General Data Protection Regulation - Privacy Notice for Tenants

Introduction

Fourbrooks Business Park Estate Management Limited collect personal information from you so that we can perform our contractual obligations as Managing Agents for The Venner Trust when you, or a company that you are involved with, become a tenant of a property owned by The Venner Trust (the Landlord), which is a small self-administered pension scheme (SSAS) that is administered by D A Phillips & Co Ltd. We process your data to enable us to fulfil your covenant with the Landlord to pay a Rent Charge and Expenses for the maintenance, repairs, replacement and all areas of estate management of Fourbrooks Business Park, Stanier Road, Calne SN11 9PP. 

Protecting and respecting your privacy is very important to us and we want you to be confident that your information is in safe hands. Looking after the personal information that we collect about existing or proposed tenants is something we take very seriously. Our Privacy Notice lets you know;

• Who controls the personal information collected and how it is used
• Our lawful basis to process the data
• What personal data is
• How and why we need to collect and store it
• When and why we share it with other organisations
• How long we keep it for
• Your rights
• How to contact us

Who controls the personal information collected and how it is used?

In addition to D A Phillips & Co Limited and The Venner Trust, Fourbrooks Business Park Estate Management Limited will process – that means collect, store and use – the information you provide in a manner that is compatible with the EU’s General Data Protection Regulation (GDPR). D A Phillips & Co Limited, The Venner Trust and Fourbrooks Business Park Estate Management Limited are Data Controllers and the personal data we collect from you will be used for the following purposes:

• The set up and day to day administration of your tenancy
• Complying with our legal, regulatory and statutory obligations
• For the detection, investigation and prevention of illegal or prohibited activity and to protect our legal rights and those of our clients

What is the lawful basis in order to process the data?

We are required to establish the lawful basis we are relying on in order to process your data. The lawful basis we will be relying on is “performance of a contract”. This lawful basis enables us to fulfil our contractual obligations of setting up and administering your tenancy.

What is Personal Data?

Under the EU’s General Data Protection Regulation, Personal Data is defined as:

“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

Special Categories of Personal Data

Certain data is classified under the Regulation as “special categories” including Health Data.

Consent is required for Fourbrooks Business Park Estate Management Limited to process this type of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data, we will always tell you why and how the information will be used and seek your consent prior to requesting it.

Why does Fourbrooks Business Park Estate Management Limited need to collect and store personal data?

In order for us to provide you with services, we need to collect personal data for correspondence purposes and/or detailed service provision. Depending on the circumstances, the personal information we gather about you may include:

• Your name and title
• Address
• Date of birth
• National insurance number
• Gender
• Nationality
• Country of residence
• Occupation
• Email address
• Phone numbers
• Financial information
• Identity details, e.g. driving license or passport information
• Bank details
• Agent details
• All communications with you

This is not an exhaustive list but includes the main data items. We will also collect data about a guarantor, where one is required under the terms of the tenancy.

Personal information is collected through our application forms and ongoing correspondence to enable us to verify your identity and allow your tenancy to be set up. We will also use your personal information to provide ongoing day to day administration of your tenancy, such as, to process Rent Charge and Expenses and reviews.

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. The information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Sharing your personal information

We are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. In the course of dealing with you, we may share your personal data with the following:

• Any member of our group of companies or organisations such as The Venner Trust, D A Phillips & Co Ltd and Premier Jobs UK Ltd
• Banks for the payment of rent charge and expenses
• Professional parties, such as solicitors, valuers, insurance providers, and credit reference agencies.
• Compliance Support 
• Any party we are required to share data with to meet our legal and regulatory duties
• Other companies within our group
• Your agent (if you have one)
• IT services
• Anti-money laundering service provider
• Fraud prevention and enforcement agencies
• Accountants for preparation of annual income and expenditure accounts and processing tax and VAT records
• Any party to assist with actual or threatened legal proceedings, provided we can lawfully do so.

These organisations are obliged to keep your details secure and use them only to fulfil the service requested. Once your service need has been satisfied or the case has been closed, they will dispose of the details in line with our firm’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do so.

Retention of personal information

We will endeavour to keep your information accurate and up to date and not keep it for longer than is necessary. In some instances, the law sets the length of time information has to be kept, but in most cases, we will use our discretion to ensure that we do not keep records outside of our normal business requirements.

We will normally retain your data for a minimum of 7 years after the cessation of your tenancy, or longer where the continued holding of it can be legally justified. The length of time that we hold such data will vary depending on the type of data and the reason it was collected. Once your data is no longer needed, it will be securely destroyed.

Your rights

In summary, the General Data Protection Regulation (GDPR) provides the following rights for individuals:

• You have the right to be informed about the collection and use of your personal data. The details are contained in this Privacy Notice.
• You have the right to access your personal data and supplementary information. The right of access allows individuals to be aware of and verify the lawfulness of the processing. You may make a request to access the information that we hold about you that personally identifies you and can request that it be sent in a structured, commonly used and machine-readable format.
• The right to data portability also allows you to obtain and reuse your personal data for your own purposes across different services. It allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability.
• You also have the right to have your personal data rectified. Personal data can be rectified if it is inaccurate or incomplete.
• Depending on the circumstances, you may also have the right to “block” or suppress the processing of your personal data, this includes if you believe the data that we hold is not accurate.
• In certain circumstances you can also request the erasure of personal information we hold about you. Please see the Contact Us section below for details.

Security

We are committed to ensuring your information is protected and held securely. However, the internet is not a secure medium and we can’t accept responsibility for the security of an email during transmission or for non-delivery of that email. We have taken appropriate steps to protect some personal information in electronic transfer, e.g. emails. As such please be advised that some email attachments may be encrypted with a password to open the document.

Marketing

We may wish to contact you in the future regarding products and services that we think may be of interest to you. If we do, we will obtain your consent first before we contact you with any marketing material.

Contact us

For more information or to make a complaint regarding your personal data please contact us at: Fourbrooks Business Park Estate Management Limited, First Floor Unit 6, Fourbrooks Business Park, Stanier Road, Calne SN11 9PP

Telephone: 01249 815983

Complaints regarding personal data can also be referred to The Information Commissioners Office (ICO) on 0303 123 1113