DATED – 12 October 2019
Clients, tenants, leaseholders, landlords, freeholders, suppliers, contractors, contacts and employees
This privacy notice explains what personal data (information) we hold about you, how we collect it, and how we use and may share information about you. We are required to notify you of this information under the General Data Protection Regulation ( referred to as GDPR).
Please ensure you read this notice (sometimes referred to as a “privacy notice”) and any other similar notice we may provide to you from time to time when we collect or process personal information about you. This privacy notice contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
1. Who we are
AR Lets a division of Austin Rees Limited collects uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
In this privacy notice, references to “we”, “us” or “our” means AR Lets a division of Austin Rees Limited.
2. Data Protection Principles
We will comply with the data protection principles when gathering and using personal information, as set out in our GDPR data protection policy.
3. The personal information we collect and use: Information collected from you
In the course of our business activities we collect the following personal information when you provide it to us:
- Names, phone numbers, addresses, email addresses and bank details.
- In order to support and manage our employees Austin Rees Limited collects emergency contact details, national insurance number, employment and educational information and information from employer references.
- The provision of names, phone numbers, addresses, email addresses and bank details is required from you to enable us to perform our duties in accordance with the contract we have with you and/or our client and/or our legitimate interest. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
4. The personal information we collect and use: Information collected from other sources
We may also obtain personal information from other sources as follows:
- Names, phone numbers, addresses, email addresses from banks and other financial institutions, Solicitors, Accountants, The Royal Institute of Chartered Surveyors (RICS), credit referencing agencies, Her Majesty’s Revenue and Customs (HMRC), other property management agencies.
- For employees we also collect educational and employment information from previous employers and/or employment agencies.
5. How we use your personal information
We will typically collect and use this information for the following purposes:
- For the performance of a contract we have with you and/or our client.
- For the purposes of our legitimate interests or those of a third party, but only if these are not overridden by your interests, rights or freedoms.
We seek to ensure that our information collection and processing is always proportionate. We will notify you of any material changes to information we collect or to the purposes for which we collect and process it.
6. Who we share your personal information with
We routinely share the following categories of personal data:
- Phone numbers
- Email addresses
This personal information may be shared with the following categories of recipients:
- Association of Residential Managing Agents (ARMA)
- Accountants and Auditors
- Banking Institutions
- Companies House
- Councils and Local Authorities
- Courts and Tribunals
- Credit referencing agencies
- Debt collection agencies
- Email providers
- Energy assessors
- Information Commissioners Office
- Insurance Brokers
- Insurance companies
- National Crime Agency
- Managing Agents
- Tenancy deposit schemes
- Ombudsman Services
- Riversong Group companies (Riversong Limited is a designated member of Graves Son & Pilcher LLP, the associated companies of Riversong Limited are Austin Rees Limited including AR Lets, Estate Management Limited and Overill Associates Limited)
- Royal Institution of Chartered Surveyors (RICS)
- Software providers
- Utility companies
For employees of AR Lets a division of Austin Rees Limited we may also share information with:
- Pension providers
- Employment benefit providers
- Payroll providers
- Advisory, Conciliation and Arbitration Service
This data sharing enables us to perform our duties in accordance with the contract we have with you and/or our client. Or where there is a legitimate interest to enable to perform our duties.
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other third party.
7. Where your personal information may be held
Information may be held at our offices and those of the Riversong Group companies, and third party agencies, service providers, representatives and agents as described above.
We have security measures in place to seek to ensure that there is appropriate security for information we hold including those measures detailed in our GDPR data protection policy.
Or, for example, a set number of years after a data subject cease to be a lessee in that development.
8. How long your personal information will be kept
- We will hold names, addresses, telephone numbers, email addresses and bank details and in the case of employees National Insurance Numbers whilst the contract with you is in place. Once the contract is terminated we are required, by law, to hold information for a period of six years.
- Legally we are required to hold financial data re leases for a period of twelve years.
9. Reasons we can collect and use your personal information
We rely on CONTRACT as the lawful basis on which we collect and use your personal data.
We rely on legitimate interest as the lawful basis where we require personal details for dealings with third parties in order for us to be able to honour our contract.
10. Your rights
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- fair processing of information and transparency over how we use your use personal information
- access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
- require us to correct any mistakes in your information which we hold
- require the erasure of personal information concerning you in certain situations
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and you have the right to transmit that data to a third party in certain situations
- object at any time to processing of personal information concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal information
- otherwise restrict our processing of your personal information in certain circumstances
- claim compensation for damages caused by our breach of any data protection laws
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
The Data Protection Manager
51 Old Steine,
telephone 01273 207 501
- let us have enough information to identify you (eg full name, address and property address),
- We may ask you to let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let us know the information to which your request relates, including any account or reference numbers, if you have them
11. Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
12. How to complain
We hope that we can resolve any query or concern you raise about our use of your information. Please see below in section 15 ‘How to contact us’ if you have a query or concern regarding this policy.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: [0303 123 1113].
13. Changes to this privacy notice
This privacy notice was published on 25th May 2018 and last updated on 25th May 2018.
We may change this privacy notice from time to time, and when we do we will inform you.
14. Do you need extra help?
If you would like this notice in another format (for example: audio, large print, braille) please contact us (see ‘How to contact us’ below).
15. How to contact us
The Data Protection Manager
51 Old Steine,
telephone 01273 207 501
Let us have enough information to identify you (eg full name, address and property address),