Fair Processing Notice:
This notice explains what information we collect, when we collect it and how we use it. During the course of our activities, we will process personal data (which may be held on paper, electronically or otherwise) about you and we recognise the need to treat it in an appropriate and lawful manner. The purpose of this notice is to make you aware of how we will handle your information. Our aim is to store your information securely for an appropriate amount of time and to only share the minimum amount of that information, if necessary, with relevant third parties.
Who are we?
Crenns Properties Ltd, a Private Landlord, takes the issue of security and data protection very seriously and strictly adheres to guidelines published in the General Data Protection Regulation (EU) 2016/679 which is applicable from the 25th May 2018, together with any domestic laws subsequently enacted.
We are notified as a Data Controller with the Office of the Information Commissioner under registration number ZA387121 and we are the data controller of any personal data that you provide to us.
Our Data Protection Officer is Simon Crisp.
Any questions relating to this notice and our privacy practices should be sent to Simon - contact details on our Contact Us page.
How we collect information from you and what information we collect
It is necessary for us to collect various items of personal information in order to provide our rental service to you.
We collect information about you:
- From your request to view accommodation or receive additional information about accommodation (Lawful basis for holding this information: Legitimate interest)
- Via email, an online form or phone call;
- From your application for or reservation of accommodation (Lawful basis for holding this information: Contract, Legitimate Interest and Legal Requirement)
- Via a completed lease, email, an online or paper form, phone call or in person.
The information we collect from you may include the following:
- Your name, e-mail address, telephone number, date of birth, address (including any previous addresses), marital status, National Insurance Number, nationality. Lawful basis for holding this information: Contract;
- Next of kin, parents' details, name of university or college where you are studying (if applicable), the name of friends that you are staying with (if applicable). Lawful basis for holding this information: Legitimate interest;
- Guarantor name, e-mail address, telephone number, date of birth, address (including any previous addresses), marital status, National Insurance Number, nationality, next of kin (if applicable). Lawful basis for holding this information: Contract;
- Property address, term, rent, deposit, utility and service responsibilities. Lawful basis for holding this information: Contract;
- Previous landlord's name, address, email address and phone number. Lawful basis for holding this information: Contract;
- Copies of your passport, visa, residency permit and national identity card information. Lawful basis for holding this information: Legal Requirement;
- All information contained in references Lawful basis for holding this information: Contract;
- The employment status of you and/or your guarantors, address, contact details (including email, phone and fax numbers) of the employer/accountant, payroll numbers, length of employment, salary information (including any regular overtime or commission), and any other income received. Lawful basis for holding this information: Contract;
- Your bank account details, or bank account details for anyone making a payment on your behalf, including card type, card number, start and expiry date, issue number, CV2 data, name of cardholder, name of bank, address the card is registered to, account number and sort code, and any hire purchase/loan agreements/credit cards or store cards that you have. Lawful basis for holding this information: Contract;
- Lifestyle and social circumstances, including any welfare benefits that you may be eligible for, or are currently on. Lawful basis for holding this information: Contract.
Why we need this information about you and how it will be used
We need your information and will use your information:
- To undertake and perform our obligations and duties to you in accordance with the terms of our contract with you (this includes maintenance requirements);
- To enable us to supply you with the services and information which you have requested;
- To help you to manage your tenancy;
- To carry out due diligence on any prospective tenant, including whether there is any money judgements against them, or any history of bankruptcy or insolvency;
- To analyse the information we collect so that we can administer, support and improve and develop our business and the services we offer;
- To contact you, on occasion, to send you information about upcoming events related to us or our suppliers that we feel may be of interest to you;
- To contact you in order to send you details of any changes to our suppliers which may affect you;
- For all other purposes consistent with the proper performance of our operations and business.
Sharing of Your Information
The information you provide to us will be treated appropriately and securely and will only be processed by a third party, acting on our behalf, within the UK/EEA. Note that if a request for a reference is made by someone outside the UK/EEA then the data will be sent as required, following your approval, outside the UK/EEA.
We may disclose your information to other third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:
- To carry out due diligence on you as a prospective tenant/ guarantor, including but not limited to the carrying out of affordability checks, due diligence checks and the obtaining of references from relevant parties, whose data you have provided;
- To determine if there are any money judgements against you, as the prospective tenant/guarantor, or to determine if you, as the prospective tenant/guarantor, have a history of bankruptcy or insolvency;
- If you are unable to make payments under your tenancy, your information may be disclosed to any relevant party assisting in the recovery of this debt or the tracing of you as a tenant;
- In response to a request for a reference that has been initiated by you but may come via a third party;
- To maintenance contractors, suppliers of goods or services, utility service providers, financial organisations, credit reference agencies, debt collection and tracing agencies, local and national Government departments or agencies, police or medical forces, security organisations, other Crenns companies;
- In the creation, renewal or termination of the tenancy, your information may be disclosed to the relevant local authority, tenancy deposit scheme administrator, service/utility provider, managing agent, freeholder, factor, facilities manager or any other relevant person or organisation in connection with this;
- If we enter into a joint venture with or merge with a business entity, your information may be disclosed to our new business partners or owners;
- To any other person listed on your lease if you are entering a joint tenancy with them. This will be restricted to the specific details on the lease itself and any financial information or other information directly necessary to uphold your obligations in accordance with the terms of our contract with you.
Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.
Transfers outside the UK and Europe
Your information will only be stored within the UK and EEA; this includes on data backup servers.
We may transfer your information outside the UK and/or EEA if a request for a reference is made by someone outside the UK/EEA; this will only be done after we have received your written approval.
We will respond either via email to their request or via an online form if they provide one.
When you give us information we take steps to make sure that your personal information is kept secure and safe.
- Electronic data is stored on a password protected, encrypted system. Only people with authorisation to view the data are allowed to access the system. Data backups are made onto encrypted hard drives and also onto an encrypted server.
- Hard copies of data are kept in locked cabinets within a locked office, which are only accessible by authorised personnel.
How Long We Will Keep Your Information
We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we are legally required to hold some types of information), or as set out in any relevant contract I have with you.
Our full retention schedule is available by contacting us. In summary, paper copies with personal information are destroyed once the lease is complete. Full lease records are kept for a number of months in case there are any queries that require us to look back at our records. A cut down version of these records, with only essential information, is stored for longer to assist with queries that may come in over a longer period of time, such as a request for a reference. Email records are stored up to an indefinite amount of time.
You have the right at any time to:
- ask for a copy of the information about you held by us in our records;
- require us to correct any inaccuracies in your information;
- make a request to us to delete what personal data of yours we hold (if the information is held only through consent by you; the majority of our information is held under the Contractual/Legitimate Interest/Legal Requirement bases);
- object to receiving any marketing communications (which are only sent on occasion) from us.
If you would like to exercise any of your rights above please contact us.
Should you wish to complain about the use of your information, we would ask that you contact us to resolve this matter in the first instance. You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information. The Information Commissioner’s contact details are noted below:
Information Commissioner's Office
Wycliffe House, Water Lane
Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113
The accuracy of your information is important to us - please help us keep our records updated by informing us of any changes to your phone number, email address and other contact details.