Privacy policy

Spencer How Limited, trading as Spencer How Relocation, is an independent UK relocation and destination-services business. We provide services to corporate clients, relocation management companies, relocating employees and their families. These services may include home search, home purchase, home sale, tenancy management, school search, settling-in support, departure services and related relocation assistance.

For UK data-protection purposes, Spencer How may act as a controller where we determine why and how personal information is used, or as a processor where we use personal information on the documented instructions of a corporate client or relocation management company. Where another organisation has instructed Spencer How, that organisation may also be a controller.

Spencer How Limited

59 High Street, Great Missenden, Buckinghamshire, HP16 0AL

Email: service@spencerhow.co.uk | Telephone: +44 (0)1494 867500 | Website: spencerhow.co.uk

Spencer How processes personal information in accordance with applicable UK data-protection legislation, including the UK GDPR, the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 where applicable, and the Data (Use and Access) Act 2025. We apply the principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, security and accountability.

Depending on the service and instructions received, we may use identity and contact information; employer and business-contact information; relocation dates and requirements; property, tenancy, purchase or sale information; household and dependant information; school-search and education requirements; transport, commuting and local-area preferences; accessibility or practical support requirements; appointment and itinerary information; agreed budgets, costs, invoices, expenses and payment records; supplier and professional contact information; communications, case notes, progress updates, complaints and incident records; and website enquiry, device, cookie and diagnostic information.

Spencer How does not normally require complete payment-card information and will not ask individuals to send card details by ordinary email.

Relocation services can occasionally involve information requiring additional protection, including health, disability or accessibility requirements, racial or ethnic origin, religious or philosophical requirements, or dietary information that reveals health or religious information. We only request or use such information where necessary and proportionate, where an appropriate legal condition applies and, where required, with explicit consent. Information relating to criminal convictions or offences is processed only where lawful, necessary and subject to appropriate safeguards.

We may receive information directly from an individual or household member, an employer, relocation management company, authorised representative, Spencer How consultant, landlord, property agent, school, local authority, professional adviser or service provider, through our website or Resource Centre, or from appropriate publicly available sources. Where a corporate client or RMC provides information to Spencer How, it is responsible for ensuring it has an appropriate basis for sharing it.

We use personal information to respond to enquiries and prepare services; provide relocation and destination services; manage property, tenancy and related arrangements; manage client, RMC and supplier relationships; meet legal, accounting, taxation, insurance and regulatory requirements; protect systems and information; investigate concerns and complaints; and, where permitted, maintain appropriate professional relationships.

Depending on the activity, our lawful basis will normally be taking steps before a contract, performance of a contract, compliance with a legal obligation, legitimate interests, or consent where required. Where special-category information is processed, an additional condition under data-protection law will apply.

Where we rely on legitimate interests, we consider the purpose, necessity and proportionality of the processing, the individual's reasonable expectations, the sensitivity of the information, the likely impact and available safeguards. Individuals may object to processing based on legitimate interests. We will consider the circumstances and stop unless we have compelling legitimate grounds or the information is required for legal claims.

We share information only where necessary, lawful and proportionate. Depending on the service, recipients may include the instructing employer, corporate client or RMC; authorised Spencer How personnel and consultants; landlords and property agents; referencing providers; schools and local authorities; property lawyers, surveyors, mortgage advisers and other authorised professionals; utility or communications providers where requested; accountants, auditors, insurers and legal advisers; IT, hosting, case-management and communications providers; and public authorities, regulators, law-enforcement bodies or courts where required.

Spencer How does not sell personal information. Third parties processing information on our behalf are subject to appropriate contractual, confidentiality and security requirements.

Spencer How uses approved business systems to store, process and communicate information. Its business environment includes Microsoft 365, and case information is managed through the RelocationOnline case-management platform. Access is granted according to business need and appropriate security controls. Technology suppliers may process information on Spencer How's behalf, with supplier assurance and contractual controls applied proportionately. Detailed third-party security evidence may be subject to confidentiality restrictions and provider consent.

Some clients, RMCs, professional contacts or technology providers may be outside the United Kingdom. Where personal information is transferred to a country not covered by UK adequacy regulations, Spencer How will use an appropriate lawful transfer mechanism where required, which may include the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, another approved safeguard or an applicable legal exception. Appropriate transfer risks and additional safeguards are considered where required.

Spencer How uses proportionate technical and organisational measures intended to protect personal information against unauthorised access, accidental loss, inappropriate disclosure, alteration, destruction and misuse. Measures include controlled access, individual accounts, multi-factor authentication, confidentiality obligations, approved business systems, device and malware protection, security updates, secure transfer and storage controls, access removal, supplier due diligence, incident response and staff guidance. No system can guarantee absolute security.

We retain information only for as long as reasonably required for the purpose for which it was collected and to meet legal, contractual, insurance, accounting and operational obligations. Retention decisions take account of the nature and sensitivity of the information, service provided, client or RMC requirements, legal and tax obligations, insurance conditions, complaint and legal-claim limitation periods, security and business-continuity requirements. At the end of the applicable period, information is securely deleted, anonymised or placed beyond routine use unless continued retention is required by law or for an established legal purpose. Further information about the criteria applying to a particular record is available from service@spencerhow.co.uk.

We take reasonable steps to keep information accurate and up to date. Individuals should tell us if their details or service requirements change, information is inaccurate, or they believe information is no longer required. Where information was supplied by an employer or RMC, we may need to liaise with that organisation when updating the service record.

Depending on the circumstances and lawful basis, individuals may have rights to be informed; access their personal information; correct inaccurate information; request deletion or restriction; object to certain processing and direct marketing; receive eligible information in a portable format; withdraw consent where relied upon; raise concerns about significant automated decision-making; and make a complaint. These rights are not absolute and exemptions may apply. We may request proportionate information to verify identity or authority. Requests should be sent to service@spencerhow.co.uk.

Spencer How does not ordinarily make decisions producing legal or similarly significant effects about relocating employees or family members solely through automated processing. If this changes, appropriate information about the processing, consequences and safeguards will be provided.

Anyone with a concern about Spencer How's use of personal information may contact the Managing Director / Data Protection Lead at service@spencerhow.co.uk or +44 (0)1494 867500. We will acknowledge the complaint, record and investigate the issues fairly and proportionately, keep the complainant informed where further information or additional time is required, provide an outcome and explanation, and record and follow up corrective action where appropriate. Where a complaint is made for another individual, we may require evidence of authority. Individuals also have the right to complain to the Information Commissioner's Office.

Spencer How may use limited information about children where necessary to support an instructed family relocation, for example for school-search requirements, household needs or settling-in support. It is used only for the relevant service, shared where necessary and handled with particular care. Where appropriate, information will be obtained from or confirmed with a parent, guardian, instructing client or other authorised person. Spencer How does not use children’s information for unrelated marketing.

The Spencer How website provides, or will provide as applicable, information explaining the cookies and other storage/access technologies in use, their purposes, relevant third parties and how choices can be managed. Non-essential technologies will only be used where permitted by applicable law. This policy and any cookie notice should be reviewed whenever there is a material change to website forms, analytics, marketing tools, hosting or integrations.

We may update this policy to reflect changes in our services, legal or regulatory requirements, client or RMC requirements, technology, suppliers, systems and working practices. The current version will show its effective date and material changes will be communicated where appropriate.

Spencer How Limited | Supplier & Compliance Resource Centre | Updated October 2026