Hunter Grey Limited

Data Protection Policy
Definitions
"we" Hunter Grey Limited
"our" Hunter Grey Limited
"you" The person, firm, company or organisation
"your" The person, firm, company or organisation
"GDPR" European General Data Protection Regulation

Date of Publication 15 May 2018
Date of Review 15 May 2018
Manager Responsible George Tambaros
Approved by Corporation

Goal of this data protection policy

Hunter Grey Limited is committed to a policy of protecting the rights and privacy of individuals in accordance with the General Data Protection Regulation (GDPR). The GDPR has placed a great demand on organisations to ensure transparency and accountability in how we use, process and protect personal data. Above all, the GDPR affords you, the individual, stronger rights.

One requirement of the GDPR it that we must ensure that our privacy notices are written in clear, understandable language.

Hunter Grey Limited is required, by the very nature of its business, to collect, store and process certain personal information including, but not limited to:

  • Identity Numbers and/ or date of birth of individuals;
  • Contact telephone numbers;
  • Contact e-mail addresses;
  • Account and/ or payment history.

To comply with various legal obligations, including the obligations imposed on it by the GDPR, Hunter Grey Limited must ensure that all personal information collected is used, stored and processed safely and fairly and not disclosed to any third party unlawfully.

The goal of this data protection policy is to depict the legal data protection aspects in one summarising document. It can also be used as the basis for statutory data protection inspections, e.g. by the customer within the scope of commissioned processing.

Data collection

Informed consent is when:

  • An individual clearly understands why their information is needed, who it will be shared with, and the possible consequences of them agreeing or refusing the proposed use of the data.
  • An individual grants consent.

Hunter Grey will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, or by completing a form. We may occasionally request information from third parties including, but not limited to, solicitors and rental agents to provide information that is applicable. Information may also be collected during the registration process of a property.

Prior consent from individuals is often the best way to ensure that data is collected and processed in an open and transparent manner. This is especially important when we are processing any sensitive data, as defined by legislation.

When collecting data, Hunter Grey Limited will ensure that the Individual:

  • Clearly understands why the information is needed.
  • Understands what it will be used for and what the consequences are should the individual decide not to give consent to processing.
  • As far as reasonably possible, grant explicit consent, either in writing or verbally, for data to be processed.
  • Is, as far as reasonably practical, competent enough to give consent and has given so freely without any duress.
  • Has received sufficient information on why their data is needed and how it will be used.

The above process will be carried out by means of a form which contains a statement explaining the use of the data, how the data may be disclosed and further indicate whether or not the individual needs to consent to the processing.

Processing of Information

At least one of the following will apply when processing personal information:

  • Consent: The data subject has given clear consent for us to process their information for a specific reason.
  • Contract: The processing can be necessary under the management contract that appointed Hunter Grey for management services.
  • Legal Obligation: The processing is necessary for Hunter Grey or the management company to comply with the law.
  • Vital Interests: The processing is necessary to protect someone's life.
  • Legitimate Interest: The processing is necessary for our legitimate interests or the legitimate interests of the managing company.

Hunter Grey Limited will need to collect certain personal information when appointed as the managing agents. Personal information collected will be used for distribution of service charge demands, ground rent demands and any other demands as deemed necessary according to the specific lease. The information kept will be used for communication regarding the management of the building, issuing of appropriate notices in accordance with law i.e. section 20 notices etc.

The personal data collected will also be used for the registration process of transfers according to the lease agreements.

Access to information

All individuals have the right to access the information Hunter Grey Limited holds about them. Any individual wishing to exercise this right may do so via an application form.

Under the terms of legislation, any such requests must be complied with within 40 days.

Hunter Grey Limited will take reasonable steps to ensure that information held about the individual is up to date and accurate.

In addition, Hunter Grey Limited will ensure that:

  • Everyone processing personal information understands that they are contractually responsible for following good data protection practice.
  • Everyone processing personal information is appropriately trained to do so.
  • Everyone processing personal information is appropriately supervised.
  • Anybody wanting to make enquiries about handling personal information knows what to do.
  • It deals promptly and courteously with any enquiries about handling personal information.
  • It describes clearly how it handles personal information.
  • It will regularly review and audit the ways it holds, manages and uses personal information.
  • It regularly assesses and evaluates its methods and performance in relation to handling personal information.
  • All staff are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action.

The individual has the right to be “forgotten” In accordance with GDPR, this will only be done when an application is completed. The application form is free of charge. This application will only be considered when we have no further contractual relationship with yourself and no longer require your information to perform specific tasks. Information required to be retained in terms of any law, will be excluded from this request. In the event of data being processed for legal purposes the individual has no right to erasure, right to data portability, or right to object.

Sharing

Any and all personal information collected by Hunter Grey Limited will be kept strictly confidential. It will not be sold, loaned, reused or otherwise disclosed to any unauthorised third-party organisation.

Hunter Grey Limited may share data with other agencies such as the local authority, funding bodies and other authorised and relevant agencies.

The individual will be made aware, in most circumstances, how and with whom their information will be shared. There are circumstances where the law allows Hunter Grey Limited to disclose data (including sensitive data) without the data subject’s consent.

These are:

  • Carrying out a legal duty or as authorised by the Secretary of State.
  • Protecting vital interests of an Individual/Service User or other person.
  • The Individual/ Service User has already made the information public.
  • Conducting any legal proceedings, obtaining legal advice or defending any legal rights.
  • Monitoring for equal opportunities purposes, i.e. race, disability, religion etc.
  • Providing a confidential service where the Individual/ Service User’s consent cannot be obtained or where it is reasonable to proceed without consent, e.g. where we would wish to avoid forcing stressed or ill Individuals/Service Users to provide consent signatures.

Hunter Grey Limited regards the lawful and correct treatment of personal information very important to a successful working environment and to maintaining the confidence of those with whom it deals.

Data Storage

Information and records relating to service users will be stored securely and will only be accessible to authorised staff. Digital data may be stored outside the EU. The necessary steps will be taken to ensure appropriate safeguards apply to the data.

Information will be stored for only as long as it is needed or required by statute and then disposed of appropriately.

It is Hunter Grey Limited’s responsibility to ensure that all personal and company data is non-recoverable from any computer system previously used within the organisation, which has been passed on/ sold to a third party.

Data Breaches

In the event of a data breach, the individual becoming aware of the breach should inform management immediately of the breach. This will be documented via a completed and filed form. In the event of a data breach, the data subjects should be informed of same, as well as the steps to be taken.

Procedure for Review

This policy will be updated as necessary to reflect best practice or future amendments made to the General Data Protection Regulation (GDPR) May 2018 and Data Protection Act 1998.

Please follow this link to the ICO’s website (www.ico.gov.uk), which provides further detailed guidance on a range of topics including individuals’ rights, exemptions from the Act, dealing with subject access requests, how to handle requests from third parties for personal data to be disclosed etc. In particular, you may find it helpful to read the Guide to Data Protection, which is available from the website.

For help or advice on any data protection or freedom of information issues, please do not hesitate to contact:

The Data Protection Officer (DPO): George Tambaros, Principal.

LKP