Clevedon Salerooms take your privacy seriously and is committed to protecting your personal data in accordance with the 2018 General Data Protection Regulations (GDPR). This policy is designed to inform you in an accessible manner how we achieve this.
We would ask that any questions relating to GDPR are directed in the first instance to info@clevedonsalerooms.com
Postal Address: Clevedon Salerooms Ltd, The Auction Centre, Kenn Road, Kenn, Clevedon, BS21 6TT
Company Registration Number: 05786037
Telephone: 01934 830111
Please keep us updated about any changes to your information that we use and rely on.
The GDPR place strict limits on the reasons that a business can hold your personal data. For the large majority of our customers, the data we hold is as a result of our direct contractual relationship, and under GDPR, no express consent is required. Below is guide to the various categories of relationships that we have with our customers and how we use your Data in each category. Some of our customers might interact with us in only one category whereas other customers might have dealings with us in all five categories.
Contractual basis to hold personal data
We store the data of Vendors consigning goods to auction, as well as the data provided by potential Vendors that we interact with prior to an agreement to consign, so that we can record who is instructing us and their authority to do so. We need to be able to communicate with our Vendors through a variety of means including email, post and telephone to notify our Vendors before and after the auction process and to forward auction proceeds.
Legal and reporting basis to hold personal data
In addition to our contractual basis, we also have legal and reporting obligations to hold data which extend beyond the time that our immediate contractual relationship is fulfilled, (i.e. after the time we have sold the items consigned to us.) The legal and reporting basis includes retaining data for money laundering regulations, reporting to HMRC and potential claims against ownership and proof of title.
Contractual basis to hold personal data
Bidders registering their personal data with us prior to auction are entering a contract to be bound by the Conditions of Sale, whether they are successful at a particular auction or not. This data is therefore held on a contractual basis as we need to be able to communicate and notify bidders of purchases and for invoicing purposes.
Legal and reporting basis to hold personal data
The legal and reporting basis includes retaining data for money laundering regulations, reporting to HMRC and potential claims against ownership and proof of title.
Clevedon Salerooms are regularly instructed to provide certified valuations for a number of purposes including Inheritance Tax Valuations, Insurance Valuations and Current Market Valuations. These instructions may come from individuals as well as institutions such as Solicitors or Banks administering an Estate for Inheritance Tax Purposes. This highly sensitive data is securely stored off line and is retained as part of our contractual relationship with you, and also for legal purposes including money laundering, HMRC and ownership/title claims.
Certified current market valuations compiled for Inheritance Tax and Insurance valuations are not automatically erased after seven years . This is because this data can prove invaluable at a future time to the individual, their relatives or an institution that originally instructed us. This could be due to the original copies belonging to the client having been mislaid or lost. The data that we hold can provide evidence of value and also of ownership at a particular point in time which may have tax implications and can be beneficial to those who have a valid right to access this information. However, since we do not have a contractual or legal obligation to hold this data beyond seven years, a request to delete the data received from an individual or institution with authority to make the request will be actioned.
Clevedon Salerooms require your express consent before communicating with you on any type of marketing material that is not part of our contractual basis for contacting you. Examples of these might include our auctions alerts and newsletters which both require you to sign-up. Consent can be withdrawn at any time and we will remove your data. Opting out of consent for marketing purposes will not automatically apply to personal data that we may hold that relates to our contractual and legal obligation to hold data. In other words, if you have had business dealings with us as a Vendor or Purchaser within the last seven years and requested email auction alerts, but now no longer wish to receive these email alerts, we will delete your data from this marketing database, but will continue to hold the contractual data for up to seven years.
Clevedon Salerooms will only ever share your data with a third party in very limited circumstances directly relating to the fulfilment of our contractual obligations to you, and NEVER for any kind of marketing purposes. We require that any business that we share your data with will respect the privacy of your data and are GDPR compliant. Examples of a situation where we might share your data with your permission would be when instructing a specialist haulage contractor to collect items from a property to be delivered to the Saleroom. Our I.T. providers and Website providers are aware of their obligations under the GDPR.
All of our customers can ask to be shown a copy of all the data that we hold on them and where we are satisfied that the request is valid, we will provide the information in a timely manner.
Client confidentiality has always been an important aspect of the auction and valuation business. We would remind our customers of the often sensitive nature of much of the information we might hold, for example, an Insurance Valuation detailing the contents of a property, or the data relating to items that we have sold on behalf of an individual. We ask that anyone making a Subject Data Request understands that we have a duty to satisfy ourselves that the person asking for access to the data has a right to receive it and therefore we may have to make our own enquiries to ensure that the Subject Data Request is valid.
May 2018