Before adding a client to the movebutler platform, you must ensure they have consented to their personal data being shared with movebutler for the purposes of the transaction and any associated services.
If a client does not provide consent, their personal data must not be added to the platform. In these circumstances, you should consult your Money Laundering Officer (MLO) to determine the appropriate next steps.
Once a client has been added to the platform and is sent a Digital Onboarding or Online Biometric ID Verification invitation, they will be required to:
| Accept the movebutler Terms & Conditions. | |
| Accept the movebutler Privacy Policy. | |
| If completing an Online Biometric ID Verification, accept their information is being shared with Credas Technologies Ltd. | |
| If completing an Online Biometric ID Verification, accept the Credas Terms & Conditions before the verification can begin. |
Client Data Removal Requests
If a client contacts movebutler Product Support requesting that their personal data be removed, we will advise them to contact their estate agent directly.
This is because the estate agent is the data controller, while movebutler acts as the data processor. As a result, any request to delete client data must be submitted to us by the estate agent, not the client.
In addition, estate agents have a legal obligation under the Money Laundering Regulations to retain customer due diligence records, including AML checks, for at least five years after the end of the business relationship. For this reason, we do not process data deletion requests directly from clients, as doing so could prevent the estate agent from meeting their legal record-keeping obligations.
If an estate agent wishes to request the deletion of client data, they should contact Product Support, who will review the request in line with the agency's instructions and any applicable legal retention requirements.
Does a client have a contract with iamproperty / movebutler?
movebutler is an estate agency tool provided by iamproperty.
When you use movebutler, you are the data controller and movebutler acts as your data processor for the information you enter into the platform.
Your client does not have a contractual relationship with movebutler. Their contract is with your agency.
If you choose to offer your client an iamproperty service through movebutler (for example, conveyancing or another optional service) and the client accepts that service, they will then enter into a separate contract with the relevant iamproperty service provider.
What is the lawful basis under UK GDPR for processing the client’s data when we input their details for electronic checks (e.g. consent, legitimate interest, legal obligation)?
As the estate agent, you are responsible for determining the lawful basis for processing your client's personal data under the UK GDPR.
Before adding a client to movebutler, you should ensure they have agreed to their personal data being shared with and processed through the platform for the purposes of completing Anti-Money Laundering (AML) checks.
If your client does not agree to their information being processed through movebutler, you must not add their details to the platform. Instead, you should follow your agency's AML procedures and consult your Money Laundering Officer (MLO) to determine an appropriate alternative method of completing customer due diligence.
How can a client object to or opt out of their data being processed by iamproperty?
If your client does not agree to their personal data being processed through movebutler, you must not add their details to the platform. You should instead use an alternative method of completing your customer due diligence in accordance with your agency's AML policy.
If a client initially agrees to their data being processed through movebutler but later wishes to withdraw that agreement or request the removal of their data, they should contact you first.
As the data controller, you should then contact movebutler Product Support so we can advise on the options available, taking into account your legal obligations under the Money Laundering Regulations and any applicable data retention requirements.