GDPR data protection privacy notice (customers)
Trinity (Estates) Property Management Limited
Data protection privacy notice (customers)
This notice explains what personal data (information) we hold about you, how we collect it, and how we use and may share information about you whilst we are managing the development where your property is situated. This information relates to all customers (including but not limited to lessees, tenants, freehold property owners).
We are required to notify you of this information under data protection legislation. Please ensure that 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.
Who collects the information
Trinity (Estates) Property Management Company Limited (‘Company’) provide property management services to a wide variety of clients and as such, may act in the capacity of a data processor or a data controller.
Data protection principles
We will comply with the data protection principles when gathering and using personal information, as set out in our data protection policy.
About the information we collect and hold
The Company’s management obligations arise either from the leases and transfers to which Trinity are a party or where Trinity are appointed as managing agents. Further to the GDPR, Trinity’s lawful basis for processing personal data will be pursuant to contractual obligations to allow us to manage the development where your property is situated.
The information we collect and process to comply with our contractual obligations includes (but is not limited to):
- Your name
- Contact details (email address/ phone number)
- Bank details (where applicable)
- Credit/ debit card numbers where you make online payments or payments over the phone
- Disability information where relevant
- Any information received from third parties e.g. bankruptcy orders/ Court orders/ Judgments which could relate to any criminal matters or mental conditions
- Images which may be processed by any CCTV or electronic equipment present at your development
How we collect the information
We may collect this information from you, your agents (such as Solicitors that acted for you on purchase of your property or any letting agents), information in the public domain e.g. Land Registry, third parties we may engage in accordance with our contractual obligations such as enquiry agents/ Solicitors, surveyors, insurers and systems used e.g. door entry systems and CCTV.
Why we collect the information and how we use it
We will typically collect and use this information for the following purposes (other purposes that may also apply are explained in our data protection policy:
- for the performance of a contract with you, or to take steps to enter into a contract;
- for compliance with a legal obligation (e.g. our obligations to you as your Freeholder, named manager in your lease or transfer or where we are appointed by a third-party client (the Data Controller) to comply with their obligations pursuant to a contract to which you are a party); and
- for the purposes of our legitimate interests or those of a third party (such as our client), 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.
How we may share the information
In view of our role as managing agent, personal data could be shared with third parties in the following circumstances (note this is not an exhaustive list):
- Where a freeholder or directors of a Resident Management Company request information we will ensure we raise relevant queries to understand the nature of the request and the extent of the information requested to ensure they are entitled to the same.
- Where maintenance issues that affect you or your property arise and it is necessary to contact you for investigation of those issues/ repairs, we will try to contact you in the first instance. Your details may also be provided to the contractor(s) to contact you regarding any necessary work.
- However, you don’t need to worry, we have a duty to ensure any data processors on our behalf are GDPR compliant and that your data will be protected.
- Trinity collect service charge/ estate contributions funds from you as per your lease/ transfer terms. Should any sums due remain in arrears, it may be necessary for us in line with our contractual obligations, to pass your details to external Solicitors for legal action for recovery of those sums.
- Where requests are received from the Police or a Court Order, we will comply with our statutory obligations following verification of the requests in line with data protection laws or regulations
- We may also need to share some of the above categories of personal information with other parties, such as our professional advisers and with potential purchasers of some or all of our business or on a re-structuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. We may also be required to share some personal information with our regulators or as required to comply with the law.
Where information may be held
Information may be held at our offices and third-party agencies, service providers, representatives and agents as described above.
Sensitive personal information and criminal records information
Further details on how we handle sensitive personal information and information relating to criminal convictions and offences are set out in our data protection policy which is available from the HR department.
How long we keep your information
We keep your information for the duration you remain our customer by way of ownership or tenancy rights in respect of a property at a development for which the Company retain management or other rights. In the event the Company cease to manage the property/ development where the property is situated, information will be retained for a period of up to 12 years and for no longer than is necessary for the purposes for which the personal information is processed.
Your rights to correct and access your information and to ask for it to be erased
Please contact firstname.lastname@example.org if, (in accordance with applicable law) you would like to correct or request access to information that we hold relating to you or if you have any questions about this notice.
You also have the right to ask for some but not all of the information we hold and process to be erased (the 'right to be forgotten') in certain circumstances and can contact Trinity by email (as per the details above) should you have any queries in this regard.
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 breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that our Legal Department can resolve any query or concern you raise about our use of your information. If not, contact the Information Commissioner at ico.org.uk/concerns or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.
GDPR data protection privacy notice (customers)