DATED: 1 June 2018
PRIVACY NOTICE provided by
HOUSTON LAWRENCE MANAGEMENT LIMITED
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 block of flats or the development within which you live or own property, and also after our management 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 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
Houston Lawrence Management 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” or “us” means Houston Lawrence Management 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 block of flats or the development within which you live or own property and for the purposes of property management we collect the following personal information when you provide it to us:
- Name, postal address, correspondence address, contact details (email and phone numbers), bank account details, emergency contact details, mortgage company details, vehicle ownership and registration details. We will however only store sensitive data from you where you have given explicit consent e.g. periods of ill-health or financial difficulty.
The provision of the above information is required is required from you to enable us to perform our contract as managing agent. 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 also obtain personal information from other sources as follows:
- Your solicitor or Mortgage Company. Your letting agent. Other parties acting for you.
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 you have with our client and pursuant to which we are appointed as their agent.
- 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:
- Name and address and contact details. Service charge and ground rent account details (strictly in relation to charging, collecting and managing these accounts only)
This personal information may be shared with the following categories of recipients:
Clients and Directors of RMCs, accountants, banks, debt collection agencies, solicitors, other property managing agencies, IT and software providers, on-site staff and contractors, HLPS and surveyors, consultants, insurance brokers, other service providers on you block of flats/your development, email merge systems e.g. Mail Chimp
This data sharing enables us to perform our contract as managing agent.
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 our 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.
8. HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
- We do not hold your personal information for longer than is necessary. We will hold your personal information for the period we manage your block of flats/your development and for 6 years, but in respect of financial records for 7 years, after the end of our management of your block of flats/your development.
9. REASONS WE CAN COLLECT AND USE YOUR PERSONAL INFORMATION
The lawful basis on which we collect and use your personal data is as stated. We rely on contract (that is the flat lease or house transfer or other document between yourself and our client). We rely on legitimate interests to fulfil all reasonable tasks as property managing agents in accordance with our contract with our client relating to your block of flats/your development.
10. TRANSFER OF YOUR INFORMATION OUT OF THE EEA
We may transfer your personal information to the following which are located outside the European Economic Area (EEA) as follows:
- USA in order to process and store data for property management purposes e.g. Microsoft and USA in order to mailshot information for property management purposes e.g. Mail Chimp.
Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European
Commission has not given a formal decision that the USA provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal information will be subject to for example the European Commission approved contract as permitted under for example Article 46/5 of the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.
If you would like further information please contact Houston Lawrence Management Ltd (see ‘How to contact us’ below). We will not otherwise transfer your personal data outside of the United Kingdom or EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
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
- 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 Houston Lawrence Management Limited, 6 Port House, Square Rigger Row Plantation Wharf, London SW11 3TY. Email:firstname.lastname@example.org. Telephone: 020 7801 9009.
- let us have enough information to identify you e.g. 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
12. 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.
13. 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 athttps://ico.org.uk/concerns/ or telephone: 0303 123 1113.
14. CHANGES TO THIS PRIVACY NOTICE
This privacy notice was published on 1 June 2018 and last updated on 1 June 2018
We may change this privacy notice from time to time, and when we do we will inform you.
15. 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’ above).