head office can be located at:

Grosvenor House 

11, St Pauls Square,

Birmingham.

B3 1RB

Contact number:  0121 232 4631 

Further contact information for a specific business area or service can be located at:

https://www.anchorpropertywm.co.uk

This division is the UK’s largest land & new homes agency and provides

services to new buyers, national land opportunities and dedicated

subject matter expertise lawyers.

Property Auctions This division hosts national and regional auctions to sell residential,

commercial, industrial and agricultural properties as well as land to a

range of clients.

The Buy to Let Business Telephony only mortgage broker

Private Rented Sector

(PRS)

Anchor Property offers a single point of contact property 

management service.

Internal Support Services

Definitions used by the organisation (drawn from the GDPR)

Material scope (Article 2 GDPR) – the GDPR applies to the processing of personal data wholly or

partly by automated means (i.e. by computer) and to the processing other than by automated

means of personal data (i.e. paper records) that form part of a filing system or are intended to form

part of a filing system.

Territorial scope (Article 3 GDPR) – the GDPR applies to all controllers that are established in the EU

(European Union) who process the personal data of data subjects, in the context of that

establishment. It also applies to controllers outside of the EU that process personal data in order to

offer goods and services, or monitor the behaviour of data subjects who are resident in the EU.

Article 4 GDPR – Definitions

Establishment – the main establishment of the controller in the EU will be the place in which the

controller makes the main decisions as to the purpose and means of its data processing activities.

The main establishment of a processor in the EU will be its administrative centre. If a controller is 

based outside the EU, it will have to appoint a representative in the jurisdiction in which the

controller operates to act on behalf of the controller and deal with supervisory authorities.

Personal data – any information relating to an identified or identifiable natural person (‘data

subject’); an identifiable natural person is one who can be identified, directly or indirectly, in

particular by reference to an identifier such as a name, an identification number, location data, an

online identifier or to one or more factors specific to the physical, physiological, genetic, mental,

economic, cultural or social identity of that natural person.

Special categories of personal data – personal data revealing racial or ethnic origin, political

opinions, religious or philosophical beliefs, or trade-union membership, and the processing of

genetic data, biometric data for the purpose of uniquely identifying a natural person, data

concerning health or data concerning a natural person’s sex life or sexual orientation.

Data controller – the natural or legal person, public authority, agency or other body which, alone or

jointly with others, determines the purposes and means of the processing of personal data; where

the purposes and means of such processing are determined by Union or Member State law, the

controller or the specific criteria for its nomination may be provided for by Union or Member State

law.

Data subject – any living individual who is the subject of personal data held by an organisation.

Processing – any operation or set of operations which is performed on personal data or on sets of

personal data, whether or not by automated means, such as collection, recording, organisation,

structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission,

dissemination or otherwise making available, alignment or combination, restriction, erasure or

destruction.

Profiling – is any form of automated processing of personal data intended to evaluate certain

personal aspects relating to a natural person, or to analyse or predict that person’s performance at

work, economic situation, location, health, personal preferences, reliability, or behaviour. This

definition is linked to the right of the data subject to object to profiling and a right to be informed

about the existence of profiling, of measures based on profiling and the envisaged effects of profiling

on the individual.

Personal data breach – a breach of security leading to the accidental, or unlawful, destruction, loss,

alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise

processed. There is an obligation on the controller to report personal data breaches to the

supervisory authority and where the breach is likely to adversely affect the personal data or privacy

of the data subject.

Data subject consent – means any freely given, specific, informed and unambiguous indication of the

data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies

agreement to the processing of personal data.

Child – the GDPR defines a child as anyone under the age of 16 years old, although this may be

lowered to 13 by Member State law. The processing of personal data of a child is only lawful if

parental or custodian consent has been obtained. The controller shall make reasonable efforts to 

verify in such cases that consent is given or authorised by the holder of parental responsibility over

the child.

Third party – a natural or legal person, public authority, agency or body other than the data subject,

controller, processor and persons who, under the direct authority of the controller or processor, are

authorised to process personal data.

Filing system – any structured set of personal data which are accessible according to specific criteria,

whether centralised, decentralised or dispersed on a functional or geographical basis.

1. Types of Information Collected.

Personal data means any information relating to a living individual who can be identified (directly or

indirectly) in particular by reference to an identifier (e.g. name, NI number, employee number, email

address, physical features). It can be factual (e.g. contact details or date of birth), an opinion about

an individual’s actions or behaviour, or information that may otherwise impact that individual in a

personal, or business capacity.

Data protection law divides personal data into two categories: ordinary personal data and special

category data. Any personal data that reveals racial or ethnic origin, political opinions, religious or

philosophical beliefs, trade union membership, physical or mental health conditions, sexual life or

sexual orientation, or biometric or genetic data that is used to identify an individual is known as

special category data. (The rest is ordinary personal data).

Categories of personal information collected and processed by Anchor Property include, but are not

limited, to:

 Name

 Gender

 Residential status – including present and past addresses

 Date of Birth

 Marital status

 Residential status

 Dependent information

 National Insurance number

 Employment history – including current and former employer information

 Copies of identification

 Financial information – such as salary, bank details, mortgage statements, credit card details,

load details

 Contact information

 Third party contact information

 Online identifier information 

Anchor Property may also collect and process special category and criminal offence data, including, but

not limited to:

 Health and medical history

 Ethnicity and race

 Criminal offences / convictions

 Child data

1.1 Methods of Collection

Personal information we process about you may be directly provided to us by yourself in the course

of you:

 Using or applying for a Anchor Property product or service

 Making a complaint or enquiry to ourselves

 Subscribing or unsubscribing to marketing material

 Participating in a promotion, offer or programme

 Entering or attempting to enter into a business or employment relationship with ourselves

 Call recordings or participation in shared online web conferencing facilities

Information may also be provided to us indirectly by, including but not limited, to:

 Next of kin / delegated authorities

 Business associates

 Employers

 ‘Trusted Sources’:

o Government / Land / Police registers

o Credit / Default Agencies

o Financial Institutes (Banks, Building Societies, Loan Agencies, Credit Card companies)

o Insurance Companies

o Other Law firms

o Health providers

o Third party service affiliates or suppliers who have sought your consent

This information may be provided via the use of:

 Forms and documentation

 Branches

 Online submission portals

 Email, postal or telephone correspondence

We will always attempt to provide you with our Privacy Notice in regards to information received

from other sources than yourself if it is not deemed to be disproportionate or prejudicial.

We, our service providers and partners collect certain information by using automated means, such

as cookies, when you interact with our advertisements, mobile applications, or visit our websites,

pages or other digital assets. The information we collect in this manner may include:

 IP address

 Browser type

 Operating system

 Referring URLs and information on actions taken or interaction with our digital assets.

1.2 Purposes of Processing

Generally, we will collect, use and hold your information for the purposes of:

• Assessing applications for and providing Anchor Property products and services

• Conducting business and developing relationships with Anchor Property and affiliates

• Processing payments and transactions including: Accounting, Authorisation, Clearing,

Chargebacks, Auditing, Billing, Reconciliation, Collection, Credit Checks and related dispute

resolution activities

• Protecting against and preventing fraud, unauthorised transactions, money laundering, tax

evasion, claims and other liabilities

• Creating and managing any accounts or associated authentication criteria (such as ID logons

and passwords) you may have with Anchor Property

• Communicating and marketing Anchor Property products, services, offers, programs and

promotions

• Compiling business directories, including business contact information

• Operating, monitoring and improving our products, services, websites, mobile applications and

other digital assets as well as developing new products and services

• Processing job applications

• Enforcing Anchor Property “Terms of Use” and other legal rights as may be required by applicable

laws and regulations or requested by any judicial process or governmental agency having or

claiming jurisdiction over Anchor Property or its affiliates.

• Complying with industry standards and Anchor Property policies

• Processing complaints, enquiries and data subject rights requests

• For training, communication and awareness

• Confirming appointments and meetings 

• Publishing of customer feedback and reviews

1.3 Lawful basis of processing

The legal basis we use to process your personal data may differ for each processing activity.

Dependent upon the purpose for processing, as outlined above, and the business area processing

your data Anchor Property relies upon the following lawful basis of processing:

 Article 6 (1) (a) GDPR Consent: Where your permission and consent has been provided to

allow processing to be undertaken

 Article 6 (1) (b) GDPR Performance of a contract: where you have or will enter into a

contract with Anchor Property and we need to process your information as part of this contract

 Article 6 (1) (c) GDPR Compliance with a legal obligation: Where Anchor Property are bound by

further laws and regulations to process your information, affecting areas such as:

 Data Protection

 Crime and anti-money laundering

 Financial Services

 Property and estate management

 Employment

 Welfare and health and safety

• Article 6 (1) (e) GDPR Public interest: Information concerning relocations is processed in

accordance with public interest

 Article 6 (1) (f) GDPR Legitimate interests: These include:

 Fraud prevention and detection

 Risk assessment

 Due diligence

 Network and Information Security

 Suppression lists and managing communication opt-out requests

 Training, communication and awareness

 Profiling

 Direct marketing

 Monitoring and web analytics

 Cloud storage

 Acquisitions

 Management Information

 Compliance self-assessments

 Utility switches

 Property Management

Should we be provided with information defined as ‘special category’ our lawful basis for processing

is:

• Article 9 (2) (a) GDPR Explicit Consent:

Your permission has been granted and documented directly to us

• Article 9 (2) (b) GDPR For the purposes of employment and social security:

Such as complying with employment laws

• Article 9 (2) (e) GDPR Data has been made public by the data subject:

Such as the Electoral Roll

• Article 9 (2) (f) GDPR Establishing, exercising or defending a legal claim:

Such as litigation against a business or employee

• Schedule 1, Part 2, Paragraph 15 DPA 2018 Suspicion of money laundering:

In line with Section 339ZB of the Proceeds of Crime Act 2002

• Schedule 1, Part 2, Paragraph 20 DPA 2018 Insurance:

Advising on, underwriting, arranging or administering an insurance contract

• Schedule 1, Part 2, Paragraph 21 DPA 2018 Occupational Pensions:

Next of kin information of employees signed up to the pension scheme.

We may also process Criminal conviction data under:

• Schedule 1, Part 3, Paragraph 33 DPA 2018 Legal claims:

In connection with legal, or potential legal proceedings, obtaining legal advice or establishing,

defending and /or exercising legal rights.

2. Information We Share

We do not sell or otherwise disclose personal information we collect about you, except as described

in this Privacy Notice or as indicated via the consent process at the time the data is collected. We

may share the information we collect, where applicable, with:

 Landlords and landlord associates and sub processors

 Property Management Estate Agents

 Third Party Property Sales Service Providers

 Vetted affiliates and partners

 Financial Institutions

 Insurance Companies 

 Formally contracted service providers for:

Hosting Data centres, Infrastructure and Applications development and support,

 Cloud Services

 Helpdesk and Call Centres etc.

 Councils, local authorities, and health and care providers

 Water and other utility companies

 Law firms and EPC providers

 Credit agencies

 Land Registry Office

 Her Majesty’s Revenue and Customs (HMRC),

 Relevant regulatory bodies and authorities

Anchor Property may also disclose personal information to other employees in the course of providing

you with our services. Anchor Property does not permit these parties to use such information for any

other purpose than to perform the services they have been instructed to provide by us.

We may also share information about you, if required legally, to prevent harm or financial /

reputation loss, for investigation of suspected or actual fraudulent or illegal activities.

We contractually require service providers and processors to safeguard the privacy and security of

personal information they process on our behalf in line with data protection obligations and

authorise them to use or disclose the information only as necessary to perform services on our

behalf and under our instruction or to comply with legal obligations and requirements.

On websites, features can be accessed where we partner with other entities that are not affiliated

with Anchor Property. These include social networking and geo-location tools etc. and are operated by

third parties who may use or share personal information in accordance with their own privacy

policies. It is recommended that you review the third parties’ privacy notice if you use the relevant

features.

In the event of a sale or transfer of our business or assets (wholly or partly) Anchor Property reserve the

right to transfer your information to the acquirer. You can exercise your rights and gain clarification

concerning the protection and processing of your information by the acquirer by contacting them

directly.

2.1 Profiling

Anchor Property may use direct or anonymised information to engage in data analysis, data matching

and profiling activities for a variety of purposes, including, but not limited to:

 Business conduct 

 Investigation and identification of fraud, money laundering and other potential unauthorised

activities,

 Financial Viability analysis / reports

 Business partner / client portfolio position, performance, risk positions

 Anti-money laundering

 Tax reporting

 Credit defaulting / exposure

2.2 International Data Transfers

Anchor Property may transfer or store your personal information to countries or organisations outside

of the EEA. Those countries may not have the same level of protection or requirements concerning

the safeguarding and processing of personal data. However, where possible, agreements will be put

in place to ensure your personal information is provided with the same adequacy of data protection

adopted in the UK, by following legislation and ICO guidelines and requirements, such as using

Binding Corporate Rules, Adequacy Rulings, EU-US privacy Shield and Model Clauses.

2.3 Retention

We keep your personal information in line with our Data Retention & Destruction Policy. In certain

circumstances we have a statutory obligation to keep your personal information for a set period of

time, for example, financial information (normally 7 years) for financial auditing purposes.

Information is always retained in line with its purpose of processing and only for as long as necessary

usually, information is kept for 7 years after last contact with you. However, this period may be

extended dependent upon any legal or contractual obligations Anchor Property may be required to

comply with, as well as any overriding business legitimate interests.

2.4 Your Rights and Choices

Under Data Protection law and regulation, you have a number of rights. The applicability of these

rights are dependent upon our purpose and lawful basis of processing, therefore not all of these

rights may be available to you.

You can exercise your rights either verbally or in writing. However, should you make a request

verbally we recommend that you follow this up in writing to provide a clear correspondence trail.

We have an obligation to respond within one month of receiving your request. Should we deem the

request to be complex the response time can be extended by up to two months. Should this be

required, you will be informed of the extended response date, alongside an explanation, within the

original one month time frame. 

Should we feel the need to verify your identity, identification will be requested within the one

month time frame and only limited to what is necessary for confirmation. Once we are satisfied we

will then process your request.

Should we refuse to comply with a request we will inform you of this within the one month time

frame and provide an explanation outlining our justification, our internal complaints procedure and

your right to complain to a supervisory authority and to enforce your rights through a judicial

remedy.

2.5 Your Right of Access

You have the right to request and receive copies of the personal information we hold that directly

relates to you. This right is applicable at all times; however, due to exemptions within the legislation

you may not always receive all the information we process. If this is applicable an explanation will be

provided to you within our response.

If you are requesting information on behalf of someone else we require you to provide proof that

you are entitled to act on behalf of the data subject and will require written confirmation of this

authority. If we are not satisfied you have the right to act as a delegated authority we reserve the

right to refuse the request.

2.6 Your Right to Rectification

You have the right to request that inaccurate information is rectified and incomplete information

completed. Please provide an overview of the information you wish to be rectified / completed.

Upon receipt of your request an investigation will be undertaken and a response determining our

decision will be provided to you. Please be aware that we may need to take certain steps to verify

the accuracy of the new information before the change can be applied.

2.7 Your Right to Erasure

You have the right to request your personal information is deleted by us; however, this only applies

in certain circumstances. To exercise this right, please provide us with an overview of the

information you would like deleted and your reasoning. Upon receipt this matter will be investigated

and a response determining our decision provided to you.

In certain circumstances we may be unable to physically delete your data, however, we may put in

place steps to ensure the data is ‘put beyond use’, anonymised or pseudonymised and you will be

notified of this. 

2.8 Your Right to Restrict Processing

You have the right to request we restrict the processing of your personal information, however, this

only applies in certain circumstances. To exercise this right please provide us with an overview of the

information you would like restricted and your reasoning for this request. Upon receipt this matter

will be investigated and our decision provided to you. Processing of your personal data will not

resume without you being notified that the restriction is to be lifted.

2.9 Your Right to Object

You have the right to object to us processing your data whereby we are processing your information

in the public interest or for our legitimate interests. To exercise this right, please provide us with an

overview of the information you are objecting to and your reasoning for this. Upon receipt, this

matter will be investigated and our decision provided to you.

You also have an absolute right to object to us using your data for direct marketing. You can exercise

this right by:

• e-mailing anchorproperty.info

• Unsubscribing via the “unsubscribe link” within the marketing e-mails you receive

from us, or

• Contacting Anchor Property as indicated below in Section 3.

2.9.1 Cookies Policy

Anchor Property operate a Cookie Policy. Some of our service providers and partners may collect

information about your online activities over time and across third-party websites to customise and

target our adverts.

You can opt out collection of personal information by automated means e.g. when visiting our

website or visit third-party websites and interact with our adverts, by using the Cookie Consent tool

displayed in the website (the browser you use may provide options on how to opt out of receiving

certain types of cookies). However without cookies you may not be able to use all of the website

features and/or online services. A full description of how we collect and use cookies is available at

https://www.anchorpropertywm.co.uk

2.10 Your Right to Data Portability

You have the right to request us to transfer the information you have provided to us to another

organisation or to you directly. This right only applies if we are processing information based on your

consent or in regards to a contract and the processing is automated. Requests to exercise this right

will be reviewed and a decision provided to you. 

2.11 Your Right to Automated Decision Making and Profiling

If automated decision making and profiling have been used you have a right to obtain human

intervention and challenge a decision made as a result of this process. Requests to exercise this right

will be investigated and a decision provided to you.

2.12 Withdrawal of Consent

If we obtain your information by consent you have the right to withdraw your consent at any time.

However, the right to consent removal may be limited in some circumstances by local law

requirements. Should this apply you will be informed appropriately.

3. Contact Information

You can exercise your rights, raise a query or concern, report a breach or make a complaint by

contacting the applicable business unit or:

Emailing: anchorproperty.info 

writing to: Mr Lee Edwards

Data Protection Officer

Anchor Property ltd

Grosvenor House 

11, St Pauls Square,

Birmingham.

B3 1RB

To assist us in responding to your request in a timely and satisfactory manner please provide as

much detail as possible during your contact with us.

4. How to Lodge a Complaint

If you remain unsatisfied with the way in which Anchor Property have handled your data or dealt with

your request / complaint you have a right to raise this with the relevant Supervisory Authority and to

seek to enforce your rights through a judicial remedy.