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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 properties on behalf of our clients (who are the landlords or management companies of those properties) and after our management ends. We are required to notify you of this information under the General Data Protection Regulation (GDPR).
Please ensure you read this notice (sometimes referred to as a “privacy notice”) and any other similar notices 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 regarding your personal data.
1.WHO WE ARE
Westbury Residential 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 “Westbury Residential Limited”, “we” or “us” means Westbury Residential 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 managing properties, we collect some or all of the following personal information when you provide it to us as applicable: Name, title, contact details, property address, correspondence address, telephone numbers, email addresses, mortgage details and bank details.
The provision of the above stated personal information is required from you to enable us to perform our contract as managing agent appointed for and on behalf of our clients. We will inform you at the point of collecting information from you, which information you are required to provide to us.
4.THE PERSONAL INFORMATION WE COLLECT AND USE: INFORMATION COLLECTED FROM OTHER SOURCES
We also obtain personal information from other sources as follows: Clients (landlords and management companies), their directors and employees, Site Staff, other Managing Agents, Flat Owners and their agents and representatives, Contractors, Insurance Companies and intermediaries such as brokers and loss adjusters, Accountants, Solicitors, Debt Collection Agencies, IT providers, Local Authorities, Emergency Services such as Police and Fire Brigade and information held in the public domain.
5.HOW WE USE YOUR PERSONAL INFORMATION
We will typically collect and use this information for the performance of a contract you have with our client and pursuant to which we are appointed as their agent. We also collect and use this information 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
Personal information such as names and contact information such as addresses, telephone numbers and email addresses may be shared with the following categories of recipients: Clients (landlords and management companies), their directors and employees, Site Staff, other Managing Agents, Contractors, Insurance Companies and intermediaries such as brokers and loss adjusters, Accountants, Surveyors, Solicitors, Debt Collection Agencies, IT providers, Local Authorities, Emergency Services such as Police and Fire Brigade, Regulatory Bodies.
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, IT service providers, at the relevant properties and by representatives and agents as described above where applicable. We have security measures in place to ensure that there is appropriate security for information we hold including those measures detailed in our GDPR data protection policy.
8.HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
We will hold personal data throughout the period we are contracted to manage a property on behalf of our client and for up to 7 years after a data subject ceases to have a vested interest in a property under our management. We also retain personal data of data subjects for up to 7 years after we cease to manage a property in which they have a vested interest.
9.REASONS WE CAN COLLECT AND USE YOUR PERSONAL INFORMATION
We rely on contract and legitimate interest for reasons of security and management of services as the lawful basis on which we collect and use your personal data.
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 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 Regulation. If you would like to exercise any of those rights, please:
•email us at firstname.lastname@example.org or write to us at Suite 2, De Walden Court, 85 New Cavendish Street, London W1W 6XD
• provide us enough information to identify you e.g. full name, address and property address,
•provide us with proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card statement)
•state 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. 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/.
13.CHANGES TO THIS PRIVACY NOTICE
This privacy notice was published on 23 May 2018 and last updated on 23 May 2018. We may change this privacy notice from time to time, and when we do we will inform you.