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Smethurst Sales & Lettings

Privacy & Data Policy

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Privacy & Data

How we store, protect, and — when the time comes — delete your personal data. We hold identity and financial documents as part of buying property, so we take data retention and your rights seriously.

Security

Encryption at rest & in transit

All data is encrypted on our managed platform (SOC 2 Type II & ISO 27001 certified). Identity documents and proof of funds are stored as encrypted files, not embedded in records.

Access controls

Staff access is role-based and authenticated. Two-factor authentication is available and required for staff with access to compliance data.

What we hold

  • Identity documents (passport / driving licence) for AML verification
  • Proof of funds evidence
  • Contact details and investment criteria
  • Property viewing reports and offer correspondence
  • Conveyancing case documents and solicitor correspondence
  • Portfolio and ownership records for managed properties

Retention schedule

Data categoryRetention period
Active client & investor recordsLife of the relationship, then up to 6 years
AML / KYC records (ID verification, proof of funds, PEP & sanctions screening)5 years after the end of the business relationship
Property & transaction documents (contracts, completion statements)6 years
Marketing contact data (with consent)Until consent is withdrawn; suppressed & purged after 24 months of no engagement
Lost or dead deal recordsPersonal data purged after 2 years of no activity
Website / contact-form leads that never convertPurged after 12 months
Audit logs5 years
Deleted records (any entity)Recoverable for 30 days, then permanently deleted

When a retention period ends, the record is deleted and remains recoverable for 30 days, then permanently removed.

Your rights

Erasure (right to be forgotten)

Ask us to delete your personal data, subject to regulatory retention above.

Data export

Receive a copy of the personal data we hold about you.

Rectification

Correct inaccurate or incomplete personal data.

Withdraw consent

Stop marketing at any time — we'll suppress your record.

Submit a data request

We action requests within one calendar month. Use this form to request deletion, export, or correction of your data.

Questions about your data? Email us or raise a request above. You also have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk.

This policy is reviewed at least annually. Last updated: July 2026.