Privacy Policy

This notice explains how DRM Residential handles personal information about people who enquire about, rent, let, sell or buy property through us, and others involved in those services. It reflects our obligations under the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018 and other applicable law. It should be read alongside any relevant terms of business, tenancy documents or other information provided to you. It does not cover staff and job applicants, for whom separate privacy information may be provided.

Who we are and how to contact us

DRM Residential Property Letting & Management Limited (trading as DRM Residential) is the data controller for the personal information described in this notice, except where we make clear that another organisation is responsible for its own use of information.

Address: 49 Comiston Road, Edinburgh EH10 6AB
Email: info@drm-residential.co.uk
ICO registration: Z7680934
You can contact us at the above address or email about this notice, your personal information or your data protection rights.

Who and what this notice covers

Depending on your dealings with us, we may hold information relating to property owners, landlords, sellers, prospective buyers, buyers, tenants, prospective tenants, occupiers, guarantors, contractors, people making enquiries and representatives of organisations. We do not collect every type of information from every person.

•  Identity and contact details, such as names, postal and email addresses, telephone numbers, dates of birth and identification documents.

•  Property and transaction details, including ownership, instructions, property-search requirements, valuation requests, requests for Home Reports, viewing arrangements and feedback, notes of interest, offers, negotiations, tenancy arrangements, repairs, inspections and correspondence.

•  Financial and verification information, where relevant, including payment and bank details, affordability and employment information, references, credit-check results, source-of-funds information and records of anti-money-laundering checks.

•  Records of communications, complaints, incidents and disputes; and images or information about people or belongings appearing in property photographs, videos or virtual tours.

•  Other information that is reasonably necessary in particular circumstances, such as information relating to support needs or accessibility arrangements.

•  Website and digital-service information, where applicable, such as IP addresses, device or browser information, basic server logs and information submitted using online enquiry forms.

Where we obtain information

We obtain information directly from you when you contact us, give instructions, complete forms, request a valuation or Home Report, register an interest in a property, arrange a viewing, apply for a tenancy, submit an offer, make a payment or otherwise deal with us. We may also receive relevant information from:

•  Landlords, sellers, tenants, applicants, guarantors and other people involved in a property or transaction;

•  Property portals, our website, other property agents, solicitors, conveyancers, surveyors and referral partners;

•  Employers, previous landlords, referencing and identity-verification providers, credit-reference agencies and payment providers, where relevant;

•  Public registers and official sources, including Registers of Scotland, Companies House, local authorities, HMRC and relevant law-enforcement or regulatory bodies.

We only use information obtained from other sources where there is an appropriate reason and lawful basis to do so. If we obtain personal information about you from someone else, we will provide relevant privacy information when required, subject to any lawful exemptions.

Why we use information and our lawful bases

UK data protection law requires us to have a lawful basis for using personal information. Different bases may apply depending on the activity and your relationship with us.

Our legitimate interestsinclude responding to enquiries, supplying property services, marketing and managing property on behalf of clients, communicating between parties, preventing fraud, keeping records and running a responsible business. We consider those interests against your rights and expectations.

Identity checks, sensitive information and information you must supply

In estate agency sales, we are required to carry out appropriate customer due diligence on sellers and buyers under anti-money-laundering rules. The checks and their timing depend on the circumstances and legal requirements. They may involve photographic identification, proof of address, ownership and beneficial-ownership information, politically exposed person and financial-sanctions screening and, where necessary, information on the source of funds or wealth. We may use an identity-checking provider and retain the results. Similar or additional checks may be required in certain letting transactions.

Some records may include health, disability or other special-category information (for example, an accessibility requirement) or, separately, information concerning criminal allegations, sanctions or offences. We process such information only where necessary and where the additional legal conditions and safeguards required by data protection law apply. Where biometric identification is used to uniquely identify a person, additional conditions may apply. The conditions may include explicit consent, legal claims or relevant substantial-public-interest grounds, depending on the circumstances.

Certain information is needed by law, to enter into an agreement or to provide a requested service. If you do not provide it, we may be unable to proceed with an instruction, tenancy application or property transaction. Information requested solely for optional marketing or other optional purposes is not a condition of receiving our core services.

Who we share information with

We share personal information only where reasonably necessary for the purposes explained above, where permitted by law, or where you have asked us to arrange an introduction. Depending on the circumstances, recipients may include:

•  Landlords and sellers, buyers, prospective buyers, tenants, prospective tenants, guarantors and their authorised representatives or solicitors, as necessary. For example, we may communicate viewing details and feedback, relevant notes of interest and offers to the seller; or tenancy and reference information to a landlord when appropriate;

•  Property portals and advertising providers, photographers, floor-plan and virtual-tour providers, Home Report or survey providers, and other contractors involved in marketing or managing property;

•  Referencing, identity-verification, anti-money-laundering, payment and accounting providers; our IT, communications, cloud-storage and back-up service providers;

•  Contractors, tradespeople, utility providers, local authorities, deposit protection providers, and organisations involved in the management or occupation of property. Where appropriate, relevant tenancy information may be supplied to a new owner or incoming managing agent;

•  Solicitors, insurers, professional advisers, redress or regulatory bodies, HMRC, law-enforcement agencies and other authorities where necessary or required;

•  Providers of optional related services, such as financial advice, conveyancing or removals, where you ask us to introduce you or the disclosure is otherwise lawful.

We may receive referral fees for some introductions. Businesses such as solicitors, surveyors, mortgage advisers and other providers of optional services may act as separate data controllers and provide their own privacy information. Organisations supplying IT, identity verification or other services solely on our behalf generally act as processors subject to appropriate contractual controls. We do not sell personal contact information to unrelated businesses for their independent marketing. If our business or relevant assets are transferred or reorganised, necessary records may be shared with appropriate advisers or a successor subject to data protection safeguards.

Property marketing, publicity and communications

When instructed to market a property, we may publish its address or location, description, photographs, floor plans, videos, virtual tours and other agreed particulars on our website, property portals, social media and advertising channels. We take reasonable steps to avoid including unnecessary personal information, but images may incidentally show personal belongings or identifying details. Please draw any privacy concerns to our attention before photography or publication. Enquiries about a property, requests for a Home Report and viewing feedback may be recorded and shared with the seller where relevant.

We may contact people about a valuation, viewing, Home Report, particular property or other service they have requested. Where available, we may use property-search preferences to provide specifically requested property information or alerts. Separate promotional emails or texts about our services or other properties will be sent only where we have consent or meet the requirements of a relevant legal exception, such as the products-and-services soft opt-in. That exception requires, among other things, appropriate opt-out opportunities at collection and in every subsequent message. We comply with applicable rules for other marketing channels. You may opt out of direct marketing at any time by contacting us or using an unsubscribe facility where provided.

Website use and cookies

When you use our website or complete an online form, technical information such as your IP address, browser or device details and basic connection logs may be handled by us or our website service providers to deliver and protect the service, troubleshoot problems and understand its operation. If we use optional analytics, advertising cookies or similar technologies, further details of the tools, purposes and choices should be set out in our website cookie information. Where consent is required for non-essential cookies or tracking, it must be obtained before those technologies are used. Third-party sites linked from our website have their own privacy practices.

Website analytics, maps and cookies

Our website may use cookies and similar technologies to provide functionality, remember visitor preferences and understand how the website is used.

We use Google Analytics to help us understand website traffic, including visitor numbers, pages visited and how visitors reach our website. Our website may also incorporate Google Maps, which can involve Google receiving information about visitors and using cookies or similar technologies.

Some cookies are necessary for the operation of the website, while others may be used for analytics or additional functionality. We provide information about the cookies and similar technologies in use, their purposes, relevant third parties, how long they operate and the choices available to visitors. Where consent is required, we will obtain it before using the relevant technologies.

International transfers and security

We use electronic systems and service providers to manage and protect records. Some suppliers or their support arrangements may involve access to information from outside the UK. Where a restricted international transfer occurs, we use an available lawful transfer mechanism, such as UK adequacy arrangements or appropriate contractual safeguards, as required. You can contact us for further information about applicable safeguards.

We apply appropriate technical and organisational measures designed to protect personal information against unauthorised access, loss, alteration or disclosure, and limit access according to business need. No transmission or storage system can be guaranteed entirely risk-free.

How long we keep information

We keep information only for as long as is reasonably necessary for the relevant service, ongoing relationship, legal or regulatory obligation, complaint, transaction record or potential claim. Retention depends on the type of information and circumstances:

•  Anti-money-laundering customer due diligence records are generally retained for five years after the relevant business relationship ends or transaction completes, then deleted unless a lawful exception requires otherwise.

•  Accounting and tax records are retained for the applicable statutory period, commonly six years, depending on the record.

•  Instructions, tenancy and sale files, correspondence and associated records are retained while active and afterwards for a period justified by legal, contractual, professional and complaint-handling needs, under our retention arrangements.

•  Unsuccessful enquiries and applications are reviewed against whether the enquiry remains active, whether follow-up was requested, and whether a dispute, legal duty or other legitimate reason requires continued retention.

•  Back-up copies may remain for a limited additional period until replaced or deleted under our back-up arrangements.

You can ask us about the retention period or criteria applying to particular information we hold about you.

Your data protection rights

Depending on the circumstances, you may have rights to receive a copy of your information, correct it, request its deletion, restrict or object to its use, and obtain certain information in a portable format. Where we rely on consent, you may withdraw it at any time without affecting previous lawful use. You have an unconditional right to object to our use of your information for direct marketing.

These rights are not absolute. Some information must be retained or cannot be disclosed where a legal obligation or an applicable exemption applies, including in some anti-money-laundering circumstances. To exercise a right, email info@drm-residential.co.uk. We may need to verify your identity before responding.

Automated decisions

We may use third-party tools to assist with reference, identity or compliance checks. In our usual process, decisions about whether we can provide a service or progress a transaction are reviewed by people. We do not currently use solely automated decision-making that produces legal or similarly significant effects. If our practices change, we will provide any additional information and safeguards required by law.

Complaints and updates

If you have a complaint about how we handle your personal information, you can email info@drm-residential.co.uk or write to us at our office address. We will acknowledge a data protection complaint within 30 days, investigate and keep you informed without undue delay, and tell you the outcome. This procedure is separate from complaints about our property services. You also have the right to complain to the Information Commissioner’s Office (ICO): www.ico.org.uk/make-a-complaint/ or telephone 0303 123 1113.

We may update this notice when our services, systems or legal obligations change. We will make the current version available on our website or on request, and communicate material changes where appropriate. Please tell us if your contact or other relevant information changes so we can keep our records accurate.