123EPC ("We") are committed to protecting and respecting your privacy.

This policy (together with our terms of website use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

  1. 1.Definitions 

Data controller - A controller determines the purposes and means of processing personal data.

Data processor - A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person

Categories of data: Personal data and special categories of personal data

Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data - The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

  1. 2.Who are we?  

N. J. Devine is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: For all data matters contact .


  1. 3.The purpose(s) of processing your personal data 

We use your personal data for the following purposes:

To enable the creation of an Energy Performance Certificate and/or property Floor Plans

4. The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data:

We may have obtained your personal data from your Estate Agent.

5. What is our legal basis for processing your personal data?

  1. a)Personal data (article 6 of GDPR) 

Our lawful basis for processing your general personal data:

Consent of the data subject;


Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract

Processing necessary for compliance with a legal obligation


Processing necessary to protect the vital interests of a data subject or another person



Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller



  1. b)Special categories of personal data (article 9 of GDPR) 

We do not process special categories of data:

More information on lawful processing can be found on the ICO website.  

  1. 6.Sharing your personal data  

Your personal data will be treated as strictly confidential, and will be shared only with Elmhurst

  1. 7.How long do we keep your personal data?  

We keep your personal data for a period of 15 years in order to comply with EPBR.


  1. 8.Providing us with your personal data 

You are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so will have the following consequences : We will be unable to provide an EPC.

  1. 9.Your rights and your personal data 

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

  1. 10.Transfer of Data Abroad 

We do not transfer personal data outside the EEA.

  1. 11.Automated Decision Making 


  1. 12.Further processing 

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

  1. 13.Changes to our privacy policy 

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

  1. 14.How to make a complaint 

To exercise all relevant rights, queries or complaints please in the first instance contact N. J. Devine at

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.