REVISION DATE NAME DESCRIPTION
1.0 13/12/2017 Mr M Corr Original draft
1.1 04/06/2018 Mr M Corr Updated to include data sharing to USA
1.2 29/05/18 Mr M Corr Updated in line with industry guidance
1.3 12/08/2020 Mr M Corr Updated to include Video Surveys
Approved by Ian Palmer on: 11/08/2020
Document became operational on: 13/12/2017
Next review date: August 2021
White & Company takes your privacy very seriously. This Data Privacy Statement describes how White & Company collects and uses your personal data and sets forth your privacy rights.
We recognise that information privacy is an ongoing responsibility, and so we will from time to time update this Data Privacy Statement as we undertake new information security practices or use new technology to collect personal data, where it is appropriate.
We are a registered ‘data controller’ with the Information Commissioner’s Office (registration number ZA458951).
What we need to know about you and how we use that information
All our services require your personal data. Exactly what personal data we require varies on the service. However, most of our services require certain personal data. This typically includes:
• The full name of the customer;
• An email address and/or phone number for the customer; and
• The addresses where goods are collected from or delivered to.
Other personal information we may collect includes:
• Financial information (e.g. payment card information).
For private jobs, payment card information is provided directly by customers, either in person or via phone call, and entered into a PCI/DSS-compliant payment processing service. White & Company does not, itself, process or store payment card information. We use an online virtual payment terminal where transactions take place with our payment provider.
• Data collected by our website (e.g. web form enquiries).
We collect personal data submitted to us using our web enquiry form. Our website also collects certain information automatically and stores it in log files, for example internet protocol (IP) addresses. We use this information to help us design our site to better suit our users’ needs.
Our website is maintained by Futurenet Publishing with whom White & Company has a Data Processing Agreement. Futurenet Publishing only handles personal data collected from White & Company’s website at our instruction and this is only ever for statistical analysis purposes to inform our marketing team.
Our website uses Google Analytics. Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use and navigate the site.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. A cookie can’t read data off your hard drive or read cookie files created by other websites. Cookies do not damage your system; they allow us to respond to you as an individual.
A cookie in no way gives us access to your computer or any information about you, other than personal data you choose to share with us.
The information generated by cookies about your use of our website (including your IP address) will be transmitted to and stored by Google on servers located in the EU. Google will use this information for the purpose of evaluating your website activity and internet usage, compiling reports on website activity for website operators and providing other services relating to website activity usage.
• Lead generation.
We purchase information about properties on the housing market from a lead generation company. They collect address information both directly from individuals and publicly available sources, for example, information about a property in the public domain includes whether it is ‘for sale’ or ‘sold subject to contract’.
• Data collected via video conferencing software (e.g. Zoom).
Where pre-move surveys in person are not possible, we conduct surveys via video call. These video calls are recorded so our surveyors can re-watch the call when calculating volumes accurately, as this informs your quotation for the service. A copy of recorded videos are stored on a server hosted by Amazon Web Services and are deleted after 30 days.
Sharing your information with our Partners
The services we provide can involve a national or transnational supply chain. In these cases we share only the personal data they require. If this involves transferring information to a country not recognised by the Information Commissioner’s Office as providing equivalent protection, we’ll use additional safeguards where required.
Where the service you book with, or is allocated to, White & Company includes importing or exporting your possessions into or via the United States, U.S. Customs and Border Protection (CBP) will legally obtain the Vessel Manifest. This document includes some of the shipper’s personal information, for example, the name and address to which the shipment is consigned and their passport number.
You can mitigate this risk, and we recommend you do so, by completing the IAM’s Vessel Manifest Confidentiality Request Form. By completing this form you are requesting that your shipment, and you as the shipper, is not shared by the CBP.
Securing your personal information Recordings of video surveys are stored on servers hosted by Amazon Web Services. All other data is stored on our on-premise servers which are kept in a secure site and protected by threat detection software and a hardware firewalls, preventing unauthorised access.
All our employees and third parties who require access must use multi-factor authentication to gain access to our servers. Employees are granted different privileges to ensure access to personal data is limited to a need-to-know basis.
We will store your personal data for the duration of the service. We retain personal data longer, only when we are legally obliged to do so. When it is no longer necessary for to retain your personal data, we securely erase and shred hardcopies.
Your privacy choices and legal rights
Here are your privacy choices:
• You can choose to not provide us with personal information, in which case we will try to provide the service but it may be impossible.
Here are your rights:
• You can access the personal information we hold about you.
• You can make us correct any of this personal information if it is inaccurate.
• You can ask us to erase the personal information about you we hold and which is no longer necessary to delivering the service for you.
• You can complain about our handling of your personal information to the Information Commissioner’s Office. (Please tell us first, so we have a chance to address your concerns.)
If you are a customer and wish to exercise your rights, please contact the Branch and Department you have been speaking with. If you prefer, you can contact us at email@example.com or write to us at:
FAO Compliance White & Company International House, Unit G Bar End Ind. Est. Winchester SO23 9NP
If you don’t feel we’ve dealt with your request appropriately you have the right to lodge an appeal with the Information Commissioner’s Office.