Our Privacy Notice For Clients –

2 RIVERS PROPERTY MANAGEMENT LIMITED
PRIVACY NOTICE FOR CLIENTS

Introduction

We are a property investment and managing agent offering leasehold choice to Resident Management Companies, Right to Manage Companies, Landlords and Freeholders.

We are regulated by the Institute of Residential Property Management and are committed to ensuring that your privacy is protected. Our use of your personal information is governed by this Privacy Notice. We are a ‘controller’ under the General Data Protection Regulation (GDPR) and other relevant UK for the very limited personal information we collect and use. We will treat your personal information as confidential and in accordance with applicable data protection legislation and your personal information will only be shared with others in accordance with English law.

In accordance with ICO guidelines and the GDPR legislation the information which we collect can be summarised into seven equally weighted principles:

1. Lawful, fair, and transparent processing
2. Purpose limitation
3. Data minimisation
4. Accurate and up to date processing
5. Limitation of storage in the form that permits identification
6. Confidential and Secure
7. Accountability and liability

With these in mind, this Privacy Notice explains;

• What personal information is
• How we collect your personal information
• The types of personal information we collect
• How we use your personal information
• The legal basis for processing your personal information
• How we share your personal information
• How long we keep your personal information
• How we keep your personal information secure
• Your rights in relation to your personal information
• How to make complaints and how to contact us

What is personal information

Personal information is any information that tells us something about you. This could include information such as name, contact details, date of birth, bank account details or any information about your needs or circumstances which would allow us to identify you.

 What personal information do we collect?

We may collect your full name and contact details (such as phone number, email address and postal address) from you whenever you engage with us. Depending on the service that we provide to you (or on your behalf) we may also collect additional personal information as detailed below;

Companies House

If you are wanting to become a director on Companies House

• We will need to have your name, the contact information as shown above and in addition your nationality and date of birth in accordance with Companies House requirements.
• These are requested purely for the purpose of making the Companies House application and no more.

If you are wanting us to open a bank account for your company

• We will need to request details depending on the requirements of the bank.  This is also usually contact details, date of birth and details of a personal bank account which you may hold with the bank to which we are making your application.
• These are requested purely for the purpose of making the bank account application and no more.

If you are a supplier who wishes to become a preferred contractor;

• We will need to request your name and have your bank account details to allow us to pay you when services are rendered at any of our sites.
• We will also need to request information and proof of your Public Liability insurance and any qualifications where applicable.
• We may also ask for a risk assessments and method statements to ensure you comply with legislation regarding health and safety.

Property Management

If we are the managing agent for your premises, we may need to have;

• Names obtained from one of the following sources: management agreement, directly supplied via email, lease or transfer documents, previous managing agents, AP01 form (for new company director appointments), via letting agents, contractor review form or share certificates
• Correspondence address is obtained from one of the following sources: directly supplied via email, lease or transfer documents, information received from solicitors or developer upon completion, previous managing agents, AP01 form (for new company director appointments), via letting agents or contractor review form
• Service address is obtained from one of the following sources: directly supplied or previous managing agents
• Telephone number is obtained from one of the following sources: directly supplied via email / phone, information received from solicitors or developer upon completion, previous managing agents, AP01 form (for new company director appointments), concierge forms or via letting agents
• Email address is obtained from one of the following sources: directly supplied, information received from solicitors or developer upon completion, previous managing agents, sales agent moving in form, AP01 form (for new company director appointments), concierge forms or via letting agents
• CCTV images are obtained from the following source: CCTV cameras on the estates where there is surveillance present.
• Date of birth is obtained from one of the following sources: AP01 form (for new company director appointments).

 How we use your personal information

What is the legal basis of our data processing?

• Under data protection legislation we are only permitted to use your personal information if we have a legal basis for doing so. We rely on the following legal bases to use your information;
• Where we need information to perform the contract we have entered
• Where we need to comply with a legal obligation

In more limited circumstances we may also rely on the following legal bases:

• Where we need to protect your interests (or someone else’s interests); and/or
• Where it is needed in the public interest or for official purposes
• With your explicit consent, in which case we will explain the purpose for which the information will be used at the point where we ask for your consent

For specific information on how your personal information will be used for the services you have requested from us, please select from any of the options below;

Property Investment

• All initial personal information is collected by the lettings agent with whom we have an agreement.  This is obtained by them for ID and other checks and is covered by their GDPR policy.  When this is handed to us once a tenancy has been agreed, it is only done so with your consent.
• If you are already renting one of our properties, we may need to share your personal data with third party referencing agencies for the purposes of the prevention and detection of crime, fraud and/or money laundering and checking your suitability to rent that property
• We are sometimes also required by lending companies to provide proof of tenancies on which your personal data may be recorded.

Property Management

Where we are managing property on your behalf, we may need to pass your contact information from time to time on to third party contractors whom we have engaged to carry out maintenance on your properties. Specifically, to perform our contractual duties as managing agent, we may share the above categories of personal data with the following categories of recipients:

• External accountants
• Insurance brokers / providers
• Solicitors
• Debt recovery companies
• Contractors/Freeholders/landlords
• Management Company Directors
• Companies House
• Regulatory bodies for audit purposes
• Managing Agents for management handovers
• Ombudsman
• Bank
• ICO for subject access requests and breaches
• Emergency services upon request from the police

We will share personal information with law enforcement or other authorities if required by applicable law

 How we keep your information secure

The security of information is very important to us, and we have measures in place which are designed to prevent unauthorised access to your personal information.

For how long do we keep your personal information?

The period for which we will keep your personal information will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in case of a legal claim. In some cases, information is kept for up to 6 years to comply with our Professional Indemnity Insurance requirements.

 Your rights in relation to your personal information

You have several rights in relation to your personal information, these include the right to:

• Be informed about how we use your personal information
• Obtain access to your personal information that we hold
• Request that your personal information is corrected if you believe it is incorrect, incomplete, or inaccurate

Request that we erase your personal information in the following circumstances:

• If 2 Rivers Property Management is continuing to process personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected
• If 2 Rivers Property Management is relying on consent as the legal basis for processing and you withdraw consent
• If 2 Rivers Property Management is relying on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us to continue with the processing

If the personal information has been processed unlawfully (i.e., in breach of the requirements of the data protection legislation)

• If it is necessary to delete the personal information to comply with a legal obligation
• Ask us to restrict our data processing activities where you consider that:
• personal information is inaccurate
• our processing of your personal information is unlawful
• where we no longer need the personal information, but you require us to keep it to enable you to establish, exercise or defend a legal claim
• where you have raised an objection to our use of your personal information
• request a copy of certain personal information that you have provided to us in a commonly saved electronic format. This right relates to personal information that you have provided to us that we need to perform our agreement with you and personal information where we are relying on consent to process your personal information
• Object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection, we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal information; and
  Not be subject to wholly automated decisions which produce legal effects or which could have a similarly significant effect on you

Complaints and Contact Details

If you have any queries or complaints about the way we use your personal information please write to us at Crane Court, 302 London Road, Ipswich, IP2 0AJ.