Data Protection Statement
This Data Protection Statement is effective as and from 25 May 2018
At Keane Thompson, we are committed to ensuring that your privacy is protected. Our use of your personal information is governed by this data protection statement.
In this statement, we use the terms, Keane Thompson, “we”, “our” and “us” to refer to Keane Thompson Limited, Ireland with limited liability having its registered office at Unit 1, 3 Sandyford Village, Sandyford, Dublin 18, Ireland.
Keane Thompson is the controller responsible for the personal information it collects, uses and stores about you.
1. What is personal information?
Personal information is any information that allows us to identify you. This could include information such as your name, postal address, telephone number, email address, date of birth or bank account details.
Any references to personal information in this data protection statement will include personal data, and where relevant, special categories of personal data. You can find out more about the special categories of data below.
2. Categories of personal information we collect and how we use it
Set out below are some of the types of personal information that we may collect, use and store about you and the reasons for doing so.
|Information type||Example of how we use it|
|Name, contact details (to include postal address, email address, telephone numbers).||We will use this information to:
|Your bank account, building society or similar account details.||If you are selling or letting a property through us, we will use this information to arrange onward payment due to you.
If you are renting a property we are listing, we will use this information to manage an approved rental account.
|Information about any specific access requirements you may have.||If you wish to rent or purchase a property we are listing, we will use this information so that we can find a property that is suitable for your needs.|
|Information relating to any familial or other close connection you may have with Keane Thompson staff.||We will use this information to manage potential conflicts of interest.|
|Details of interactions with our staff and officers, including notes of your calls with our staff on our database and information provided by you in customer satisfaction surveys.||We will use this information to monitor and train our staff and improve our service to our customers.|
|Details about the sector in which you work and the type of content that you would like to receive.||If you subscribe to receive marketing materials from us, we will use this information to tailor the information we provide to you.|
|Recruitment information (including copies of right to work documentation, contact details, date of birth, work and education history, referees names, interview notes and related documentations that form part of the application process).||We will use this information to review and process your application for recruitment opportunities with us.|
|Information relating to your online activities including your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access any website operated by us.||We will use this information:
To monitor the effectiveness of our website
To deliver relevant website content and advertisements to you and
To measure or understand the effectiveness of the advertising we serve to you.
We also collect, use and store aggregate data. Aggregate data is information gathered and expressed in a summary form for purposes such as statistical or demographic analysis. Aggregate data may be derived from your personal information but is not data that directly or indirectly reveals your identity. For example, we may aggregate information relating to your use of our website to calculate the percentage of users accessing a specific feature on our website. If we combine or connect aggregate data with your personal information so that it can directly or indirectly identify you, we consider the combined data as personal information, which will be treated in accordance with this data protection statement.
We do not collect any special categories of personal information. Special categories include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions and health. Nor do we collect any criminal conviction information. However, if it is necessary to collect special categories of personal information and/or criminal conviction information, we will only do so with your explicit consent and we will explain the purpose for which the information will be used at the point when we ask for your consent.
3. The purpose and legal basis for processing your information
Under data protection law we are only permitted to use your personal information if we have a legal basis for doing so. We rely on the following legal bases to use your information:
a) To enter into and perform a contract with you
We may use your information in order to enter into a contract with you or to provide you with a service that you have requested from us.
b) To comply with a legal obligation
We are required to use your personal information to comply with certain legal and regulatory obligations to which we are subject. For example:
- We are obliged to obtain certain business records in accordance with company and revenue law requirements, which may include your personal information.
- Anti-money laundering legislation requires us to keep customer and other related parties’ personal information for a period of at least five years after the relationship ceases with the customer or the date of the last transaction, whichever is later.
- Health and safety legislation requires us to keep records of persons attending properties that we are marketing.
- We have certain obligations pursuant to the Property Services (Regulation) Act 2011, which include maintaining certain records in respect of property transactions in which we are instructed. These records may contain personal information.
c) For our legitimate interests
We may use your personal information for the purposes of carrying out activities that are in our legitimate interests (or those of a third party). When we use your personal information in this way, we ensure that there is a fair balance between our legitimate interest and your fundamental rights and freedoms.
Our legitimate interests include developing our business and tailoring our offering to meet the needs of our existing and prospective customers. In pursuing these legitimate interests, we may use your personal information to carry out research on the property market in order, for example, to identify trends for the purpose of improving our service.
We may also use your personal information to manage and operate the administrative and technical aspects of our business efficiently and effectively. This will include verifying the accuracy of information that we hold about you to create a better understanding of you as a customer and taking steps to protect your information against loss, damage, theft or unauthorised access.
In more limited circumstances we may also rely on the following legal bases:
- Where we need to protect your interests (or someone else’s interests); and/or
- Where your personal information is needed in the public interest or for official purposes.
d) With your consent
We may send you marketing materials by post, text, email and/or phone from time to time after you have engaged us to provide services or received services from us either which may be similar and of interest to you or where you have expressly indicated that you would like to receive such information. You can withdraw this consent at any time by emailing us at email@example.com or by writing to us at Data and Compliance, Keane Thompson, Unit 1, 3 Sandyford Village, Sandyford, Dublin 18, Ireland.
4. Your information and Third Parties
Third Party Service Providers
We may share your personal information with third party service providers that perform services and functions at our direction and on our behalf. Such third party services providers include accountants, legal advisers, IT service providers, security services providers, administrative services providers and marketing agencies engaged by Keane Thompson.
Other entities within Keane Thompson
Where we convert your information into statistical or aggregate data in such a way as to ensure that you are not identified or identifiable from it, we may pass this information on to other Keane Thompson entities for analytical and statistical purposes.
An Garda Síochána, government or quasi-government bodies, courts and tribunals
We may share your personal information with these organisations and bodies where required to do so by law.
Potential sale or merger
If we sell any part of our business and/or integrate it with another organisation your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers. If this occurs the new owners of the business will only be permitted to use your information in the same or similar way as set out in this data protection statement.
5. Storage Periods
The period for which we will keep your personal information will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where, for example, we have a legitimate interest in retaining such information that is not outweighed by your fundamental rights and freedoms, where we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in the event of a legal claim.
6. Transfers outside the European Economic Area
We may transfer, store or process your personal information to countries outside the European Economic Area. Where the laws of such countries do not afford an equivalent level of protection of personal information as the laws of Ireland, we take specific steps in accordance with data protection law to protect your personal information.
We’ll use one of these safeguards:
- Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA.
- Put in place a contract with the recipient of the personal information that means they must protect it to the same standards as the EEA.
- Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA.
7. Automated decision-making and profiling
We may use your personal information for automated decision-making and profiling purposes to analyse or predict matters relating to you, such as your interests or location. We carry out this processing in our legitimate interest for the purposes of our market research activities.
8. What happens if you do not provide information that we request?
We need some of your personal information to perform the services you have requested from us. For example, where we are selling a property on your behalf, we require your contact information so that we can update you with information on viewings, offers and the progress of the sale.
We also need some information from you so that we can comply with our legal obligations. For example, we may need identity and financial documents from you to meet our obligations to prevent fraud and money laundering.
If you do not provide the information required for these purposes, we will not be able to perform our contract with you and may not be able to provide services to you or continue to provide certain services to you. We will explain when this is the case at the point where we collect information from you.
9. Your Rights
You have a number of rights under data protection law in relation to how we use your personal information. These include the right, free of charge, to:
- 1. Be informed about the personal information we hold about you and how we use that information.
- 2. Obtain access to your personal information we hold.
- 3. Have any personal information that we hold about you that you believe is incorrect, incomplete or inaccurate updated or corrected.
- 4. Have your personal information erased in the following circumstances:
- a. If Keane Thompson is continuing to process personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected.
- b. If Keane Thompson is relying on consent as the legal basis for processing and you withdraw consent.
- c. If Keane Thompson is relying on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us to continue with the processing.
- d. If the personal information has been processed unlawfully.
- e. If it is necessary to delete the personal information to comply with a legal obligation.
- 5. Have our processing of your personal data restricted where you consider that:
- a. The personal information is inaccurate.
- b. The processing is unlawful and you oppose erasure and request restriction instead.
- c. Where we no longer need the personal information but you require us to keep it to enable you to establish, exercise or defend a claim.
- d. Where you have raised an objection to our use of your personal information.
- 6. Object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal information.
- 7. Not be subject to wholly automated decisions, including profiling, which produce legal effects or which could have a similarly significant effect on you.
These rights are in some circumstances limited by data protection legislation. If you wish to exercise any of these rights, you can contact us using the details below.
10. Complaints and contact details
If you have any complaints about the way we use your personal information please contact us using the details below and we will try to resolve the issue. If we cannot resolve any issue, you have the right to complain to the Data Protection Commissioner. You can find further information about the Data Protection Commissioner at www.dataprotection.ie.
If you have any questions, comments or requests regarding any aspect of this data protection statement, please do not hesitate to contact us by emailing us at firstname.lastname@example.org or by writing to us at Data and Compliance, Keane Thompson, Unit 1, 3 Sandyford Village, Sandyford, Dublin 18, Ireland.
We will update this data protection statement from time to time. Any updates will be made available and, where appropriate, notified to you.