Aston Rose Property Management Privacy Notice
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 during our management of the property in which you hold a lease of part and after it ends.
We are notifying you of this information under the General Data Protection Regulations, which are incorporated into English law by the Data Protection Act 2018.
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
Aston Rose (West End) limited and we collect, use and are responsible for certain personal information about you. When we do collect and process personal data, 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. Our Data Protection Officer is currently Neil Spurrier to whom representations can be made.
In this privacy notice, references to “we” or “us” means Aston Rose (West End) 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 BY US
In the course of the performance of our contract as managing agent for the property where you are a leaseholder, we collect the following personal information when you provide it to us:
The personal data kept by us will include your name, address, accounts, billing and payment details and data in any correspondence between us. Management Accounts may contain data from which you can be identified.
4. THE PERSONAL INFORMATION WE COLLECT AND USE: INFORMATION COLLECTED FROM OTHER SOURCES
5. HOW WE USE YOUR PERSONAL INFORMATION
The purpose of processing the data is, in the case of property management, in order that we can manage the building in which your property is situate. The data will be stored by us for as long as you own your property. Following your cessation as a lessee, your data will be archived. The criteria for these decisions is that we will need the data during your ownership of the property for the purposes of fulfilment of your and our and the landlords’ / managements company’s leasehold contractual obligations. Following the cessation of your ownership of the property, the data will only be required for historical purposes. It will be impractical to re-run accounts and demands in order to delete past lessees and payees. In addition it will be impracticable to extract email correspondence from the server, which as a consequence will be retained by us.
In the case of clients, we will need sufficient identity documents in order to comply with statutory anti-money laundering requirements and any other information that is reasonably necessary in order for us to act for you.
6. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
The recipients of your personal data will be us, our client (the landlord/management company) and the relevant professional advisors. In the case of financial details or references supplied by prospective buyers or tenants, the details may be passed to the relevant client of ours.
7. WHERE YOUR PERSONAL INFORMATION MAY BE HELD
Information will be held at our offices and backed up on a secure server within the UK. Upon our ceasing to be instructed in the management of the building of which your property forms part, we will part with the personal data to the successor managing agent.
8. HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
Following your cessation as a lessee, your data will be archived for a period of up to 12 years. In addition it will be impracticable to extract email correspondence from the server, which as a consequence will be securely retained by us. With clients we will erase data as soon as practicable after cessation, although email correspondence is not possible to extract for destruction.
9. REASONS WE CAN COLLECT AND USE YOUR PERSONAL INFORMATION
The reason for collecting and processing the data is in order that we can manage the building in which your property is situate.
In respect of clients, we need to collect sufficient data to comply with client identity requirements and to have sufficient information in order to effectively act for you.
10. TRANSFER OF YOUR INFORMATION OUT OF THE EEA
We may transfer your personal information outside the European Economic Area for back up storage and only if there is in existence an appropriate and recognised safeguard policy.
If you would like further information please contact us or our Data Protection Officer.
11. 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
- where information is give to us with your consent, to withdraw that consent
- 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 have the right to transmit those 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.
If you would like to exercise any of those rights, please:
- email, call or write to us
- let us have enough information to identify you
- 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.
We then have one calendar month to respond to you. If your request is complex or time consuming, we may take longer to respond. After that period of time, you have a right to refer the matter to the Information Commission (see “How to Complain” below).
12. KEEPING YOUR PERSONAL INFORMATION SECURE
We have appropriate and proportionate 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.
13. HOW TO COMPLAIN
We hope that we can resolve any query or concern you raise about our use of your information.
The Data Protection Act 2018 gives you the right to lodge a complaint with the Information Commissioner’s Office (ICO) who may be contacted at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or telephone: [0303 123 1113]. Our registration number at the ICO is Z5829259.
14. CHANGES TO THIS PRIVACY NOTICE
This privacy notice was published on 23rd May 2018 and updated on 7th November 2019.
We may change this privacy notice from time to time, and when we do we will inform you.