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The General Data Protection Regulations (GDPR)
Privacy Notice Red Rock Estate and Property Management Ltd (“The Company”) collects and processes personal data relating to its clients and customers to manage the business relationship. We are committed to being transparent about how we collect and use that data and to meet our data protection obligations. As part of our business, we are instructed by your Management Company or your property owner to act as Manging Agents to undertake their respective obligations to property owners pursuant to your lease and/or transfer. It is for that purpose and on behalf of such entities, that we collect and process your data. If you are the owner of a property (“property”) either as a leaseholder, or the freeholder of a house forming part of a development (“development”) owned or managed by a Management Company, or a landlord, we will collect and process your data on a day-today- basis. If you are a tenant living in a development or property for which we act as Managing Agents, we will hold very limited personal data, if any at all. This information would only be collected or processed in the event of an emergency such as; a leak, flood or fire.
Leasehold Flats If the property is leasehold, you may pay ground rent to the landlord and in all cases a proportion of the premium to allow the development to be insured. We may be instructed, by the landlord, to collect ground rent and the insurance premium. Under the terms of the lease of the property you will be entitled to require the landlord, or in some cases a Management Company, to provide services such as; gardening, maintenance of the common parts, cleaning etc., for which you will pay a service charge.
Freehold Houses If the property is a freehold house, and there are communal areas shared with other residents, under the terms of the purchase documentation, you will be obliged to pay towards the maintenance of the communal areas and Insurance.
Management Agency Whether the property is a leasehold flat or a freehold house, we are instructed by the landlord or Management Company, to carry out on its behalf, the provision of the services and collection of monies due in respect thereof. Any insurance premiums collected prior to the commencement of the insurance year. Service charges, on the other hand, are payable in arrears and based upon the figures which appear in the year-end service charge accounts. All documents will provide for payments on account and these will be demanded prior to the financial year in question.
What information does the company collect? We collect and process a range of information about our customers and clients. This includes:- • Your name, address and contact details, including email address, telephone numbers and any other address for service • Financial information with regard to monies due, owed or received in relation to service charge or ground rent payments • A record of all correspondence received via; phone, email, letter, correspondence and any calls made out of hours through our out of hours emergency helpline We may collect this information in a variety of ways. For example, through:- • an owner data form, which we ask you to send to us when you have completed your purchase of a property, and when we take on the everyday running of new developments • the records maintained at Land Registry/Companies Registry • our out of hours emergency helpline in relation to an emergency • the “contact us” page from our website • email enquiries through our manned reception mailbox, or via email through specific members of staff • telephone enquiries through our reception/switchboard • other correspondence with you and • in some cases, personal data from a third party, such as your solicitors
Why do we process personal data? We need to process data to enable the preparation of the service charge demands and/or ground rents or (when required) to demand outstanding payments. In some cases, we need to process data to ensure that we are complying with our legal obligations relating to the property, owed to the Management Company, or the landlord and to you. We have a legitimate interest in processing personal data during our management of the property. Processing personal data allows us to:- • Efficiently run service charge/ground rent demands • Prepare annual budgets and planned preventative maintenance • Arrange and provide services • Maintain accurate and up-to-date records and contact details • Operate and keep a record of processes and legislation followed • Plan and prepare for long term works and budgets • Control and keep a record of monies due, owed or received in relation to service charge or ground rent payments • Obtain professional advice, to ensure that we meet our obligations under Health and Safety Law and relevant legislation as applicable • Respond to and defend against complaints and/or legal claims
Who has access to data? Your information will be shared internally with Red Rock Estate and Property Management Limited staff for the purposes of dealing with the day-to-day management of the development. As part of the management process we may share your data with the Board of Directors and individual Directors of the Management Company and/or the landlord. We will also share limited data (e.g. your name and contact details) with contractors who need to make contact with you in relation to specific areas of management. Where possible, this will be done so with clear written consent, however during out of hours emergencies we may need to share your name and contact telephone number with a contractor to attend to emergencies such as leaks, flooding or fire. In accordance with our obligations within the documentation relating to the property, limited data will also be shared with your property or developments Insurers, who often request your name and address to be specifically added to the Policy. Each year the financial element of the data is made available to independent accountants for the purposes of preparing and completing the year-end service charge accounts. From time to time, the financial element of the data together with some personal data (such as your property details and the funds received) is open to inspection by an accountancy officer appointed by our professional governing bodies for the purposes of audits. By Law we may be required to make available the financial element of the data together with some personal data to HM Revenue & Customs for tax purposes. We are bound to comply with money-laundering legislations and are required to make available the financial element of the data together with some personal data to the relevant authorities. We will also share your data with third parties such as; solicitors and debt collection agencies, if and when applicable. In all these circumstances the data will be subject to confidentiality arrangements. Otherwise we will not share your data with third parties. We will not transfer your data to countries outside the European Economic Area (EEA).
How will the company protect data? We take security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed and it is not accessed except by our employees in the proper performance of their duties. The data is stored centrally on encrypted servers and upon networked company owned workstations used by our employees. All electronic storage systems are governed by password and a hierarchy of access users. Where we engage with third parties to process personal data we do so under the duty of confidentiality and under obligation to implement an appropriate technical and organisation measure to ensure the security of data.
How long with the company keep data for? We will hold your personal data for the duration of our appointment as Managing Agents. Thereafter the periods for which your data is held will remain in accordance with our legal retention obligations. Data regarding the processing of financial information with reference to the collection of service charge, ground rents and other financial information in relation to the management; is kept for a period of six years after the expiry of each financial year of management. Personal data such as contact details; telephone numbers and email addresses will be discarded immediately.
Your Rights As a data subject, you have a number of rights which include your right to:- Access and obtain a copy of your data maintained by us Submit a subject access request Require us to change incorrect or incomplete data Require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of management of your property and Object to us processing your data where we are relying on our own legitimate interests as the legal ground for processing. This may arise if you have disposed of your interest in the property but have failed to formally tell us in writing. If you would like to excercise any of these rights, please contact our Data Protection Officer on the details below. If you believe we have not complied with your data protection rights, you can make a complaint to the Information Commissioner.
Data Controller Red Rock Estate and Property Management Ltd Red Rock House Unit 5, Wix Road Beaumont Cum Moze Essex CO16 0AT Telephone no: 0333 123 5670 Email: firstname.lastname@example.org Data Protection Officer Kelly Frost – Administration Manager Telephone no: 0333 123 5670 Email: email@example.com