Fair Processing Notice
1. Fair Processing
1.1 The personal data we collect from you will be used for the following purposes:
- Processing your instructions with respect to the sale and/or purchase of businesses in our portfolio, including related advertising, submission of offers etc as well as consultancy and valuation services.
- Direct marketing informing you of similar opportunities arising in the market
1.2 You may unsubscribe from marketing communications from us at any time by
- sending an email to email@example.com , using your email address that we have in our records, with the title “Unsubscribe”; or
- if you are registered on our website, by updating your account accordingly; or
- sending a letter to our Data Protection officer at Pinder House, 249 Upper Third Street, Milton Keynes MK9 1DS.
1.3 What is Personal Data?
Under the EU’s General Data Protection Regulation, Personal Data is defined as “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”.
1.4 In order for us to provide you with a service we need to collect personal data for correspondence purposes and/or direct marketing. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. We may pass your personal data on to our service providers who are contracted to the Christie Group in the course of dealing with you. Our contractors are obliged to keep your details securely, and use them only to fulfil the service they provide you on our behalf. Once your service need has been satisfied or the case has been closed, they will dispose of the details in line with the Christie Group’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do so.
1.5 The Christie & Co Network will process – that means collect, store and use – the information you provide in a manner that is compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date and not keep it for longer than is necessary. In some instances the law sets the length of time information has to be kept, but in most cases the Christie Group will use its discretion to ensure that we do not keep records outside of our normal business requirements.
1.6 Marketing use: Your personal information may be used for marketing purpose as part of our legitimate business interests. If you object to the use of your personal data for this purpose, please email firstname.lastname@example.org and ask for removal of your details for marketing purposes. In addition, all our electronic marketing material carries an unsubscribe option, so you can also unsubscribe at any time.
1.7 Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
1.8 Special Categories of Personal Data - Certain data are classified under the Regulation as ”special categories”:
- Ethnic origin
- Political Opinions
- Religious Beliefs
- Trade-union membership
- Genetic Data
- Biometric Data
- Health Data
- Data concerning a natural person's sex life
- Sexual orientation
1.9 We will only ask you for data in some of the above Special Categories in order to fulfil our legal obligations, such as anti-Money Laundering due diligence.
A current version of this document is available to all members of staff on the corporate intranet.
This policy was approved by the Christie & Co Sub Committee on [date] and is issued on a version controlled basis under the signature of the Chief Executive Officer (CEO).
Change History Record
|Issue||Description of Change||Approval||Date of Issue|
|1||Initial issue||George Papavgeris (DPO)||28/11/2017|
|2||Christie Group ref added||George Papavgeris (DPO)||24/1/2018|
|3||Simplify 1.8 & 1.9||George Papavgeris (DPO)||8/5/2018|