Wates Group Limited and all its subsidiaries (“Wates”, “we”, “us”) are committed to protecting the privacy and security of those we interact with. We recognise the need to respect and protect information that is collected by us or disclosed to us.
This notice is intended to tell you how we collect and use information about you during and after your relationship with us, in accordance with the UK General Data Protection (“UK GDPR”), the Data Protection Act 2018 (the “DPA18”) and all other data protection legislation and regulation that is in force in the United Kingdom at the relevant time (together the “Data Protection Laws”).
This policy applies where we collect and process your Personal Data through your use of our website, when we provide services to you (or the owner or manager of the building you live in), when you or your employer purchase services from or provide services to us, or otherwise when you contact or deal with us.
This policy may be read in conjunction with supplementary policies relevant to specific processing of Personal Data. Where this is the case, we will notify you and provide you with a copy of the relevant supplementary policy.
Our website is not intended for children, and we do not knowingly collect data relating to children.
1. Who are we?
Wates Group Limited (“Wates”, “we”, “our”, and “us”) is a family owned Construction, House Building, Maintenance, Building Services and Facility Management Services company. As a leader in our chosen markets, our objective is to deliver excellent services for our customers, resulting in safe, fair and professional contracting services at all times.
We are committed to handling Personal Information fairly, lawfully and in a transparent manner, and we take our data protection obligations seriously. We ensure that Personal Information is processed in compliance with applicable Data Protection Laws.
We are a “data controller”. This means that we are responsible for deciding how we hold and use Personal Information about you. We are required under Data Protection Laws to notify you of the information contained in this Privacy Notice.
In some circumstances, such as where we provide facilities management services, we may process your Personal Information for and on behalf of a third party, such as your landlord or property management company. We may also process your personal data on behalf of our clients for the purpose of providing our services to those clients. Where this is the case, this privacy notice does not apply to that processing, and you should consult with the relevant third party for information about how your Personal Information will be used by that third party (including by us on their behalf).
2. What personal information does Wates collect about you?
For the purposes of this Privacy Notice “Personal Information” consists of any information that relates to you and/or information from which you can be identified, directly or indirectly.
We collect, use, store and transfer different kinds of Personal Information about you. The precise Personal Information listed below that we collect and use will vary depending on our relationship with you.
- Identity Data: which is your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, photograph (where you have attended an event or site opening) and (where you are the representative or employee of a business or organisation) your job title and the name of that business or organisation.
- Contact Data: which is your billing address, and business or personal contact information which is your address, email address and telephone numbers.
- Financial Data: is your payment details.
- Transaction Data: which is details about payments to and from you and other details of services purchased from us, or call recordings where you contact us in relation to our services.
- Technical Data: is your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data: is your username and password, or other similar identifier.
- Usage Data: is information about how you use our website and services.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Information but is not considered Personal Information in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data (or other data which does not on its own identify you) with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this privacy policy.
We do not generally collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data), or information about criminal convictions and offences, for the purpose of providing our services. In the event that we do collect or use such data, we will notify you and provide you with relevant information at the time.
3. How is your personal information collected?
We use different methods to collect data from and about you as follows:
- Personal Information you provide directly – You may give us your contact, identification details and financial data by filling in forms or corresponding with us by phone, email, post or otherwise. Please note that from time to time we also use call recording for training and quality purposes. You will be notified at the time if this is the case.
- Automated technologies or interactions – In some cases, we may collect information about your system and website usage by using cookies, server logs and other similar technologies.]#
- Third parties or publicly available sources – We receive Personal Information about you from various third parties and public sources, such as Companies House and analytics providers such as Google. Wates uses an application called Stop/Go for the purpose of reporting safe and unsafe activities and practices on its sites. If you have visited one of our sites, information about you may be recorded in a report submitted to the application. If you would like further information about how we use your personal data when we use the Stop/Go application, please contact GDPR@wates.co.uk.
- Surveillance – We capture photographs or video images of you by way of CCTV in operation throughout Wates’ controlled sites and offices.
If you fail to provide Personal Information
Where we need to collect Personal Information by law, or under the terms of a contract we have with you or your employer, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you or with the manager or owner of the building you live in or your employer (for example, to provide you or your employer or the building manager/owner) with products or services). If this is the case, we may have to amend the contract (or delay or cancel provision of the affected product or service), but we will notify you if this is the case at the time.
4. How do we use your information?
We will only use your Personal Information when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you, your employer or your building owner or manager;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- Where we need to comply with a legal obligation;
- More rarely, we may need to use your Personal Information in order to protect your vital interests, for example we may need to disclose information regarding your health to the emergency services in the event of a medical emergency.
Generally, we do not rely on consent as a legal basis for processing your Personal Information, although we will get your consent before sending direct marketing communications to you via email or text message where the law requires. Where you provide consent for specific processing of your Personal Information (such as direct marketing), you have the right to withdraw your consent at any time by contacting us at GDPR@wates.co.uk or use the unsubscribe option at the bottom of our emails to you.
Purposes for which we will use your personal information
We have set out below, in a table format, a description of all the ways we plan to use your Personal Information, and which permitted legal basis we rely on to do so. Where the permitted legal basis is “legitimate interests”, we have also identified what those legitimate interests are.
Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Information where more than one ground has been set out in the table below.
| Purpose/Activity | Type of information | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you or your employer as a new customer. | (a) Identity (b) Contact | (a) Performance of a contract with you (b) Necessary for our legitimate interests (in order to perform a contract with your employer) |
| To deliver services to you, or your employer or building owner or manager, including: (a) Manage payments, fees and charges for those services (b) Collect and recover money owed to us (c) To provide customer support | (a) Identity (b) Contact (c) Financial (d) Transaction | (a) Performance of a contract with you (b) Necessary for our legitimate interests (in order to perform a contact with your employer) (c) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you, or your employer or building owner or manager, which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (in order to perform a contract with your employer or building owner or manager) (d) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage | Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, for training and quality purposes, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation, group restructuring exercise, or business disposal) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content to you | (a) Identity (b) Contact (c) Profile (d) Usage (f) Technical | Necessary for our legitimate interests (to study how our customers use our products and services, to develop them, to grow our business) |
| To use data analytics and to improve our website, products/services, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To prevent accidents on Wates’ controlled sites | (a) Incident | Compliance with a legal obligation |
| To make suggestions and recommendations to you about goods or services that may be of interest to you, or your employer or building owner or manager | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | Necessary for our legitimate interests (to develop our products/services and grow our business) |
| Promoting Wates’ business via general publications and social media platforms | (a) Identity | Legitimate interests: promotion of our business |
Marketing communications
Wates may use your Personal Information to provide you with email notifications and other communications, including surveys, by telephone or post (‘Marketing’) on the basis that such use is necessary for the purposes of the legitimate interests pursued by us, or where you have signed up to receive marketing and information from us, in order for us to perform our contract with you.
We will only send you Marketing, in accordance with your email and contact preferences or as you otherwise agree to. You have a right to object to this processing. If you wish to do so, please contact the Privacy Team by email: GDPR@wates.co.uk or use the unsubscribe option at the bottom of our emails to you.
We do not share Personal Information with third parties for the third parties’ marketing purposes.
We may also use your Personal Information to personalise and to target more effectively our marketing communications to ensure, to the extent possible, that any marketing-related correspondence is relevant to you.
To opt out of receiving marketing-related correspondence from Wates, please contact us or click “Unsubscribe” or text message (SMS) you receive from us.
Social media, promotional material and publications
From time to time we may wish to use photographs, film and quoted statements taken at organised events and that relate to you, on site or in our internal and external communications, including for example on our website, internal Intranet and in published articles. We may also wish to use the same information to promote our activities on social media platforms such as Twitter, Facebook and LinkedIn. We will obtain your consent before identifying you in any photograph, film or quoted statement. Where we use photographs, film or quoted statements that do not identify you, this is not Personal Information. However, please let us know if you have any objection to our use of such photographs, film or quoted statements (even if they do not clearly or specifically identify you) and we will take any concerns into account.
Please contact the us at GDPR@wates.co.uk for more information, to raise any objections or to withdraw your consent at any time.
Please note that once an article or promotional material is published and in circulation (for example in a brochure or a Tweet) it may be copied and used by others. If you ask us not to use a photograph, film or quoted statement that identifies you, we will comply with your request and will do our best to stop others doing so, but we cannot guarantee this.
We will make efforts to notify you when photography and/or filming for this purpose is taking place at an event or on site where it is likely that such images will be posted internally or externally so that you can make your preferences known to us in advance.
Combining Personal Information
We may combine the Personal Information that we collect from you (including information received from our affiliates) to the extent permitted by applicable law.
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with Wates.
5. To whom do we discuss your personal information and what do we do to keep your information secure?
We will only use your Personal Information for our internal business purposes. We do not sell any of your Personal Information to third parties. However, we may disclose your information to service providers (including companies who provide marketing services to us), email support services, regulators, HMRC, legal advisors, accountants and actuaries, and to all parts of the Wates Group.
We have put in place appropriate physical and technical measures to safeguard the Personal Information we collect in connection with our products and services. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality. However, please note that although we take appropriate steps to protect your Personal Information, no website, product, device, online application or transmission of data, computer system or wireless connection is completely secure and therefore we cannot guarantee the absolute security of your Personal Information.
6. International transfer of data
The Personal Information that we collect from you may be stored and processed in your region, or transferred to, stored at or otherwise processed outside the UK and European Economic Area (“EEA”), or in any other country where Wates or Wates Affiliates, subsidiaries or service providers maintain facilities.
By using or interacting with any of our products or services and/or providing us with your Personal Information, you acknowledge that we will collect, transfer, store and process your information outside of the UK. We will take all steps reasonably necessary to ensure that your Personal Information is kept secure and treated in accordance with this Privacy Notice and the requirements of applicable law wherever the data are located. Where we transfer your Personal Information outside the UK and EEA to other countries, we will ensure that appropriate transfer agreements and mechanisms (such as the EU Model Clauses) are in place to help ensure that our third party service providers provide an adequate level of protection to your Personal Information. We will only transfer your Personal Information outside the UK and EEA in accordance with applicable laws or where you have given us your consent to do so.
7. Data retention – how long we will store/keep your personal information
Wates retains Personal Information for as long as necessary to fulfil the purposes for which your Personal Information has been collected as outlined in this Privacy Notice unless a longer retention period is required by law. When your Personal Information is no longer required for the purpose it was collected or as required by applicable law, it will be deleted and/or returned to you in accordance with applicable law. Please refer to our Data Retention Policy or contact us if you would like further information.
8. Accessing your personal information and other rights you have
Wates will collect, store and process your Personal Information in accordance with your rights under any applicable Data Protection Laws. Under certain circumstances, you have the following rights in relation to your Personal Information:
- Subject Access – you have the right to request details of the Personal Information which we hold about you and copies of such Personal Information.
- Right to Withdraw Consent – where our use of your Personal Information is based upon your consent, you have the right to withdraw such consent at any time. In the event you wish to withdraw your consent to processing, please contact us using the details provided below.
- Data Portability – you may, in certain circumstances, request us to port (i.e. transmit) your Personal Information directly to another organisation.
- Rectification – we want to ensure that the Personal Information about you that we hold is accurate and up to date. If you think that any information we have about you is incorrect or incomplete, please let us know. To the extent required by applicable laws, we will rectify or update any incorrect or inaccurate Personal Information about you.
- Erasure (‘right to be forgotten’) – you have the right to have your Personal Information ‘erased’ in certain specified situations.
- Restriction of processing – you have the right in certain specified situations to require us to stop processing your Personal Information and to only store such Personal Information.
- Object to processing – You have the right to object to specific types of processing of your Personal Information, such as, where we are processing your Personal Information for the purposes of direct marketing.
- Prevent automated decision-making – in certain circumstances, you have the right not to be subject to decisions being taken solely on the basis of automated processing.
9. Enforcing your rights
If you wish to enforce any of your rights under applicable Data Protection Laws, then please contact us at GDPR@wates.co.uk. We will respond to your request without undue delay and no later than one month from receipt of any such request, unless a longer period is permitted by applicable Data Protection Laws.
Complaints
If you are concerned that we have not complied with your legal rights under applicable Data Protection Laws then please let us know by contacting us at GDPR@wates.co.uk. You may contact the Information Commissioner’s Office (www.ico.gov.uk) at any time which is the data protection regulator in the UK which is where Wates is located. Alternatively, if you are based outside the UK, you may be entitled to contact your local data protection supervisory authority.
10. Third-party links and products on our services
Our websites, applications and products may contain links to other third-party websites that are not operated by Wates, and our websites may contain applications that you can download from third parties. These linked sites and applications are not under Wates’s control and as such, we are not responsible for the privacy practices or the content of any linked websites and online applications. If you choose to use any third-party websites or applications, any Personal Information collected by the third party’s website or application will be controlled by the Privacy Notice of that third party. We strongly recommend that you take the time to review the privacy policies of any third parties to which you provide Personal Information.
11. Cookies
For information on what cookies are, how Wates and other third parties use them, and for details of how cookies can be disabled, please see our Cookie Policy https://www.wates.co.uk/cookie-policy/.
12. Changes to this Privacy Notice
It is also important that you check back often for updates to the Privacy Notice, as we may change this Privacy Notice from time to time. The “Date last updated” legend at the bottom of this page states when the Privacy Notice was last updated and any changes will become effective upon our posting of the revised Privacy Notice.
We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. We will provide this notice by email or by posting notice of the changes on our website or through any relevant Services.
13. Contact us / further information
The Head of Ethics and Compliance is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the Head of Ethics and Compliance using the details set out below.
Contact details
Full details are: Head of Ethics and Compliance, Group Legal, Wates Group Limited
Email address: GDPR@wates.co.uk
Postal address: Head of Ethics and Compliance, Group Legal, Wates House, Station Approach, Leatherhead, Surrey, KT22 7SW
If you have any questions regarding the collection, processing, or use of your Personal Information or if you wish to exercise any of your rights in relation to your Personal Information, please contact us.