Updated 14th July 2022
Who we are: Our website address is: www.firststep.ltd
Privacy & Cookies
This is the privacy statement for First Step Estate Agents. Please read it carefully. You should only use this site and complete our Contact and Newsletter Sign-up Form if you agree to our use of information about you in accordance with this privacy statement.
Protecting your personal data
We’re committed to protecting you and your family’s personal data and information. This policy applies to any personal information or “personal data” that we collect from you. It covers how we:
- Destroy/Remove your personal data
Please read this policy carefully. By using any of our websites, and any services we offer via our websites, you are agreeing to the processing of your data as set out below. We sometimes use your data to provide additional marketing services but you can always opt out. For more information, see section 6 Contacting you for marketing purposes below.
1. Introducing First Step Estate Agents – their current working Partners
First Step Estate Agents include:
- First Step Residential
- First Step Lettings
- First Step Land
- First Step New Homes
- In addition, we act on behalf of a number of Joint Ventures, in which we hold a material interest.
- The Data Protection Act 1998;
- The GDPR – General Data Protection Regulations; and
- Any regulations made under or to supplement either of the above, relating to the personal information that we collect about you.
In this policy, “we” refers to all of the above.The First Step website is operated by a third party on First Step.
2. Our commitment to you
We are committed to safeguarding your personal information and we comply with all data protection laws including –
3. When do we collect personal information about you?
We may collect personal information when you:
- Visit/access one of our websites or platforms
- Contact us by telephone, email, SMS, letter or any other form of messaging
- Visit any of our sites or office
- Complete any of our website forms
- Apply for employment
- Access information about our developments and/or new homes via a third- party provider, such as a property portal e.g. Rightmove or others
- Whenever you enter into any transaction with us, whether it’s in person or any other way
- If you request information from us with a view to entering into a transaction with us.
This may include for example your:
- Email address
- Postal address
- Telephone or mobile number
As well as information about:
- Your use of our website
- The purpose of your visit to our website or the reason you made contact with us
This policy also covers our use of any of your personal information, whether provided to us in person, over the phone, via email, SMS or any social messaging, via website forms, property portals or in other correspondence.
Requests for additional information
Sometimes we will require you to provide further personal information. This may be if you are purchasing or thinking about purchasing a home from us, or if you ask us to contact you with properties/developments that may be of interest to you. Whenever we do this, we will tell you why we are collecting this information and how we will use it.
Queries via social media
Our social media pages, such as Twitter and Facebook, are monitored by a third- party company. They pass any customer queries, questions or complaints onto the most appropriate person in our team, so that we can respond accordingly.
If you contact us online, we may monitor the type of device used by you. This may include specific identification, such as your IP address.
CCTV and call monitoring
Our developments and Sales Offices use CCTV to make sure we provide a safe and secure environment for all visitors to our premises and to ensure the protection of our employees and property.
We also record calls for training, monitoring and quality purposes to and from our Customer Services Helpline.
4. How will we use this information?
We do not sell “customer’s personal” data to third parties and will only use your personal information to provide you with details of our own products, properties or developments which we believe will be of interest to you. In addition, we may use your information to:
- Contact you if you have indicated a specific interest in a property/development, or a particular area in which we have properties/developments available.
- Provide a relevant service if you have contacted us for a specific purpose or accessed our services by completing a website form and not opted out. We’ll take into account your perceived preferences for a specific property type or location. In the event that you do not wish to receive this personalised service, you can unsubscribe from our emails or similarly contact us as set out in section 10 of this policy.
- Tailor our service to your location. With your permission, Rightmove or other external portals may use your IP addresses and device identifiers to identify your location. We will use this for general, depersonalised statistical purposes. We may also use this information to direct you to specific developments/properties in your area.
- For legitimate purposes aligned with our contract.
- In relation to a previous communication from you. This includes any comment or complaint concerning us, our services, properties or developments, or any previous contact we may have had with you.
- If you requested further information or signed up to a product, property or development, whether directly through us or via a third-party provider, such as a property portal.
- If you have expressed an interest in a specific product, property or development.
- To provide you with additional information concerning a specific property/development, type of property/ development or similar properties/developments to those in which you have expressed an interest.
- For marketing purposes if you have chosen to receive a service from us by completing one of our website forms and not opted out, in accordance with this policy, see section 6.
5. Contacting you for marketing purposes
Please be rest assured that any personal information given to us for a specific use or purpose, will not be used for any other purpose, without your notification and (where appropriate) permission. See section 10.
6. When will we contact you?
We will only contact you for marketing purposes, via email, SMS or phone, if you have agreed to this or where you have requested a service from us and not opted out. You can easily unsubscribe from any of those sources at any time.
We will deem a service request to be any of the following:
Online appointment booking – using our appointment tool on the website to select a date and time to visit one of our developments. Arrange a viewing – to request a viewing. In this instance we will call you to arrange a suitable time for an appointment for you to visit one of our developments.
Call-back request – when you request us to call you back to find out more about one of our developments. Keep me informed – this is where you ask us to keep you updated on a development that has not launched yet (coming soon site).
Download brochure – when you request to download a brochure of one of our developments.Registration – when you register on our website with an account to store your searches, etc.
Information emails/SMS/phone calls
We offer regular information by emails, telephone and SMS communications concerning our properties and developments.
Tailoring our service to you
We may personalise our communications with you based on the information you provide to us and the information we obtain when you use our platforms.
We do not allow the information we hold about you to be used for advertising purposes or contact from third parties. However, if you show an interest in a specific property/development or type of property/development via a third-party website, such as a property portal, this is outside of our remit – we have no control over who else can contact you.
7. Keeping your information private
Your information will be kept private and confidential, except where we are obliged/permitted to share it with third parties by law (e.g. Government bodies, law enforcement agencies and similar).
We will retain your information within our group of companies, except:
At your request: If you have requested that we share the information with you or have given your permission.
- To fulfil our contractual/similar obligations to you: For example, in connection with any property you are in the course of purchasing or have purchased from us, or which you had previously sought to purchase from us.
This could include:
- To our solicitors, your solicitors or other advisers for the purposes of progressing a sale or dealing with any issue you may have.
- To a third party for the purposes of carrying out a survey in relation to your experience with us.
- With a consultant or a subcontractor appointed to carry out/required to carry out work to a property which you have purchased.
- To any of your advisers in connection with any contract or transaction entered into with us for the purposes of performance of our obligations.
- For statistical or similar analysis in relation to purchase or use of our properties, products or any service we provide.
Keeping you in the know
When you enter into a contract with us, we will set out, as comprehensively as possible, the purposes for which we may use your personal information in order to fulfil our contract with you and address any issues relating to our performance.
Whilst not sharing your personal information, we may use suitable and accredited third-party organisations specifically for the purpose of destroying or deleting any personal data.
8. Is there an age limit to who we can contact?
If you are under the age of 18, you should obtain your parents’ or guardians’ permission before you contact us. It is unlikely that we will be in a position to provide you with any information which may assist you, or be relevant to you, until you reach the age of 18 – this is simply because of the nature of the legal obligations you will enter into when purchasing a property or renting.
9. How long do we store your information?
This is dependent upon its purpose, or the amount of time set out in the contract you enter into with us.
Purchasing or renting a property: If you enter into a contract with us to purchase a property, we will hold your information for a maximum of 12 years from the date of completion of that purchase. Anti-money laundering: In the event that you provide us with personal information so that we can fulfil any anti-money laundering obligations, we will retain such information for a period of 5 years – this is to fulfil our legal obligations.
If you contact us: If you get in touch regarding any of our properties/developments or types of property/developments or the services we provide – whether we receive such contact directly from you or via a third party – we will retain your personal information until whichever of the below happens first:
- You request that we delete it: We will need to retain a record of your request to be deleted.
- A maximum period of 2 years: From the date that you last made contact with us – directly or via a third-party – in relation to any of our properties or developments.
- We will use all reasonable efforts to delete (aside from the note of your request to be deleted) all information in our possession which constitutes, in our reasonable opinion, personal data belonging to you.
10. Your rights
Deletion of personal data “Right to be forgotten”
It is your right to request the deletion of your personal data from our records, except (as explained above) if it is necessary for us to perform our legal obligations or contractual obligations to you or another third party.
Keeping your details accurate
You have the right to ask us to rectify any personal data we hold about you which is inaccurate or incomplete.
Sending a request
A request for the deletion or correction of personal data should be addressed to the Data Protection Manager at First Step Estate Agents at our registered office, or by email to firstname.lastname@example.org.
Please note that while we always strive to comply with any requests you make, we cannot guarantee to action any request for the deletion or rectification of your personal data if it is not made using the method outlined above.
What do we do?
Within reason, we will aim to make anonymous and/or delete any of the personal data which we hold in relation to you. It is in the nature of digital or computer records that we cannot guarantee that every trace or record of your personal data will be removed, but we will delete it as far as it is reasonably possible for us to do so.
Third party platforms
11. Finding out what personal information we hold.
Under the current Data Protection Act, you have the right to request a copy of any personal information we hold about you and to have any inaccuracies corrected.
At the present time, we charge £10.00 per request and we may require you to prove your identity (with two documents of approved identification) before searching our records. At the present time, the information will be provided to you within 40 days of whichever of the following comes last:
- The date of submission of your request
- Payment of the fee
- Establishment of your identity
Identification that we accept
The following are examples of the type of identification that we can accept in order to process your information request:
- Driving licence
- Birth or marriage certificate
- Utility bill (from the past 3 months)
- Current vehicle registration document
- Bank statement (from the past 3 months)
- Rent book or similar tenancy agreement (that covers the past 3 months)
Please note, if we have previously established your identity and it matches the information you provide, this may be sufficient for the purposes of actioning your request. If you have not previously provided us with identification, then we may require you to provide copy documentation of the examples listed above in order to process your request.
The amount we charge and the period of time in which we are able to action your request may alter by law. If so, this policy will be amended.
So that we avoid any delays to your application, please address any questions concerning our privacy and cookies policy to the Data Protection Manager at the registered office of First Step Estate Agents set out below or using the email address provided in this policy.
12. Accessing our platforms from outside the UK
Depending upon your location, different privacy rules may apply as a matter of law. These are presently harmonised within the EU, but you should note that any personal information that we use or process is done so in accordance with the law applicable in England, Wales or Scotland, as appropriate.
13. Web browser cookies
What is a cookie?
A cookie contains a small amount of data and (typically) a unique identifier. When you access any of our websites or platforms (or those of third-party providers) a cookie will be sent to your device. The cookie records information about your online preferences and therefore allows us to tailor our websites and any contact with you to your specific interests.
The information we obtain by monitoring all visits to our websites enables us to improve, through anonymous analysis, our services to our customers and visitors.
Your web browser may also provide us with information concerning your device, such as an IP address or details about the browser you are using. For example, if you are looking at a specific location or property, we may use your location to ensure that any web pages or communications are tailored to you.
Please note, you are able to change your cookies settings to control access to any device you are using.
Information about other websites
We cannot control any information concerning websites other than those operated by us. You must refer to those websites for their terms and conditions and privacy policies
14. Mobile applications
We occasionally release mobile applications to complement specific developments. Use of these mobile applications is set out in the terms and conditions, which you will need to accept in order to load and access the app on your device.
15. Changes to our privacy and cookies policy
We may make changes and update our privacy and cookies policy from time to time and in accordance with updated legislation. Any such changes will be shown here as part of our privacy and cookies policy and will apply from the date that they are published. We are unable to contact you directly to inform you of these changes, other than in response to a specific request made to our Data Protection Manager as referred to above.
16. Contacting us concerning our privacy and cookies policy.
Any contact you wish to make with us concerning this policy or how it works in practice should be directed to the Data Protection Manager. Please either write using the email address provided, or via post to our registered office:
First Step, Waterloo Farm, Stofold Road, Arlesey, Beds, SG15 6XP
Email our Data Protection Manager: email@example.com
- Platforms are the means by which we establish digital contact, including websites operated by us.
- IP addresses are specific to any device used. This could be a laptop computer, tablet or phone.
- Similar developments may include developments in similar locations. Properties may include other properties within our range, which we consider relevant based on previous contact with you.
Buy to let & Lettings – Policy
If you are buying, selling or letting a property through First Step:
- We will collect a contact telephone number to get in touch with you about organising viewings and updating you on any offers received or rental applications for your property
- Where you are not the legal owner of the property we will request details from you as to your ability to sell or let the property such as a Power of Attorney, Guardianship Order or Grant of Probate
- We will collect your bank account details to arrange onward payment of rent due to you
If you wish to rent a property we are listing:
- Specific access requirements so that we can find a property that is suitable for your needs
- Your bank / building / similar account details to allow us to manage an approved tenancy deposit account for you and to set up your rental payments
- If you are a tenant renting under the ‘Right to Rent’ scheme we will collect details of your Biometric residence card, your immigration status document and/or your birth certificate to carry out our required checks under this scheme
- If you wish to purchase a property we are listing for sale where you have specifically provided us with these, we will collect personal information relating to any specific access requirements you may have in relation to a property so that we can find a property that is suitable for your needs. We will also collect personal information required to source a property for you and, where required, negotiate the purchase of a property on your behalf.
Where we engage with you to manage property on your behalf, we will ask for additional emergency contact information in case we need to get in touch with you outside of working hours, or in the event there is a matter requiring your urgent attention. Where you engage us for portfolio management services, we will share your personal information with third party lenders/contractors as is necessary, to allow us to fulfil our obligations to you and to properly manage and advise you on your property investments.
Where you engage with First Step, we will collect information required to identify you to meet anti-money laundering and counter terrorist financing requirements. If the investor is an entity such as a company, trust or charity, we may need to collect personal information about the controllers and the beneficiaries of the entity.
If you subscribe to receive research, news or other market updates from us, then in addition to the above we will collect details about the sector in which you work and the type of content that you would like to receive.
How we use your personal information
What is the legal basis of our data processing?
Under data protection legislation 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:
• For employment-related purposes
• Where we need information to perform the contract we have entered into with you
• Where we need to comply with a legal obligation
• Where the processing is necessary for us to carry out activities for which it is in First Steps‘ legitimate interests (or those of a third party) to do so and provided that your interests and fundamental rights do not override those interests, including:
– Processing that is necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns. – This will include sending you marketing information 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 have the right to opt out of receiving this information at any time.
– Processing that is necessary to improve our knowledge of the real estate sector – This will include undertaking market analysis and research so that we better understand trends in the property sector and provide better knowledge along with more tailored and relevant services for our customers in the future.
Processing necessary for us to 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 and create a better understanding of you as a customer/tenant;
processing for administrative efficiency purposes such as where we outsource certain administrative functions to third parties who are specialised in such services;
processing for network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access, or to comply with a request from you in connection with the exercise of any of your rights outlined below.
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 it is needed in the public interest or for official purposes
We may process special categories of personal information and criminal conviction information in the following limited circumstances:
With your explicit consent, in which case we will explain the purpose for which the information will be used at the point where we ask for your consent.
How we use your personal information
For specific information on how your personal information will be used for the services you have requested from us, please select from any of the options below:
Buy to let, Selling, Letting, Renting
We use your personal information for the purposes of fulfilling our obligations to you to let or sell your property or, if you are a buyer or tenant, for the purposes of arranging a contract for sale or a lease for you.
If you are purchasing a property, we are acting as agents for the sale of or selling a property through us, we will share your personal information with your appointed solicitors and the solicitors acting for the other side of the deal as is necessary to facilitate the sale or purchase.
If you are renting a property, we are acting as letting agents of, we will share your personal data with third party referencing agencies for the purposes of the prevention and detection of crime, fraud and/or money laundering and checking your suitability to rent that property.
Where we are managing property on your behalf, we may need to pass your personal information from time to time on to third party contractors whom we have engaged to carry out maintenance on your properties.
Where you engage us for portfolio management services, we will share your personal information with third party lenders as is necessary to allow us to fulfil our obligations to you, to raise finance for you and to properly manage and advise you on your property investments.
Where you engage with First Step, we will collect and hold your personal data to maintain a register of investment holdings in order to comply with our Financial Conduct Authority requirements.
If you are obtaining mortgage brokerage services, we will disclose personal information that needs to be submitted lenders (and if you are a high value mortgage customer, private banks) in order to fulfil our obligations to seek funding options for you.
If you are an insurance customer, we will disclose information to be sent to a selected panel of insurance providers in order to obtain suitable options for insurance products for your requirements.
Other uses of your personal information
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 privacy notice.
We will share personal information with our regulators, governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our regulatory and legal obligations;
Where we use third party services providers who process personal information on our behalf in order to provide services to us. This includes IT systems providers and IT contractors as well as third party referencing or screening agencies for the purposes of the prevention and detection of crime.
We may share your personal information with any person working within First Step on a need to know basis to ensure we are able to perform our obligations to you.
We will hold your personal information on our client management systems, and use this to provide you with marketing information about similar services offered by First Step to those which you have engaged us to provide, which we feel you might find useful from time to time. You have the opportunity to opt out of receiving this information at any time.
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 need to know your contact information so that we can update you with information on viewings, offers and the progress of the sale;
• Where you have asked us to find you a property which meets certain access requirements, we may need to know some further details about your particular circumstances so that we can find you a suitable property;
• We also need some information so that we can comply with our legal obligations. For example, we may need identity 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.
How we keep your information secure
The security of information is very important to us and we have measures in place which are designed to prevent unauthorised access to your personal information including but not limited to:
• Our client files are stored on our secure client management systems. Access is restricted on our client systems to those within the business who are required to have access to your information for legitimate business purposes.
• All data is hosted in a specialised datacentre which have systems and protections in place to protect against both unauthorised access, and other external factors that could cause damage to, your personal data. There are strict access requirements in place and access is restricted to those absolutely necessary.
We ensure access to personal information is restricted to First Step employees and workers or other persons working within the First Step on a need to know basis. Training is provided to any of those First Step employees and workers who need access to personal information.
How long we keep your personal information
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 we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in case of a legal claim.
Your rights in relation to your personal information
You have a number of rights in relation to your personal information, these include the right to:
• Be informed about how we use your personal information
• Obtain access to your personal information that we hold
• Request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate
• Request that we erase your personal information in the following circumstances:
• If First Step 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
• If First Step is relying on consent as the legal basis for processing and you withdraw consent
• If First Step 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
• If the personal information has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation)
• If it is necessary to delete the personal information to comply with a legal obligation
• Ask us to restrict our data processing activities where you consider that:
- Personal information is inaccurate
- Our processing of your personal information is unlawful
- Where we no longer need the personal information, but you require us to keep it to enable you to establish, exercise or defend a legal claim
- Where you have raised an objection to our use of your personal information
- Request a copy of certain personal information that you have provided to us in a commonly used electronic format. This right relates to personal information that you have provided to us that we need in order to perform our agreement with you and personal information where we are relying on consent to process your personal information
- 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; and
Not be subject to wholly automated decisions which produce legal effects, or which could have a similarly significant effect on you.