White Rose Homes Ltd
Matrix@ Dinnington Business Centre
Nobel Way
Dinnington
S25 3QB
Tel: 07525 800 384
Website: www.whiterosehomes.co.uk

Accountability: Danny Wigglesworth
Responsibility: Danny Wigglesworth
Last Review date: 17/12/2019 Next Review due: 17/12/2021
Version: 1
Law/Regulations covered: Policy & Electronic Communications Regulations (amended 2016)
General Data Protection Regulations
Data Protection Bill 2018

1. Overview

This Policy covers the data collected and processed by White Rose Homes Ltd who can be contacted at:
White Rose Homes Ltd
Matrix @ Dinnington Business Centre
Nobel Way
Dinnington
S25 3QB
Tel: 07525 800 384
Website: www.whiterosehomes.co.uk

White Rose Homes Ltd is the Data Controller of the personal data we process on our own behalf and
the Data Processor of data processed on behalf of our clients. We have a legal duty to protect the
privacy of all, personal and business data obtained from you while you are using our website, as well
as in the provision of our services to you. This Privacy Policy explains what information we may
collect from you and the purposes for which it will be used. This Policy complies with all current data
protection and privacy regulations in the UK, including, but not limited to, the General Data
Protection Regulations (the GDPR) and the Privacy and Electronic Communications Regulations (the
PECR).

The GDPR relates to ‘personal data’ which covers any information which makes an individual (the
Data Subject) identifiable.

2. Purpose of and Legal Basis for Processing Personal Data

White Rose Homes Ltd will only process personal data for the purposes of delivering the services
contracted by our clients, unless we are provided with specific consent to process for other
purposes, such as marketing, or the purpose of complying with local laws or regulations. Personal
data will never be processed without the knowledge and/or permission of the Data Subject.
By using our services, including accessing our website and the forms, etc. therein, you give your
agreement to our processing any personal data we may have as described in this policy.

3. Types of Personal Data Processed

Personal Data is any information which could potentially make an individual identifiable and can
include, but may not be limited to, your name, address, date of birth, email address and IP address.
We collect data in a number of ways including, but not necessarily limited to:

• Contact forms on our website completed and submitted by a Data Subject
• As part of a Contract for Services, i.e. names and contact information of individuals, including
  where they are acting on behalf of a client company
• Provided to us by clients in order that we can deliver the services they have contracted us for

Our contact forms make it clear that the information will be used for the purposes of the contact
(e.g. to respond to a query or provide a quote, etc.) but also provide the option for consent to
expand the processing of that data for marketing purposes. Similarly, any contract for services will
set out what the personal data will be used for.

Personal Data provided to us by our clients as part of our service provision will be processed only in
accordance with the contract for services and no such data will be used for the benefit of White Rose
Homes Ltd.

4. Our Website and Cookies

4.1. Who manages our website?

The content of our website is owned and edited by White Rose Homes Ltd/ADM Marketing Ltd and
Serif Systems Limited.

4.2. Website usage information

Web usage information is collected by our web server and from other sources including page tagging
techniques using e.g. Javascript, Cookies, etc. We use cookies to analyse website usage trends,
understand user journeys and gather broad demographic information for aggregate use. Our cookies
are not linked to personally identifiable information and we do not collect, store or process the IP
addresses of visitors browsing our website.

The type of website usage information that we collect during your visits to our site includes, for
example, the date and time, pages viewed or searched for, guides printed, tools used, some
truncated postcode or telephone area code information entered on forms (which is not traceable
back to you) and other information relating to your usage of our website.

We may also use web usage information to create statistical data regarding the use of our website
and we may then use or disclose that statistical data to others for marketing and strategic
development purposes, however, no individual identities will or can be identified in such statistical
data.

4.3. Cookies

Cookies are small pieces of data given to your browser by a website which may be stored as text files
in the cookie directory of your computer. Cookies are not programs and cannot collect information
from your computer. They do not damage your computer and are defined as “a piece of text stored
on a user’s computer by their web browser. A cookie can be used for authentication, storing site
preferences, shopping cart contents, the identifier for a server-based session, or anything else that
can be accomplished through storing text data” (source: Wikipedia, 2011).

Each website may send cookie data to your browser which may save it if your browser’s preferences
allow it to do so. To protect your privacy your browser only returns a cookie to the website that sent
you the cookie and does not send it to any other website. A website cannot access your cookie
directory or information on your computer, instead relevant cookies are included by your browser
within each request you make to the website. A website can only obtain cookie data that your
browser sends to it.

You do not have to accept cookies and you can change the settings within your browser to accept
all cookies, reject all cookies, reject cookies from certain websites, notify you if a site is requesting
to set a cookie, and set various other options. Please see below in ‘4.4 Further information about
cookies’ for more details on how you might do this.

Switching off cookies will still allow you to view the majority of content on our site, however, it will
prevent you logging in and so accessing personalised information. It will also stop us remembering
your login User ID, if you ask us to do so, and may restrict your use of our interactive tools and of
some services available through linked sites.

4.4. Further information about cookies

If you would like to opt out of, or restrict the use of cookies when visiting our, or any other third
party’s website, you are able to adjust the sefngs in your Internet browser to do this. Exactly how
this is done will depend on which browser you use for access to the Internet. Each browser has its
own variation on how this can be achieved, but it is usually under ‘Settings’ which can be found at
the end of the Search bar.

Users should check their Internet browser for details of how to amend, remove or restrict the use of
cookies on their computer, tablet or other internet enabled device.
For further information about cookies, please refer to the Information Commissioner’s website.

5. Information sharing and disclosure

We may share your data with specified third parties for the purposes of supplying the services you
have contracted us for or if required to by law or by a regulation based on a law. We will not sell, rent
or disclose your information to any third parties other than those set out in this privacy policy
without your prior consent.

We do not transfer your personal data outside of the UK and the European Economic Area.

We may transfer your personal data outside of the UK for the purposes of backing up data to a cloud
server hosted by Amazon Web Services (AWS) who are based who are based at 410 Terry Avenue,
North, Seattle, WA 98109-5210, U.S.A. however your personal data is kept encrypted at all times so
that it cannot be read by the service provider. All personal data is still under the remit of the GDPR,
regardless of our use of storage outside the UK and the EEA.

6. Retention of Data

Personal Data will always be held for the minimum amount of time required. This will depend on a
number of factors, such as the terms and length of a contract or a relevant law or regulation based
on law. It will be deleted a maximum of 12 months after such a period has ended under our semiannual
data clearance procedures. Personal Data that has been gathered via our website contact
forms will be held for a maximum of 12 months aoer the initial contact, unless additional permission
is obtained from the Data Subject or a contract for services is brought into force in the interim.

Electronic Personal Data is encrypted and held in a secure manner on physical and cloud-based
services. The encrypNon used meets all current requirements for encrypted services and is updated
regularly to ensure that it remains fit for purpose. Electronic data is deleted following a secure
process to ensure there is no lapse in security at the point of deletion.

7. Your Rights

Under current legislation, Data Subjects have the following rights:

• To be informed – This policy is one of ways in which White Rose Homes Ltd informs you how and
  why we process your data
• Of Access – All Data Subjects have the right to quest access to all of the data we hold on them.
  Any Data Subject requests received will be reviewed and responded to within one calendar
  month of receipt of the request. Most requests will be fulfilled free of charge, however White
  Rose Homes Ltd reserve the right to charge a reasonable administration fee for any requests
  deemed to be excessive, unfounded or repetitive.
• Of rectification – Should you find that any data we hold about you is incorrect, you can ask us to
  correct it and we will investigate and respond within one calendar month of receipt of the
  request.
• Of Erasure – You can ask for your Personal Data to be erased permanently. All such requests will
  be responded to within one calendar month of the receipt of a request. Please note that, whilst
  we will always endeavour to fulfil requests, there may be some instances were this is not possible
  due to legal or regulatory reasons. We will always provide a full explanation in any such
  instances.
• To restrict processing – If you do not wish for your data to be erased, you may ask for it to be
  restricted so that we continue to hold it but not process it or use it in any way – we would
  essentially ‘archive’ your data. This is only applicable in certain circumstances, however we will
  look at all requests and respond within one calendar month of the receipt of a request.
• To data portability – All electronically held data can be transferred to another company in a
  structured, commonly used and machine readable format on request. Please note that this will
• only include the data you have provided to us and not any ancillary data produced as a result of
  the services we have created during the provision of our services or where that data includes
  information regarding a third party. All requests for moving data will be responded to within one
  calendar month of a request being received.
• To Object – You can object to our processing data for the purposes of marketing, scientific/
  historical research and statistics, or legitimate interests or in the performing of a task in the
  public interest /exercise of official authority (including profiling). All such requests shall be
  responded to within one calendar month
• Rights related to automated decision making, including profiling – The GDPR sets out specific
  rights in relation to automated decision making. Please note that White Rose Homes Ltd does not
  use any form of automated decision making system whilst processing your data.
• To complain – You have the right to raise a complaint regarding the processing of your data or
  our response to a request under the above rights. As part of this, you also have the right to
  escalate your complaint to a supervisory authority. In respect of data handling, you have the right
  to escalate your complaint to the Information Commissioners Office (ICO).
  Please go to https://ico.org.uk/for-the-public/raising-concerns/ for full details.

Data Subjects have the right to withdraw their consent to our processing their data at any time.
In respect of any of the rights indicated above, if you would like to make a request, require further
information, or have a complaint regarding our processing of your data please contact us at:

White Rose Homes Ltd
Matrix @ Dinnington Business Centre
Nobel Way
Dinnington
S25 3QB
Tel: 07525 800 384
Website: www.whiterosehomes.co.uk

8. Changes to this policy

We may make changes to this privacy policy at any time. Changes will be posted on our website and
are effective immediately, except where they relate directly to a contract for services where all
changes will be subject to the agreements in that contract. Regularly reviewing this Policy ensures
that you are always aware of what information we collect, how we use it and under what
circumstances, if any, we will share it with other parties.

© White Rose Homes Ltd Pol COM
V1 17/12/2019