Privacy

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PRIVACY NOTICE

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Introduction
This Privacy Notice tells you what to expect when Herbert Collins Estates Limited processes personal information. It applies to information about company Members, Estates residents (including freeholders, leaseholders and tenants) and other service users. It tells you the purposes for which we may process your personal information and the legal basis for the processing, which includes us just keeping your personal information.

Definitions
“Company” means Herbert Collins Estates Limited,
“Member” means a member of Herbert Collins Estates Limited,
“Estates” means the Ethelburt Avenue (Bassett Green Estate) Conservation Area and other land of which the Company owns the freehold or land over which the Company has the benefit of restrictive covenants.

Why we need your personal information
Herbert Collins Estates Limited needs to collect, process and store personal information for Company administration purposes (such as maintaining member records and communicating with Members about Company business) and to operate as the freeholder of the Estates (including registering assignments of leases, collecting ground rents, selling freeholds, giving or withholding consents to alterations and taking any action if these are made without consent).

Our main legal basis for processing personal data is where it is necessary for the purposes of the legitimate interests pursued by the Company and also, for Members, the Companies Act 2006. The other reasons we can rely upon to process your personal information under the General Data Protection Regulation (GDPR) can be found in GDPR-Article 6.

How we use your information
The information we hold on our records concerns our relationship with you. For example:
• We hold names, addresses, telephone numbers, email addresses and the residential status of Members to enable us to assess your suitability for membership and to be able to communicate with you and keep you informed about Company business.
• We hold names, addresses, telephone numbers, email addresses and property ownership information about leaseholders and freeholders within the Estates to enable us to manage the Estates and deliver our responsibilities as a lessor and holder of covenants on properties.
• We record information to enable us to provide estate management services. For example, we record applications to undertake works to houses within the Estate that require our consent under the covenants.
• We keep financial records about the amount of money you have paid us; any amount(s) outstanding and action taken to recover money you owe.
This list is not exhaustive, as we hold records of most contacts we have with you, or about you, and we process this information so we can deliver services to you. Generally, the information we hold will have been provided by you (on application for membership or in response to enquiries when we communicate with you), but we may also hold information provided by third parties where this is relevant to the management of the Estates e.g. from Land Registry (such as information on property titles).
We will only ask for personal information that is appropriate to enable us to deliver our services. In some cases, you can refuse to provide your details if you deem a request to be inappropriate. However, you should note that this may impact our ability to provide some services to you if you refuse to provide information that stops us from doing so.

How we manage your personal information
We process your personal information in accordance with the principles of the GDPR. We will treat your personal information fairly and lawfully and we will ensure that information is processed for limited purposes; kept up-to-date, accurate, relevant and not excessive; not kept longer than is necessary; and is kept secure.

Access to personal information is restricted to authorised individuals on a strictly need to know basis. We are committed to keeping your personal details up to date, and we encourage you to inform us about any changes needed to ensure your details are accurate. We will not discuss your personal information with anyone other than you, unless you have given us prior authorisation to do so.
For the purposes of local history and Company history some documents containing personal information will be archived.

Sharing your information
Normally, only Directors of the Company and Members appointed by the Directors to undertake Company business will be able to see and process your personal information. However, there may be times when we will share relevant information with third parties, or where we are legally required to do so. When sharing personal information, we will comply with all aspects of the GDPR. At its discretion, the Company may share personal information with the Herbert Collins Estates Residents Association.
We reserve the right to access and disclose individually identifiable information to enable us to comply with applicable laws and lawful government requests to operate its systems and to protect itself or its users.

Your rights
You have a number of rights under the GDPR, as set out below. More information on your rights can be found in GDPR-Chapter 3.
Access to personal information – Under the GDPR, you have a right to ask us what personal information we hold about you and to request a copy of your information. Requests need to be made in writing and accompanied by proof of your identity. We have one calendar month within which to provide you with the information you’ve asked for (although we will try to provide this to you as promptly as possible). This will not generally include information that relates to your property, as this is not considered personal information.
Rectification – If you need us to correct any mistakes contained in the information we hold about you, you can let us know by contacting the Directors on hcel@herbertcollins.co.uk.
Erasure (‘right to be forgotten’) – You have the right to ask us to delete personal information we hold about you. We can refuse to erase your personal information where the personal information is processed for the reasons set out in GDPR-Article 17.
Restriction on processing – You have the right to require us to stop processing your personal information. When processing is restricted, we are allowed to store the information, but not do anything with it. You can do this for the reasons set out in: GDPR-Article 18/. We must inform you when we decide to remove the restriction giving the reasons why.
Objection to processing – You have the right to object to processing where we say it is in our legitimate business interests. We must stop using the information unless we can show there is a compelling legitimate reason for the processing, which overrides your interests and rights or the processing is necessary for us or someone else to bring or defend legal claims.
Withdrawal of consent – You have the right to withdraw your consent to us processing your information at any time. If the basis on which we are using your personal information is your consent, then we must stop using the information. We can refuse if we can rely on another reason to process the information such as our legitimate interests.
Right to data portability – You have the right to receive an electronic copy of your personal data for passing on to another company but this right only applies when processing has been carried out by us using automated means.

Changes to this Privacy Notice
We keep our privacy notice under regular review and will place any updates on our website at www.herbertcollins.co.uk/the-company/privacy/; you will be notified of any major changes to it.

How to contact us
For further information on how to request your personal information and how and why we process your information, you can contact the Directors via email or write to the Company’s Registered Office:

The Information Commissioner
The Information Commissioner’s Office (ICO) is also a source of further information about your data protection rights. The ICO is an independent official body, and one of their primary functions is to administer the provisions of the GDPR.
You have the right to complain to the ICO if you think we have breached the GDPR. You can contact the ICO at:
Information Commissioner’s Officer, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. www.ico.org.uk. Tel: 0303 123 1113.

Last revised 10th July 2018

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