1. Who we are
Keith Perry Chartered Surveyor is a property management business based at 17a High Street, Hucknall, Nottingham NG15 7HJ, UK. You may contact us by mail at that address, by telephone on 0115 963 3764, or by email at email@example.com .
Our activities include:
• liaising with:
o current, prospective and past flat leaseholders;
o where applicable, their tenants (current, prospective and past);
o solicitors, accountants, insurers, other professionals;
o relevant public authorities; and
o relevant suppliers;
• invoicing for and collecting service charge funds;
• arranging repairs; and
• paying for supplies of goods and services,
all in connection with the proper financial and practical management of properties where we are appointed or entrusted with any management responsibility.
In this Privacy Notice, each of those properties is referred to as a ‘Property’.
As a small firm, we are both data controller and data processor.
2. What personal information we may collect about you
• Your residential or commercial postal address;
• Your full name or your initials and surname;
• Your home, work and mobile telephone numbers;
• Your email address;
• Contact details of anyone authorised to act on your behalf (if applicable);
• Updates to any of the above, as they change over time (if applicable); and
• Other personal information, that will vary on a case by case basis to help us to resolve possible or alleged breaches of applicable lease terms, lease regulations and applicable legal regulations and other requirements.
3. How we may collect your personal information
• You may provide (or have provided) personal information to us by completing a “Leaseholder Information” form.
• Also, we may correspond with you (and you with us) by post, email, fax or if you visit our website: www.keithperrycharteredsurveyors.com .
• Further, you may provide personal information over the telephone, if you telephone us or if we telephone you, whenever there is a property management matter to discuss.
• We may obtain personal information from a third party (such as your solicitor, e.g., at the point of purchase or sale of a flat lease), your accountant or other professional adviser.
Note: We do not use direct debiting to collect any ground rent, service charge or any other payment, and therefore do not hold any of your bank or other payment account details.
4. What processing we do with the personal information collected
The personal information which we obtain from you is used:
• to manage the development of the relevant Property; and
• to fulfil our legal obligations for Property management, such as:
o administering your service charges due and payments made;
o arranging repairs and maintenance; and
o ensuring lease obligations are complied with (such as dealing with anti-social behaviour, and compliance with relevant legislation, e.g. short term lettings, Houses in Multiple Occupation [HMO’s], etc.).
We may arrange for photographs to be taken of Property interiors in connection with repair requirements, but these will only be: (i) taken with your prior consent; and (ii) used for those purposes.
The purpose of our holding this data is solely to facilitate efficient contact with you for the purpose of conducting Property-related business, or providing you with services or information which you have requested. This use is considered lawful under Article 6b under the terms of the new General Data Protection Regulation (‘GDPR’) legislation.
5. Disclosure of your information
We may share your personal information with third parties, including other professionals working alongside us in the proper management of the relevant Property, e.g., maintenance contractors, solicitors, accountants, and insurance brokers.
We may also share your personal information with third parties if we find ourselves under a formal duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce Property lease terms and regulations.
We may also exchange information with other organisations for the purposes of fraud protection and credit risk reduction.
6. Where personal data is stored
• Information is held in electronic accounts systems on personal computers at our offices at the address shown at 1. above, plus a laptop and mobile phone device to which only our principal (Mr. Keith Perry) has the passwords. All devices are firewalled and have Norton anti malware software.
• Our office server is located at our offices at the address shown at 1. above. Our email system is maintained by Getyouonline.co.uk on secure servers on UK-based data centres which are owned and managed by CompuWeb Communications Services Limited (which trades as CWCS Managed Hosting). All servers are secured with individual firewalls, antivirus software, active and passive exploit scanners and each account is run in a ‘jailed’ environment. This ensures that in the event of an individual user account being in some way compromised (such as a compromise on a local personal computer granting unauthorised personal access to files and/or emails) this cannot be used to leverage access to anything else for any of Getyouonline.co.uk’s other customers. All servers are monitored 24/7, ensuring that any updates or security patches to the systems are installed by our IT service suppliers as soon as they become available, maintaining the highest possible level of security at all times.
7. What we will not do
• We do not involve ourselves in any marketing which uses personal information relating to you.
• We will not send you unsolicited marketing material.
• We will not sell your personal information on to third parties.
• We will not pass any of your personal information on to unrelated third parties unless we are allowed or required to do so by law, or we have your explicit permission to do so.
• We will not transfer or store your personal information outside the control of the UK/European regulations.
• We will not hold or process your personal information after 7 years from the date when you last interacted with our firm.
8. Your rights
• You have the right to request a copy of the personal information which we hold about you. We will respond within one month of receiving your request. In respect of any such request that is unreasonable or excessive, we may either refuse to supply the information or we may make a nominal charge.
• You have the right to correct information that we hold.
• You have the right to be forgotten, though it is unlikely to be possible to accept your request if, for example, we have a legal duty to retain and continue to process your information.
• You have the right of ‘data portability’, i.e., to move, copy or transfer your personal information to another organisation or to you.
• You have the right to lodge a complaint directly with the supervisory authority, i.e., the Information Commissioner’s Office (ico.org.uk)
9. Data breaches
We will always do our best to ensure that your personal information held by us is never stored or processed in a way that may be compromised or intercepted. However, no form of data security or processing is completely infallible. So in the event of our identifying that a data breach has taken place, we shall contact any person who may have been a victim of that breach immediately after discovering it.
10. Changes to this Privacy Notice
This Privacy Notice was last updated on [18 June 2018]: any changed version will be identified at the foot of this page. We will notify you separately of any future material change in a future version. You are encouraged to visit our website at URL: http://www.keithperrycharteredsurveyors.com/ from time to time to make sure that you are aware of the current version of this Privacy Notice.
Original published on [25 May 2018]
Changed on 31 May 2018
Changed on 18 June 2018