General Data Protection Regulations (GDPR)

Concordia Residential respects your privacy and is committed to protecting your personal data when carrying out leasehold management duties. This privacy notice will inform you as to how we look after your personal data in ways that comply with the General Data Protection Regulations.

As your managing agent, we process the personal data of individuals. We do this to carry out our role as a managing agent. Whenever we do this, we will ensure that we are clear with those individuals about what we do with their data.

This notice explains what personal data we hold and states who we are,what we do, why and how we collect, store and share information.  It also explains the individual’s rights and how to contact us in case you should have a complaint.

Controller

Concordia Residential is the controller of individual’s personal information. We are regulated under the General Data Protection Regulation which applies to the European Union.

We will comply with the data protection principles set down by GDPR when gathering and using personal data.

The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). In the course of our leasehold management duties, we collect and process information relating to individuals. The information we collect (and how we handle that information) differs depending on who the individual is and why we are collecting their information. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data – includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data – includes billing address, delivery address, email address and telephone numbers.
• Financial Data – includes bank account, payment card details and details of your mortgage lender.
• Transaction Data – includes details about payments to and from you.
• Enquiries – includes details of any enquiries that you have reported to us.

Why We Collect It

This information is collected to enable us to fulfill our role carrying out leasehold management. It assists us with:

• Providing services to leaseholders and tenants.
• Improve our services.

Who We Share It With

We may share your personal data from time to time for a specific purpose. The following categories of individuals or companies may be the recipients:

• Solicitors, Barristers, Debt Collection Agents
• Insurers, Insurance Brokers
• Maintenance contractors
• Regulatory Bodies
• Energy Brokers
• Parking Enforcement
• Accountants
• IT Support
• Resident Associations (provided that consent is obtained)

We are required to share your personal data with law enforcement or other authorities as required by law. Your data will not be shared with any other third party.

Security

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised manner. Access to your personal data is limited to individuals who have a genuine business need to know it. Your data is processed in an authorised manner and will be kept confidential.

We have processes in place to recognise suspected data breaches and will notify you should we suspect that this has happened to the information that we hold about you.

How to Complain

We will always endeavour to address any queries or concerns that you may have concerning the processing of your personal information. On the rare occasion that you are not satisfied with the responses received, please contact us.

Please contact the Information Commissioner Office for further guidance.

Transfer of Information – Outside of EEA

We may transfer your data outside of the EEA due to the location of our servers or software providers. Data may be transferred to The United States of America in these instances. Please be advised that these platforms contain safeguards such as Privacy Shield.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for (carrying out leasehold management duties), including for the purposes of satisfying any legal, accounting, or reporting requirements. Concordia Residential will keep your data for the entirety of our management and then will retain it for 6 years should we cease to be your managing agent.

Your Legal Rights

The law gives you a number of rights to control what personal information is used by us and how it is used by us. You have the right to ask for the information we have about you. When we receive a request from you in writing, we must give you access to what personal information we’ve recorded about you.
However, we can’t let you see any parts of a record which contain:

• Confidential information about other people; or
• May be held in preparation to defend legal claims

This applies to personal information that is in both paper and electronic records. If you ask us, we’ll also let others see your record (except if one of the points above applies).
A request for personal information can be made via email to hello@cr.turner-close.top. This is known as a subject access request. In order to make a subject access request you will need to provide the following information:

• your name
• your address
• proof of identity and signature
• enough information to identify your records

What Types of Documents Could I Submit as Proof of ID?

• Copy passport with signature (please remove your passport number)
• Copy driving license picture with signature (please remove your driver number)
• Copy of signed tenancy or contract with us

We will not start your subject access request until we are satisfied that you have provided us with enough information for us to identify you. Once you have made a request you will receive an acknowledgement and your request should be answered within 30 days. You can ask to change information you think is inaccurate. You should let us know if you disagree with something we may have recorded about you. We may not always be able to change or remove that information, but we’ll correct factual inaccuracies and may include your comments in the record to show that you disagree with it.

Our Lawful Basis

Should you be a leaseholder or own a dwelling on a development that we manage, our basis for processing your data is contractual. If you are a tenant or other third party, we process your data as a legitimate interest.

ICO Registration: ZA478659