Privacy policy

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Background:

GMS Estates Limited understands that your privacy is important and that you care about how your personal data is used. We respect and value the privacy of all of our tenants, shareholders, contractors and others with whom we have a relationship. We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

  1. Information about us

    GMS Estates Limited

    Private Limited Company registered in England under company number 210378

    Registered address and Head Office 32 Great James Street, London WC1N 3HB

    Residential Office: 127a Queensway, London, W2 4SJ

    Main Switchboard telephone number: 020 7831 8041

    Data Protection Officer: Bernadette Griffin, email address: bg@gms-estates.co.uk

  2. What does this notice cover?

    This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

  3. What is personal data?

    Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. The personal data that we use is set out in Part 5 below.

    The personal data that we use is set out in Part 5 below.

  4. What are your rights?

    Under the GDPR, you have the following rights, which we will always work to uphold:

    1. The right to be informed about our collection and use of your personal data.
    2. The right to access the personal data we hold about you. Part 10 will tell you how to do this.
    3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11.
    4. The right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11.
    5. The right to restrict (i.e. prevent) the processing of your personal data.
    6. The right to object to us using your personal data for a particular purpose or purposes.
    7. The right to data portability. This means that, if you have provided personal data to us directly, and we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases. We do not process data using automated means.
    8. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

    Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

    If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

  5. What personal data do we collect?

    We may collect some or all of the following personal data (this may vary according to your relationship with us):

    • Name
    • Date of birth
    • Gender
    • Address
    • Email address
    • Telephone and mobile numbers
    • Business name
    • Job title
    • Profession
    • Banking and payment information
    • Number of shares held and any transactions relating thereto (shareholders only)

    On occasion personal data may be obtained from third parties, such as managing agents, referees, reference checking agencies or others providing services to us.

  6. How do we use your personal data?

    Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for the performance of a contract with you, because you have consented to our use of your personal data, for legal compliance 3 purposes or because it is in our legitimate business interests to use it. Depending on your relationship with us, your personal data may be used for one or more of the following purposes:

    • Property management
    • Property transactions
    • Contract management and/or performance
    • Receiving or making payments
    • Legal and regulatory compliance
    • Legal proceedings
    • Communicating with you
    • Maintenance of Company Registers and shareholder records

  7. How long will we keep your personal data?

    We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. This will usually be for the duration of our relationship and then for a period of six years thereafter. In some cases, we may retain your information for longer but only if there is a relevant or legal reason for doing so.

  8. How and where do we store or transfer your personal data?

    We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.

  9. Do we share your personal data?

    We may share your personal data with other companies in our group for tenancy or property management or transactional purposes. The group comprises GMS Estates Limited, as the parent company, and our subsidiaries.

    We may sometimes contract with third parties to supply services on our behalf. These may include payment processing, tenancy or property management, contract works or professional services and advice. In some cases, those third parties may require access to some or all of your personal data that we hold.

    If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.

    In some circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

  10. How can you access your personal data?

    If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

    All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11, together with proof of your identity.

    We will respond to your subject access request within one month of receiving it.

    We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

    There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

  11. How to contact us

    To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following contact details:

    Bernadette Griffin (Company Secretary)
    Email address: bg@gms-estates.co.uk
    Telephone number: 020 7831 8041.
    Postal Address: 32 Great James Street, London WC1N 3HB.

  12. Changes to this Privacy Notice

    We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

    Any changes will be made available on our website: www.gms-estates.co.uk.

May 2018

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