Pacey Wingent Dickson Property Partnership Limited (trading as Pacey Wingent Dickson)
Last updated: 6 May 2026
1. About This Privacy Policy
Pacey Wingent Dickson Property Partnership Limited ("Pacey Wingent Dickson", "we", "us", "our") is committed to protecting your personal data. This policy explains how we collect, use, store and share personal data when you interact with us, whether through our website (https://www.pwdproperty.co.uk/), our offices, our marketing channels or our property services.
This policy is written to comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (PECR) and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017). It also reflects our obligations under the Estate Agents Act 1979, the Consumer Protection from Unfair Trading Regulations 2008, the Tenant Fees Act 2019 and the Immigration Act 2014 (Right to Rent).
2. Who We Are (Data Controller)
Pacey Wingent Dickson Property Partnership Limited (trading as Pacey Wingent Dickson) is the "data controller" responsible for your personal data.
- Registered office: c/o Russell & Co Partnership LLP, Station House, Station Approach, East Horsley, Surrey, KT24 6QX
- Registered in England and Wales
- Email: info@pwdproperty.co.uk
- Telephone: 01372 456 804
- Website: https://www.pwdproperty.co.uk/
- ICO Registration Number: ZB667490
- Property Redress Scheme membership: Property Redress Scheme (PRS)
- Client Money Protection scheme: Propertymark Client Money Protection (membership number C0139367)
We are registered with the Information Commissioner's Office (ICO) as required by law.
3. Whose Data We Collect
We collect personal data from a range of individuals, including:
- Property vendors (sellers) and prospective vendors
- Buyers and prospective buyers
- Landlords and prospective landlords
- Tenants, prospective tenants and tenant applicants
- Guarantors and referees provided in tenancy applications
- Visitors to our website and social media pages
- Subscribers to our newsletter or marketing communications
- Individuals who leave reviews or testimonials about our services
- Contacts at corporate clients, contractors and professional partners
4. The Personal Data We Collect
4.1 Identity and contact details
Name, title, date of birth, photograph (where provided), home and previous addresses, email address, telephone numbers.
4.2 Identification and verification documents
Copies of passport, driving licence, national identity card, utility bills, bank statements and other documents required for identity verification, Right to Rent and anti-money laundering (AML) checks.
4.3 Financial information
Proof of funds, mortgage in principle, source of funds and source of wealth declarations, deposit details, payment information for fees and rent, salary and employment details (for tenant referencing).
4.4 Property information
Details of the property you are selling, letting, buying or renting, including viewing history, offers made or received, valuations and survey information.
4.5 Tenancy referencing data
Employment details, credit history, previous tenancy history, landlord references, Right to Rent documentation, guarantor details where applicable.
4.6 Transaction and correspondence data
Records of viewings, offers, negotiations, communications (including emails, WhatsApp messages, letters and call notes), instructions to solicitors, contracts and signed documents.
4.7 Marketing and preference data
Your marketing preferences, search criteria, property alerts and feedback.
4.8 Technical and usage data
IP address, device identifiers, browser type and version, operating system, referring URLs, pages visited on our website, time spent on pages and other analytics data collected via cookies and similar technologies.
4.9 Special category data
We do not routinely collect special category data. In limited cases (for example where accessibility requirements are relevant to a property search) we may process this data with your explicit consent.
5. How We Collect Your Data
We collect personal data:
- Directly from you when you contact us, register on our website, request a valuation, register interest in a property, attend a viewing, make or receive an offer, apply for a tenancy or instruct us
- From third parties acting on your behalf, such as solicitors, mortgage brokers, accountants or other estate agents
- From public sources, including HM Land Registry and Companies House
- From property portals such as Rightmove and Zoopla when you submit an enquiry
- From referencing agencies and AML/ID verification providers
- Automatically when you visit our website (via cookies and similar technologies)
6. Why We Use Your Data and Our Legal Basis
Under UK GDPR we must have a lawful basis for processing your personal data. The bases we rely on are:
6.1 Performance of a contract or steps to enter into a contract
- Providing valuation, sales, lettings, property management and related services
- Arranging viewings, processing offers and progressing transactions
- Drafting and managing tenancy agreements, memoranda of sale and terms of business
6.2 Compliance with a legal obligation
- Carrying out customer due diligence (CDD) and AML checks under MLR 2017
- Reporting suspicious activity to the National Crime Agency (NCA) where required
- Carrying out Right to Rent checks under the Immigration Act 2014
- Protecting tenancy deposits with a Government-approved scheme
- Complying with HMRC, tax, accounting and audit requirements
- Complying with our obligations under the Estate Agents Act 1979 and the Consumer Protection from Unfair Trading Regulations 2008
6.3 Legitimate interests
- Promoting our services and properties through marketing and advertising
- Improving our website, services and customer experience
- Preventing and detecting fraud, securing our IT systems and protecting our business
- Managing relationships with clients, contractors and suppliers
- Sending service updates to existing clients about similar services
We carry out a balancing test before relying on legitimate interests. You have the right to object: see Section 10.
6.4 Consent
- Sending marketing emails to individuals who are not existing clients
- Setting non-essential cookies on your device
- Processing any special category data (such as accessibility information)
- Sharing your details with selected partners for non-essential services such as Muuvo
You can withdraw consent at any time without affecting the lawfulness of processing carried out beforehand.
7. Who We Share Your Data With
We share your personal data only where necessary, and only with parties who provide adequate guarantees of data protection. The categories below explain the main third parties we work with.
7.1 Property software, platforms and tools
- Loop (Reapit): our customer relationship and property management system. Loop holds contact details, viewing records, offers, instructions, tenancies, accounts and progression notes.
- DocuSign: used to issue and collect electronic signatures on tenancy agreements, terms of business, memoranda of sale and other contractual documents.
- WhatsApp for Business (Meta Platforms Ireland Limited): used for client and applicant communications. Messages are end-to-end encrypted between devices, but Meta processes message metadata.
- Our offer system: used to log, track and communicate offers between buyers, sellers, landlords and tenants and to maintain a clear audit trail in line with the Estate Agents Act 1979.
- Muuvo: a free home-move service that helps buyers and tenants set up utilities, council tax, broadband, insurance and related services. Where you choose to use Muuvo, we share your name, contact details and basic move information so they can contact you with relevant deals. You can opt out at any time by contacting us or Muuvo directly.
7.2 Property portals
- Rightmove: for listing properties for sale and to let.
- Rightmove Plus: the agent platform we use for market data, comparable evidence and lead management.
- Rightmove Tenancy Applications and Tenancy Manager: where applicable, used to receive, process and manage tenancy applications, referencing and ongoing tenancy administration.
- Zoopla: for listing properties and receiving applicant enquiries.
When you submit an enquiry through these portals, your data is shared with us under the portal's own privacy terms. Once received by us, it is processed under this policy.
7.3 Identity verification, AML and onboarding
We are legally required under MLR 2017 to verify the identity of buyers and sellers (and in some cases tenants and landlords). We use a third-party AML and identity verification platform, referred to in our communications as "our portal", to securely capture, verify and store ID documents, proof of address, source of funds and source of wealth information.
7.4 Tenant referencing
For tenancy applications we instruct referencing agencies to verify identity, employment, income, credit history and previous landlord references. Where a guarantor is required, the same referencing process applies to them.
7.5 Contractors and suppliers
Where works, inspections, inventories, EPCs, gas safety checks, electrical inspections (EICR), cleaning, maintenance or other property-related services are required, we share the minimum personal data needed (typically a name, contact number and property address) with the relevant contractor.
7.6 Solicitors, mortgage brokers, surveyors and conveyancers
With your knowledge, we share contact and transaction details with the professionals required to progress your sale, purchase or letting. Where we recommend a third party, you are always free to instruct your own.
7.7 Marketing and advertising platforms
- Meta (Facebook and Instagram): we run advertising campaigns and may use Custom Audiences and the Meta Pixel on our website to measure and target campaigns.
- LinkedIn: used for B2B marketing, recruitment and brand awareness, including the LinkedIn Insight Tag where deployed.
- Google Ads and Google Analytics: used for online advertising and to understand how our website is used.
- Google Business Profile (Google My Business) and Google Reviews: where you leave a public review, your name (or chosen display name) and review content will be visible online. Reviews are governed by Google's own privacy and content terms.
7.8 Live chat and contact forms
Messages submitted via our website chat or contact forms are stored in our systems and may be processed by the live chat provider that powers the service.
7.9 Banks, deposit schemes and government bodies
- Tenancy deposits are protected with the Tenancy Deposit Scheme (TDS), a Government-approved tenancy deposit protection scheme.
- We may share data with HMRC, local authorities, the police, the NCA and other regulators where legally required.
- We are members of the Property Redress Scheme (PRS) and may share data with them in the event of a complaint.
7.10 Professional advisers and insurers
Including our accountants, auditors, legal advisers and insurance providers, where strictly necessary.
We will never sell your personal data.
8. International Transfers
Some of our service providers (including Meta, Google, DocuSign, Microsoft and certain referencing platforms) may process personal data outside the United Kingdom. Where personal data is transferred outside the UK, we ensure appropriate safeguards are in place, such as:
- A UK adequacy decision covering the destination country
- The International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses
- Other lawful transfer mechanisms recognised by the ICO
You can contact us at info@pwdproperty.co.uk for more information or a copy of the relevant safeguards.
9. How Long We Keep Your Data
We keep personal data only for as long as necessary for the purposes for which it was collected, and to comply with our legal and regulatory obligations.
Indicative retention periods:
- AML and CDD records: at least 5 years from the end of the business relationship or transaction (MLR 2017)
- Sales and lettings transaction records: 6 years from the end of the relevant tax year (limitation periods and HMRC requirements)
- Tenancy records: 6 years after the end of the tenancy
- Failed applications and unsuccessful enquiries: typically 12 months, unless you ask us to retain them for longer
- Marketing data: until you withdraw consent or object, with a periodic review
- Website analytics: in line with Google Analytics retention settings (typically 14 months)
- CCTV footage at our offices, if any: typically 30 days
After these periods we will securely delete or anonymise your data.
10. Your Rights
Under UK data protection law you have the following rights:
- Right to be informed: through this policy
- Right of access: to obtain a copy of the personal data we hold about you (a "subject access request")
- Right to rectification: to correct inaccurate or incomplete data
- Right to erasure: to ask us to delete your data, subject to legal obligations (for example, AML records we are required to retain)
- Right to restrict processing: in certain circumstances
- Right to data portability: to receive certain data in a structured, machine-readable format
- Right to object: to processing based on legitimate interests, including direct marketing
- Right to withdraw consent: where we rely on consent
- Right not to be subject to solely automated decision-making: we do not currently make decisions about you using automated processing alone
To exercise any of these rights, please email info@pwdproperty.co.uk. We will respond within one calendar month. We may need to verify your identity before acting on a request.
If you are unhappy with how we have handled your personal data, please contact us first so we can try to resolve the issue. You can also lodge a complaint with the Information Commissioner's Office at https://ico.org.uk/, by telephone on 0303 123 1113 or by post to Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
11. Marketing
We will only send you marketing emails or SMS where you have consented or where the law otherwise allows (for example, you are an existing client and we are marketing similar services under the "soft opt-in" rules in PECR). You can opt out at any time by clicking the unsubscribe link in our emails, replying STOP to a marketing SMS or contacting info@pwdproperty.co.uk.
We may show you targeted adverts on Facebook, Instagram, LinkedIn and Google based on data you have shared with us or your interaction with our website. You can manage these preferences within the settings of each platform.
12. Cookies and Tracking Technologies
Our website uses cookies and similar technologies, including Google Analytics, the Meta Pixel and (where applicable) the LinkedIn Insight Tag. These help us understand how the website is used, measure advertising effectiveness and improve user experience.
You can accept, reject or manage cookies via the cookie banner displayed when you first visit our website, and you can change your preferences at any time. Full details of the cookies we use are set out in our Cookie Policy.
13. How We Protect Your Data
We use a range of technical and organisational measures to keep your data secure, including:
- Encrypted data transfer (HTTPS) on our website
- Role-based access controls within our systems
- Two-factor authentication where supported by the platform
- Secure storage and disposal of physical documents
- Staff training on data protection and confidentiality
- Vendor due diligence and written data processing agreements with our key suppliers
No system is ever completely secure, but we work to reduce risk and respond promptly to any incident. We will notify the ICO and affected individuals of any personal data breach where required by UK GDPR.
14. Children's Data
Our services are not directed at children. We do not knowingly collect personal data about children under 16. Where children's details appear on a tenancy or sale (for example, occupants of a household), we collect only the minimum information needed.
15. Third-Party Websites
Our website may contain links to other websites. We are not responsible for the privacy practices of these websites and recommend you review their own privacy policies before submitting personal data.
16. Changes to This Privacy Policy
We may update this policy from time to time to reflect changes in law, our services or our practices. The "Last updated" date at the top of this policy will always show when it was last revised. We encourage you to review this page periodically.
17. Contact Us
If you have any questions about this Privacy Policy or your personal data, please contact us:
Pacey Wingent Dickson Property Partnership Limited (trading as Pacey Wingent Dickson)
Email: info@pwdproperty.co.uk
Telephone: 01372 456 804
Website: https://www.pwdproperty.co.uk/
This Privacy Policy was last updated on 6 May 2026.
