Data controller (“the Company”): Broad Oak Properties Ltd. and group companies.
As a customer or potential customer The Company collects and processes personal information, or personal data, relating to you. This personal information may be held by the Company on paper or in electronic format.
The Company is committed to being transparent about how it handles your personal information, in protecting the privacy and security of your personal information and in meeting its data protection obligations under the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018. The purpose of this privacy notice is to make you aware of how and why we will collect and use your personal information.
The Company has appointed a data compliance manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or about how we handle your personal information, please contact Ben Crompton on 01782 550371 or at firstname.lastname@example.org
Data protection principles
Under the GDPR, there are six data protection principles that the Company must comply with. These provide that the personal information we hold about you must be:
Processed lawfully, fairly and in a transparent manner.
Collected only for legitimate purposes that have been clearly explained to you and not further processed in a way that is incompatible with those purposes.
Adequate, relevant and limited to what is necessary in relation to those purposes.
Accurate and, where necessary, kept up to date.
Kept in a form which permits your identification for no longer than is necessary for those purposes.
Processed in a way that ensures appropriate security of the data.
The Company is responsible for, and must be able to demonstrate compliance with, these principles. This is called accountability.
What types of personal information do we collect about you?
Personal information is any information about an individual from which that person can be directly or indirectly identified. It doesn’t include anonymised data, i.e. where all identifying particulars have been removed.
The Company collects, uses and processes a range of personal information about you. This includes (as applicable):
your contact details, including your name, address, telephone number and personal e-mail address
your emergency contact details/next of kin
your date of birth
your marital status and dependants
your National Insurance number
The Company may also collect, use and process the following special categories of your personal information (as applicable):
information about your health, including any medical condition, whether you have a disability in respect of which the Company is required to provide adaptation services.
How do we collect your personal information?
The Company may collect personal information about you in a variety of ways. It is collected during the application process, either directly from you or from a third party such as a Local authority.
We may also collect additional personal information throughout the period of our provision of services and works.
Your personal information will be stored in secure paper and electronic formats.
Why and how do we use your personal information?
We will only use your personal information when the law allows us to. These are known as the legal bases for processing. We will use your personal information in one or more of the following circumstances:
Provide you with the services you have asked for.
Offer you services and products from time to time.
Help run, and contact you about improving the way we run services we have provided before, now or in the future.
Create statistics, test computer systems, analyse customer information.
Help prevent and detect debt, fraud and loss.
Help train our staff.
where we need to comply with a legal obligation
where it is necessary for our legitimate interests (or those of a third party), and your interests or your fundamental rights and freedoms do not override our interests.
We may also occasionally use your personal information where we need to protect your vital interests (or someone else’s vital interests).
We need all the types of personal information listed under “What types of personal information do we collect about you?” primarily to enable us to perform our service to you and to enable us to comply with our legal obligations.
Please note that we may process your personal information without your consent, in compliance with these rules, where this is required or permitted by law.
What if you fail to provide personal information?
If you fail to provide certain personal information when requested or required, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations. You may also be unable to exercise your statutory or contractual rights.
Change of purpose
We will only use your personal information for the purposes for which we collected it. If we need to use your personal information for a purpose other than that, for which it was collected, we will provide you, prior to that further processing, with information about the new purpose, we will explain the legal basis which allows us to process your personal information for the new purpose and we will provide you with any relevant further information. We may also issue a new privacy notice to you.
Who has access to your personal information?
Your personal information may be shared internally within the Company such as managers in the department and IT staff if access to your personal information is necessary for the performance of their roles.
The Company may also share your personal information with third-party service providers (and their designated agents), including:
external organisations for the purposes of completing our services
benefits providers and benefits administration, including insurers
The Energy Savings Trust
occupational health providers
professional advisers, such as lawyers
We may also need to share your personal information with a regulator or to otherwise comply with the law.
How does the Company protect your personal information?
The Company has put in place measures to protect the security of your personal information. It has internal policies, procedures and controls in place to try and prevent your personal information from being accidentally lost or destroyed, altered, disclosed or used or accessed in an unauthorised way. In addition, we limit access to your personal information to those employees, workers, agents, contractors and other third parties who have a business need to know in order to perform their job duties and responsibilities. You can obtain further information about these measures from our data compliance manager.
Where your personal information is shared with third-party service providers, we require all third parties to take appropriate technical and organisational security measures to protect your personal information and to treat it subject to a duty of confidentiality and in accordance with data protection law. We only allow them to process your personal information for specified purposes and in accordance with our written instructions and we do not allow them to use your personal information for their own purposes.
The Company also has in place procedures to deal with a suspected data security breach and we will notify the Information Commissioner’s Office (or any other applicable supervisory authority or regulator) and you of a suspected breach where we are legally required to do so.
For how long does the Company keep your personal information?
The Company will only retain your personal information for as long as is necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, tax, health and safety, reporting or accounting requirements.
The Company will generally hold your personal information for the duration of our services to you plus 6 years. However, this is subject to: (a) any minimum statutory or other legal, tax, health and safety, reporting or accounting requirements for particular data or records, and (b) the retention of some types of personal information for up to six years to protect against legal risk, e.g. if they could be relevant to a possible legal claim in a County Court or High Court.
Personal information which is no longer to be retained will be securely and effectively destroyed or permanently erased from our IT systems and we will also require third parties to destroy or erase such personal information where applicable.
In some circumstances we may anonymise your personal information so that it no longer permits your identification. In this case, we may retain such information for a longer period.
Your rights in connection with your personal information
It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes. The Company cannot be held responsible for any errors in your personal information in this regard unless you have notified the Company of the relevant change.
As a data subject, you have a number of statutory rights. Subject to certain conditions, and in certain circumstances, you have the right to:
request access to your personal information – this is usually known as making a data subject access request and it enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it
request rectification of your personal information – this enables you to have any inaccurate or incomplete personal information we hold about you corrected
request the erasure of your personal information – this enables you to ask us to delete or remove your personal information where there’s no compelling reason for its continued processing, e.g. it’s no longer necessary in relation to the purpose for which it was originally collected
restrict the processing of your personal information – this enables you to ask us to suspend the processing of your personal information, e.g. if you contest its accuracy and so want us to verify its accuracy
object to the processing of your personal information – this enables you to ask us to stop processing your personal information where we are relying on the legitimate interests of the business as our legal basis for processing and there is something relating to your particular situation which makes you decide to object to processing on this ground
data portability – this gives you the right to request the transfer of your personal information to another party so that you can reuse it across different services for your own purposes.
If you wish to exercise any of these rights, please contact our data compliance manager. We may need to request specific information from you in order to verify your identity and check your right to access the personal information or to exercise any of your other rights.
This is a security measure to ensure that your personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you have provided your consent to the processing of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. This will not, however, affect the lawfulness of processing based on your consent before its withdrawal. If you wish to withdraw your consent, please contact our data compliance manager. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose you originally agreed to, unless we have another legal basis for processing.
If you believe that the Company has not complied with your data protection rights, you have the right to make a complaint to the Information Commissioner’s Office (ICO) at any time. The ICO is the UK supervisory authority for data protection issues.
Transferring personal information outside the European Economic Area
The Company will not transfer your personal information to countries outside the European Economic Area.
Automated decision making
Automated decision making occurs when an electronic system uses your personal information to make a decision without human intervention.
We may also notify you about the processing of your personal information in other ways.