Privacy Policy

The purpose of this notice is to explain and inform you of what personal data we may ask for and collect, how we manage it and what we do with it. 

During the course of our activities and business operations, we will process personal data, which may be held on paper, electronically, or otherwise, about you and we recognise the need to treat it in an appropriate and lawful manner. 

We, The Corporate Lettings Company, a registered limited company in England and Wales under registered company number 12196491, take the issue of security and data protection very seriously and endeavour to strictly adhere to guidelines published in the General Data Protection Regulation (GDPR) (EU) 2016/679, which is applicable from the 25th May 2018, together with any domestic laws subsequently enacted.

We are notified as a Data Controller with the Information Commissioner’s Office (ICO) and are the data controller of any personal data that you provide to us. 

How our staff know about GDPR and know their data protection responsibilities.

All our staff are trained on company procedures and given written information surrounding your personal data, made aware of their responsibilities under the General Data Protection Regulation (GDPR) and must sign and date to confirm they understand this. 

Why we ask for, collect and hold your personal data.

Some personal data that we ask for, collect, hold and use that may be about you and/or a third party may be necessary for us to provide our services, carry out our business operations, is lawfully required by the contracts we enter, our regulators and/or by industry regulations and may vary depending on the nature of enquiries and therein requirements from us. 

Some personal data that we ask for, collect, hold and use that may be about you and/or a third party may be optional for you to provide us and is not specifically required to provide our services, carry out our business operations nor lawfully required by the contracts we enter, our regulators and/or by industry regulations, but may be mutually beneficial to achieve certain outcomes and provide certain services that may include, but may not be limited to:

· Time management 

· Security of sending data quickly and securely between us 

· Enhancing our services to you 

What personal data we may ask for, collect and hold.

We may ask for, collect, hold and use the following personal data about you and/or a third party, much of which will depend on your status, e.g. as an investor, landlord or tenant,  and that may include, but may not be limited to and/or may vary depending on your status, enquiries and therein requirements from us:

Personal details; name; date of birth; nationality; national insurance number; marital status; contact details; home/resident addresses and how long you lived there

Property; addresses; mortgage documents; licensing certificate; insurance documents; utility service bills; maintenance certificates

Company; Companies House registration details and trading name; business address; contact details; business partners, shareholders and/or employee personal details as outlined above

Employment; company name; addresses; contact details; Director’s/Manager’s name and their contact details; employment status; job title; length of employment; salary/income 

Banking (personal and/or company’s); bank’s name, account number, sort code, credit and/or debit card information 

Financial status; insolvencies; bankruptcies; government benefits/credits claimed; outstanding loan agreements, credit cards and/or store cards including agreed limits, amounts owed, when they are owed by and regular payment amounts made 

Previous tenancies; tenancy evictions; monies owed or previously owed to landlords or third parties 

Criminal status; criminal convictions; current police investigations and/or ongoing prosecutions 

Health status; whether or not you smoke; underlying and previous health issues; disabilities 

Children that visit or stay with you under the age of 18 years old; name; date of birth; nationality; national insurance number; marital status; contact details; home/resident address

Pets that visit or stay with you; type/breed of animals 

Copies of personal documents; Pay slips; UK driver’s licence; passport; VISA 

Contractual; term of agreement; deposit amounts; rent amounts; utility and/or service responsibilities 

How we may collect personal data from you.

We may collect your personal data in various ways, directly from you or via other means and/or depending on your status that may include, but may not be limited to: 

· Emails sent to us

· Visiting and enquiries via our website

· Content, posts and/or messages via our social media channels and/or ads

· Your social media channels that are and/or that you have chosen to make available, publicly or otherwise

· Online search engines that are publicly available 

· Speaking with us on the phone and/or leaving us voice messages 

· SMS text messages and other digital messaging platforms 

· Online platforms/websites 

· Reference checks with third party companies, organisations, government bodies and/or law enforcement 

· Third party referrals 

· Estate, letting and/or managing agents 

· Landlords 

· Utility service providers 

· Maintenance contractors 

How we may use your personal data.

We may use your personal data in various ways to help you with your enquiries and therein requirements from us and/or use for business operations that may include, but may not be limited to:

· Undertaking and performing our obligations and duties to you in accordance the law, industry regulations and/or terms of our contract with you 

· Enabling us to provide you with the services and information that you have requested 

· Carrying out due diligence, e.g. credit checks, immigration checks, right to rent checks

· Helping you to manage your contracts and/or tenancies 

· Analysing personal data we ask for, collect and hold so that we can administer, support, improve and develop our business and/or the services that we offer 

· Contacting you for company marketing purposes 

· Contacting you in order to send you details of any changes to our suppliers, partners and/or company that may affect you 

· To protect you in emergencies 

How we hold and keep your personal data secure.

We only use industry approved and/or reputable companies and online systems/platforms and we make every reasonable effort as required by us by the General Data Protection Regulations (GDPR) to ensure that there are adequate safeguards in place to protect your information in accordance with this notice. 

We take the appropriate steps to make sure that your personal data is held and kept secure. The ways in which we do that may include, but may not be limited to:

· All our computers on which your personal data is held require administrator or individual user passwords to use when switching on or unlock 

· All personal data is backed up on hard drives and/or third party cloud service platforms, e.g. iCloud, Dropbox, Google Drive 

· All users log off and/or lock their computers when away from their computers and/or desks

· Online systems/platforms and company accounts for these systems/platforms to which your data is held is protected by account login passwords and further passwords where required by the system/platform to access your information 

· All online system/platform passwords are themselves held on third party online systems/platforms protected by further passwords where required

· Full addresses for keys to properties that we hold on your behalf are never written on the keys or on/within the storage that the keys are held, but recorded digitally and held on our online systems/platforms as described above 

· Keys are physically held in secure locations and not visible or easily accessible to any third party without approved access

· When we take your personal data out of the office, we only take what we need for the job required and do not leave it anywhere and/or with anyone that is not privy to it 

Who we may share your personal data with.

The personal data that we ask for, collect and hold will be treated by us as strictly confidential. We may only share your personal data with third parties for the purposes set out in this notice and that may include, but may not be limited to:

· Companies that own the online systems/platforms that we use for business operations 

· Your landlord where we are contractually managing their property on their behalf

· Financial companies and organisations for mortgage, insurance, payment and other financial means 

· Utilities and service providers 

· Contractors for maintenance works required at the property to ensure it is kept safe and legal 

· Government bodies and local authorities, e.g. the Department for Work and Pensions 

· Estate, letting and/or managing agents  

· You next of kin and emergency services in an emergency where we deem your health and/or safety is at risk 

· Future owners/landlords of the property that we own or contractually manage that our clients own and will be selling 

· Professional advisors, e.g. our lawyers and accountants 

· Obtaining references from other relevant parties whose data you have provided 

· Companies that we pay to carry out checks, referencing and/or due diligence on you 

· Determining if there are any money judgements against you or to determine if you have a history of bankruptcy or insolvency 

· Debt collection and tracing agencies for assisting in the recovery of debt owed to us and/or our clients 

· Industry bodies for the creation, renewal or termination of contracts 

· Your guarantors whose data you have provided

· Your joint tenants whose data you have provided

· Entering into a joint venture, merge or acquisition with a business entity and disclosed to our new business partners, shareholders and/or owners 

Unless lawfully required by government bodies, local authorities, law enforcement agencies, our regulators and/or by industry regulations, we will not otherwise share, sell, distribute your personal data or use your personal data for activities and/or operations outside of our business services and operations without your written consent. 

Your information will only be held and transferred outside the UK and EEA unless; 

· You are not an EU National for the purposes of the points stated within 

· We use online systems/platforms for business operations owned and run by companies based outside the UK and/or EEA 

How we keep your personal details up to date.

We will check regularly with you to ensure your personal details are up to date, however in the meantime, please help us keep our records updated by informing us of any changes to your personal data whereby we will update our records accordingly. 

How we deal with a breach of your personal data.

A personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data. This includes breaches that are the result of both accidental and deliberate causes. It also means that a breach is more than just about losing personal data. 

If a breach is likely to result in a high risk to the rights and freedoms of individuals, the General Data Protection Regulation (GDPR) states we must inform those concerned directly and without undue delay, in other words, as soon as possible. 

In the unlikely event that your personal data is breached by any means and the above applies, we will endeavour to inform you within 72 hours of us becoming aware of the breach. 

How long we keep your personal data for and how we will dispose of it.

Personal data can only be stored on a time limited basis and not indefinitely. 

We will hold your personal data for the duration of the contracts between us or third parties and for up to seven years after these contracts officially end or are terminated. 

This is the statutory limitation period six years plus a further one year to allow for service of proceedings should proceedings commence later. We are also required to retain personal data for up to six years for tax purposes. 

If you’re a tenant and your tenancy application does not go ahead, we may retain personal data for one year. 

Where requested or required, your personal data will be deleted/destroyed in an appropriate and secure manner that may include, but may not be limited to:

· Shredding of paper documents and disposed of in a shredding bin

· Permanent removal and/or deletion from online digital platforms, hard drives and/or cloud services 

Your Individual Rights

You have several individual rights under the General Data Protection Regulation (GDPR) that include, but may not be limited to:

The right to be informed; being told what data we hold about you and what we do with it.

The right of access; being able to request a copy of your personal data that we hold

The right to rectification; being able to have inaccurate data corrected.

The right to erasure; being able to ask us to delete/destroy your personal data.

The right to restrict processing; being able to limit the amount or type of personal data used.

The right to data portability; requesting to move your personal data electronically to another business.

The right to object; being able to request that we stop using your data.

You can view your full individual rights at https://ico.org.uk/your-data-matters/ 

You may request any of your individual rights either verbally, in writing by letter, email and/or by other electronic means. 

We have one month from the date of your request to comply, unless the last day of the one month period falls on a weekend or bank holiday where we then have until the end of the next working day.

If we require further details or wish to discuss your request with you, we will contact you. 

We do not own your personal data and cannot charge you for any request that is made by you in relation to your individual rights. 

Our Data Protection Officer is Jay Duncan.

If you have any questions relating to this notice, our privacy practices, to request a copy of our certificate of registration with the Information Commissioner’s Office (ICO) and/or to exercise any of your individual rights, please email to info@thecorporatelettingscompany.uk to ensure that your requests are dealt with in a timely manner. 

Should you wish to complain about the use of your personal data, we would respectfully ask that you email info@thecorporatelettingscompany.uk to resolve any matters in the first instance. 

You also have the right to complain to the Information Commissioner’s Office (ICO). The Information Commissioner’s Office (ICO) relevant contact details can be found at https://ico.org.uk/global/contact-us/