SARUM PROPERTIES LTD - PRIVACY NOTICE
his 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 whilst we are freehold/leasehold owner or acting as an agent for the freehold/leasehold owner of your Development Estate or flat, and after your interest in the property ends. We are required to notify you of this information under the General Data Protection Regulation.
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 notice contains 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
Sarum Properties Ltd (Sarum), Company Number 2194078 England & Wales whose registered & operational offices are at 14 Wilton Road, Salisbury, SP2 7EE, undertakes the administration and holds data for a number of freehold companies (our Clients). We therefore collect, hold, are responsible for, and use 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). We are responsible both as a “controller” and as “processor” of that personal information for the purposes of those laws.
In this privacy notice, references to “we” or “us” means Sarum
The contact details of the “Privacy Controller”, who is your contact at Sarum are at the end of this document.
Sarum takes great care with all data but especially personal data. We are committed to ensuring this is secure and processed in a lawful manner. Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions.
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. We will process the information fairly, endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.
3. THE PERSONAL INFORMATION WE COLLECT AND USE:
We collect, hold and use relevant personal data, when provided to us, in relation to registered leaseholders, freehold home-owners and other tenants/residents at Estates and properties where we or our Clients are owners of the Freehold, Headlease, or Lease. We also hold details of the above-mentioned data-subjects’ appointed representatives when they have been provided to us.
With regard to each registered property owner we hold some or all of the following data relevant to your property: name, contact details (address, property address, contact phone numbers, e-mail address, mortgagee details), dates of acquisition & disposal of your interest in the property, copies of written and email correspondence / Notices / documents / Agreements / Licences and Deeds / file notes of pertinent phone calls, records of billings and payments, and correspondence with your property’s conveyancing solicitors.
We may also hold personal data relating to tenants or other residents who do not own the leasehold or freehold being some or all of the following - name / contact details, a copy of your AST or other tenancy agreement, dates of residence at the property concerned, as well as copies of any correspondence / Notices / Agreements / Licences and Deeds / and file notes of any pertinent phone calls provided to us.
Occasionally residents at neighbouring properties or directors of Right to Manage companies may ask us to hold personal data such as contact details, or may correspond with us regarding a problem at one of our Developments that affects their property, which we then hold on file.
The provision of all the above data is required to carry out the terms of the lease contracts, to fulfil our legal obligations, and at times for duty of care
Special Category Data: In certain circumstances we will request or you may choose to provide us with special category data that is either required by the terms of the leases (an example is proof of age required by leases at Developments with an age restriction) or in order to carry out Sarum’s or our Clients’ management or legal obligations at a building (an example would be a medical condition relevant to health & safety at a building).
Suppliers: Personal data held in relation to suppliers will include the following examples for sole traders and unincorporated partnerships; contact details in order to provide effective services, and bank details for the legal obligation of invoice payment.
4. .HOW WE COLLECT DATA
We receive the aforementioned categories of personal data in paper, electronic or verbal form.
This data is received from solicitors and appointed managing agents when we or one of our Clients acquires the Freehold or Head-leasehold of a Development, or the lease of a property. It is also received from solicitors when arranging a Notice of Assignment or Registration on behalf of their Client as per the terms of the lease, and from the data subjects themselves. In the case of tenants and other residents, it may be provided to us by the owner of the property you occupy.
During the course of ownership of a Development or lease, personal data relevant to the lease agreements and our general management obligations of the properties may also be forwarded to us by appointed managing agents, other contractors, service providers, authorities, solicitors and other authorised third parties
We may also seek details of your registered address or mortgagee from the Land Registry if we have not been provided with this information.
5. .HOW WE USE YOUR PERSONAL INFORMATION
We will typically collect and use this information for the following purposes:
* to bill and collect rents and any other costs that may be due under the terms of the lease contracts, other contractual agreements, or by order of a court.
* to fulfil our legal obligations and the requirements of the lease contracts (including the services that the Landlord is contracted to provide),
* for the purposes of Sarum’s or our Clients’ legitimate interests or those of a third party, but only if these are not overridden by your interests, rights and freedoms,
* for legitimate management information and data analysis purposes,
* and at times for duty of care.
We collect Special Category Data as specified previously when provided to us to assist the data subject and/or to comply with lease and other legal requirements. We only use it for the purposes required by the lease agreements, or to assist you at your or your appointed representative’s request.
We seek to ensure that all 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 personal data (as appropriate and when required) with Sarum’s (or our Clients’) appointed Managing Agents, Insurance brokers and Insurers, leasehold support services, service-providers & other contractors, Solicitors, Surveyors & Valuation Surveyors, bookkeepers, accountants and auditors, government agencies, utilities companies, database support and development contractors, and solicitors of potential Freehold or Head-leasehold purchasers.
This data sharing enables us to perform our legal obligations, fulfil the requirements of the lease contracts, and perform our duty of care when required.
We will share personal information with law enforcement or other authorities if required by applicable law.
We will share your name and address with other leasehold-owners or freehold home-owners at your Development if requested, when permitted or required to do so by the leases or other legal contracts after the service of a Privacy Notice stating the basis on which we plan to share your address.
We will not share your personal information with other third parties without your consent.
7. WHERE YOUR PERSONAL INFORMATION IS HELD
Information in documents and files is held in filing cabinets at our offices and at our secure storage archive; electronic information is held on our database & email records located on a secure password-protected server.
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.
8. HOW WE PROTECT THE INFORMATION
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
We secure electronic and manual information in the following ways
• Password security
• Role based control of access
• Locked and alarmed building only accessed by authorised persons.
• Contracts with third party processors and controllers
• Contract with a secure waste paper disposal company which collects the paper documents that we remove from file at regular intervals.
9. HOW LONG WE KEEP THE INFORMATION
We will keep your Personal Information only as long as necessary for the purposes for which we collected it and to comply with applicable law. Depending on our relationship with you, we may keep your Personal Information for a number of years after our relationship ends.
In detail:
We will keep Personal Information for as long as is necessary for the purposes for which we collect it. T he precise period will depend on the purpose for which we hold your information. In addition, there are laws and regulations that apply to us which set minimum periods for retention of Personal Information. We will provide you with further information if appropriate to give you a full picture of how we collect and use your Personal Information.
Overseas Transfers
None of the information that we collect process or store is transferred outside of the European Economic Area (EEA). This includes information that is processed by third parties as above.
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 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, call or write to us • let us have enough information to identify you [eg. your full name, address and property address, • 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. HOW TO COMPLAIN
We hope that we can resolve any query or concern you raise about our use of your information. Please contact the Privacy Controller at Sarum Properties Ltd, 14 Wilton Road, Salisbury, SP2 7EE, or Admin@14wiltonroad.co.uk
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].
12. CHANGES TO THIS PRIVACY NOTICE
This privacy notice was published on 21st May 2018
We may change this privacy notice from time to time, and when we do we will inform you.