This privacy notice explains what personal data (information) we hold about you, how we collect it, and how we use and may share information about you during out management of the property and after it ends. We are required to notify you of this information under the General Data Protection Regulation.
Please ensure 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. This privacy notice contains important information on who we area, how and why we collect, store, use and share your personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
Who we are
SPL Property Management LLP (OC346661) of Lorne Park House, 1 Lorne Park Road, Bournemouth BH1 1JJ collects, uses and is responsible for certain personal information about you. We are responsible as both a ‘controller’ and ‘processor’ of your personal information in relation to the General Data Protection Regulation. In this policy, any reference to “we” or “us” means SPL Property Management LLP.
Data Protection Principles
We will comply with the data protection principles when gathering and using personal information, as set out in this policy.
The personal information we collect and use: Information collected by us In the course of the performance of our contract as Managing Agent for the development where you are a leaseholder, we collect the following personal information when you provide it to us:-
Contact – how we correspond with and contact you
Ownership – details of the lease/agreement you have for your property
Transactional – your service charge and ground rent payment history
Identifying – your name, date of birth etc.
Communication –e-mails, telephone conversations, letters you have with us
Family – relevant information about family members which you may provide from time to time
Account – mortgage details
The provision of the above information is required from you to enable us to perform our contract as Managing Agent. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
The personal information we collect and use: Information collected from other sources
We also obtain personal information from other sources as follows:
Identifying, Ownership and Contact details from our Client
Identifying, Ownership and Contact details from Solicitors who may act on your behalf
We may be provided with additional personal information about you during the course of our management. Where this is the case, the information will only be retained if it is in line with our management obligations and the source is verified.
How we use your personal information
We will typically collect and use this information for the following purposes:-
– For the performance of a contract you have with our Client and pursuant to which we are appointed as their agent. This contact will usually be your Lease, TP1 agreement, or similar. and/or
– For the purposes of our legitimate interests or those of a third party, 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.
Who we share your personal information with
We will only use your data in line with the terms of our management contract and in line with any consent granted by you.
We routinely share personal data with our Client in line with their legitimate interests in the data.
With your consent, we will provide your data to third party contractors who may need to contact you in relation to your property.
Data is routinely shared with the following further parties:-
Database Management System
Debt Recovery Solicitors
Document Transfer Systems
Electronic Cloud Storage
In such cases, details are only shared in so far as they are necessary for the third party to perform their duties and for us to fulfil our duties under our management agreement.
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your information with any other third party.
Where your personal information may be held
Personal data will be held at our offices and by any third parties detailed above.
We have measures in place to ensure appropriate security for information held, including those details within this GDPR Data Protection Policy.
How long your personal information will be kept
We will hold you data for the following terms:-
Contact – For the duration of our management contract
Ownership – For the duration of our management contract
Transactional – For 6 years from the date of the transaction or the duration of our management contract – whichever is the greater
Identifying – For the duration of our management contract and 6 years thereafter
Communication – For 6 years from the date of the transaction or the duration of our management contract – whichever is the greater
Family – For the duration of our management agreement
Account – For the duration of our management agreement
If you sell the property we do need to retain adequate accounting records and identifying records in this respect. We will only retain any details as far as they are relevant to our duties under our management contract.
Reasons we can collect and use your personal information
We rely on our management agreement as the lawful basis on which we collect and use your personal data
Transfer of your information out of the European Economic Area
We may transfer your personal information to the following which are located outside the European Economic Area (EEA) as follows:
– The USA in order to store data and access our e-mail programme.
Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that The USA provides an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal information will be subject to a Data Processing Amendment of the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. To obtain a copy of the Data Processing Amendment please visit https://gsuite.google.com/terms/dpa_terms.html. If you would like further information please contact us (see ‘How to contact us’ below). We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
– fair processing of information and transparency over how we use your use personal information
– access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
– require us to correct any mistakes in your information which we hold • require the erasure of personal information concerning you in certain situations
– receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
– object at any time to processing of personal information concerning you for direct marketing
– object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
– object in certain other situations to our continued processing of your personal information
– otherwise restrict our processing of your personal information in certain circumstances
– claim compensation for damages caused by our breach of any data protection laws
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK
Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation. If you would like to exercise any of those rights, please:
– email, call or write to us at SPL Property Management LLP, Lorne Park House, 1 Lorne Park Road, Bournemouth BH1 1JJ
– 01202 555560 – firstname.lastname@example.org
– let us have enough information to identify you (eg full name, address and property address)
– let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill)and
– let us know the information to which your request relates, including any account or reference numbers, if you have them
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 security 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 we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at
https://ico.org.uk/concerns/ or telephone: 0303 123 1113
Changes to this privacy notice
This privacy notice was published on 24 May 2018 and last updated on 24 May 2018.
We may change this privacy notice from time to time, and when we do we will inform you
What our clients say about us
We would recommend you to anyone. Nothing is too much trouble it seems.
Mr and Mrs J Stevens