Watts Property Consultants Limited (‘WPCL’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection regulation and laws in the EU and in Guernsey. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.  WPCL is a Guernsey Company. We are registered with the Office of the Data Protection Commissioner in Guernsey. We have a designated Information Secuity Officer who can be contacted at the address and contact details on this letterhead. We are subject to EU GDPR and Guernsey’s own data protection legislation.

WPCL processes your personal information to meet our legal, statutory and contractual obligations and to provide you with estate agency services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice. The personal data that we may collect from you is:-

• Name/ former names/ other names used
• Date of Birth
• Home Address
• Personal Email/Business Email
• Home Telephone Number/Mobile Telephone Number
• Occupation/Employer
• National Insurance Number
• Passport Number/Driving Licence Number
• Tax numbers and details including advice
• Source of wealth information
• Bank Details

We collect information directly from you and will verify the information that you give us utilising open source information as we are obliged to do under Guernsey legislation designed to ensure that our jurisdiction’s financial service business are not utilised for money laundering, terrorist financing or bribery and corruption (AMLCFTABC) processes. 

Where we operate CCTV in a property we manage, we may also capture your image.  This would also constitute your personal data.

WPCL takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. The purposes and reasons for processing your personal data are detailed below:-

• We collect and store your personal data as part of our legal obligation for AMLCFTABC, business accounting and tax purposes
• We will store your data on our property management system
• We will store minimum personal data on our accounting system to enable us to invoice you
• With your specific consent (see below) we will process your data to keep you up to date with the properties that we have on our books which we think that you may be interested in for rental or purchase
• With your specific consent (see below) we will process your data in order to approach you to advise you of a possible buyer for your own property
• With your specific consent (see below) we will add you to our mailing list and you will receive our newsletter and other general communications which we think may be of interest to you.
• Where we operate CCTV in properties we manage, this is based on our legitimate interest in protecting the property and ensuring the safety of visitors, tenants and clients, as well as to assist with the prevention and detection of crime.

You have the right to access any personal information that WPCL processes about you and to request information about:-

• What personal data we hold about you
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.  You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws.

It should be noted that due to the fact that W&C have a legal obligation to process your data to comply with AMLCFTABC legislation in Guernsey and also record retention requirements of at least 5 years (for the same legal reason), the permanent and total erasure of the data that we hold for you would not be immediately possible and we would discuss our processes with you should you ever need to exercise this right. In addition a request to cease or restrict processing where we have a legal obligation to do so would necessitate the cessation of our business relationship in accordance with Guernsey AMLCFTABC legislation.

Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use. It should be noted that W&C does not, at this time, utilize any automated decision-making.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. WPCL uses third-parties as detailed below to provide the services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

• We have a legal obligation to share your personal data with our Regulator (the Guernsey Financial Services Commission) or the local Financial Intelligence Service if ever requested to do so
• We will share your personal data with our local compliance consultant who is also bound by the same Data Protection legislation as we are and with whom we have entered into a legally binding contract to ensure that your data is kept safe and secure
• We will share your personal data with our IT service provider who is also bound by the same Data Protection legislation as we are and with whom we have entered into a legally binding contract to ensure that your data is kept safe and secure
• We will share your data with Banks (where we provide management services) in order to ensure that they can comply with AMLCFTABC legislation and in order to ensure that banking services are maintained for the entity relationships under our control and to ensure that you can receive the funds to which you may be entitled from them
• We will input selected parts of your data (ie name and address) to our online accounting system to enable us to raise invoices to you and bookkeep those invoices.

WPCL takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place.

Personal data in the European Union is protected by the General Data Protection Regulation (GDPR) but some other countries may not necessarily have the same high standard of protection for your personal data. WPCL does not transfer or store any personal data outside the EU.

You are not obligated to provide your personal information to WPCL, however, as this information is required for us to provide you with our services and to comply with local AMLCFTABC legislation, we will not be able to offer any of our services to you without it.

WPCL only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under international tax law and local AMLCFTABC legislation to keep your basic personal data for 5 years after our business relationship ceases.

WPCL does not process any special category data.

WPCL only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the Data Protection Officer. If your complaint is not handled to your satisfaction, or you simply wish to go straight to the supervisory authority, you have the right to lodge a complaint with the Office of the Data Protection Commissioner in Guernsey.

Office of the Data Protection Authority
St Martin's House
Le Bordage
St. Peter Port
Guernsey
GY1 1BR

Telephone: +44 (0) 1481 742074
Email: enquiries@odpa.gg