REASONS/PURPOSES FOR PROCESSING INFORMATION
We process personal information to enable us as to carry out all property services, promote and advertise our services, maintain our own accounts and records, support and manage our employees and for the various purposes as described in detail below.
PERSONAL DATA WE COLLECT FROM YOU
“Personal Data” is any information that relates to you and identifies you personally, either alone or in combination with other information available to us. This will generally be: name including ‘title’, mobile/home/work telephone numbers, email and home address. In the case of ‘tenants’, more information will be needed to cover legal requirements and referencing. If we hold an event and required your dietary requirements, your data would be deleted after the event.
INFORMATION WE COLLECT AUTOMATICALLY
HOW WE USE YOUR PERSONAL DATA
We use your personal data to assist you with all your property requirements and to enable us to keep in touch with you and provide the service you expect. Your personal data will also be used to enable us to perform all contractual and legal requirements on your behalf. To adhere to the new General Data Protection Regulations 2018 (GDPR) and for lawful reasons, Ocean Residential will need to hold and process your personal data for:
• Contractual necessity (legal necessity)
• Compliance with legal obligations
• Legitimate Interest
• Marketing if Consent given
Ocean Residential will securely store your personal data for as long as we are acting in your interests to provide the full letting agency service required. We may from time to time transfer your personal data to a country outside of the EEA. For example; when personal data is stored on a cloud server.
KEEPING YOU UP TO DATE WITH OUR KNOWLEDGE, EXPERTISE, SERVICES & EVENTS THIRD PARTIES
We will share your personal data as necessary and on the lawful grounds described above with various third parties who process your personal information on our behalf. Where necessary or required we share information with:
• business associates
• suppliers of goods or services
• financial organisations
• credit reference agencies
• debt collection and tracing agencies
• local and central government
• police forces
• security organisations
• current, past and prospective employers
• employment and recruitment agencies
• educators and examining bodies
• other companies in the same group
HOW WE PROTECT YOUR PERSONAL DATA
We are committed to protecting your personal data and implement; appropriate technical and organisational security; and training measures, to protect it against any unauthorised or unlawful processing and against any accidental loss or damage.
All Ocean Residential Data Processors and joint Data Controllers will be contracted to only use your data as instructed by Ocean Residential and to protect the confidentiality and security of your data at all times in accordance with GDPR requirements. All data retention is stored securely with limited access. When data is deleted it is done so irretrievably, all
hard copy papers are shredded and disposed of in confidential waste. Clients may request their paperwork is returned ad would need to arrange collection of this from the office.
YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
The new GDPR legislation creates rights for data subjects. These are the right to be informed, the right of access, the right to rectification, the right of erasure, the right to restrict processing, the right to data portability, the right to object and rights in relation to automated decision making and profiling. With regard to the ‘right to be forgotten’ (right of erasure), by law we have to keep your data for six years with regard to our legal obligations to HMRC for tax purposes. We also have a legal obligation to hold the following data on outgoing tenants for six years:
• Deposit information held with the Tenancy Deposit Scheme
• Right to Rent
• Invoices linked to the tenancy
• Dilapidation Report
• Exit Inspection
Any AML (Anti Money Laundering) information obtained through any department also needs to be kept for 6 years.
IF THERE IS A BREACH
In the event of a data security breach, we will advise you and any other parties as soon as we are made aware of the breach and notify the Information Commissioner’s Office (ICO) if appropriate.
OUR COMPLAINTS PROCEDURE
If you have a grievance, please write in the first instance to Ocean Residential at our office address or using our contact form. The grievance will be acknowledged within 3 working days, investigated thoroughly in accordance with established internal procedures and a reply sent to you with our final viewpoint on the matter within 15 working days.
If you remain dissatisfied with the result of the internal investigation, you can then contact the Property Ombudsman to request an independent review.
(The Property Ombudsman Ltd, Milford House, 43‐55 Milford Street, Salisbury, Wiltshire SP1 2BP – 01722 333 306) Please refer to their website for further details. www.tpos.co.uk
LISTED BELOW ARE OUR CORE THIRD PARTY COMPANIES/CONTRACTORS
Joint Data Controllers – For further information on their Privacy Policies, please visit their websites
FCC Paragon www.fccparagon.com
Tenancy Deposit Scheme www.tenancydepositscheme.com
The Property Ombudsman www.tpos.co.uk
Nest Pensions www.nestpensions.org.uk
H & M Maintenance Ltd
DPL Plumbing Ltd
MAP property services
H & G Brooks Roofing
Sparks Electrical Services Ltd
Gemini Windows Ltd
Veri Smart Inventories
From time to time we might also use other contractors if and when necessary.