The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.
The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.
Lower Richmond Properties Ltd is a Data Controller and Data Processor; our registered office is at KLSA LLP, St John’s Square, London EC1M 4DN; and we are currently registered with the Information Commissioner.
Who we are
Lower Richmond Properties Ltd was established over 15 years ago as a property development and management company.
We currently own and manage a large portfolio of stand-alone and mixed-use properties including serviced and conventional offices, retail units, and leisure and industrial properties located primarily in London, the Home Counties and in the south-east of England, and the West Country.
The data protection principles
This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:
- Processed lawfully, fairly, and in a transparent manner in relation to the data subject.
- Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.
- Adequate, relevant, and limited to what is necessary for relation to the purposes for which it is processed.
- Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.
- Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods as required by any statutory regulations.
- Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.
What types of data do we collect and hold?
The personal data that we hold about you will be specific to your relationship with Lower Richmond Properties Ltd and the services that we provide to you. The data may include some or all of the following:
- Personal identifiers: such as your name, gender, and title;
- Contact information: such as your work address, work email, work telephone number;
- Business information including current and previous employers where we have a long-term relationship with you;
- Information to assist us to verify your identity;
- The information you provide to us as part of our services, or when you contact us directly;
- Personal contact information for our private clients;
- Information about your visits to our website, and engagement with our online information services;
- Communication data between you and us, direct or via our brokers, e-mail communication, online chats, comments and reviews collected through surveys or posted on social media platforms. This also includes your preferences in receiving marketing from us and your communication preferences.
- Financial Data including bank account and payment card details.
- Information collected as part of our recruitment and employment practices (which is managed under a different policy which we will make available to all candidates);
- We hold and process information about our employees and candidates for positions with us under a separate privacy notice.
- CCTV Data including recording or viewing visual images for the effective management, safety and security within our buildings.
How do we collect personal data?
We collect your personal data:
- Directly from you
- Through automated systems
- Via Third parties
What do we use personal data for?
Our primary use of personal information is to enable us to deliver services to our clients and their customers. Where we have a contract with you, or your employer it is necessary for us to process certain personal data to deliver that contract and provide our services.
We also use personal information for our legitimate business interests in monitoring, managing, developing and promoting our products and services.
Communicating with you:
We also use your personal information to offer you property updates and information on our products and services that we think will be of interest to you. We will also provide information on networking opportunities. From time to time, we may also use your information to contact you for market research purposes.
We rely on one or more of the following lawful conditions to process your personal identifiable data:
- To perform our obligations under an agreement that we have with you, or that we may have with a third party
- To satisfy a legal or regulatory obligation that we are required to meet
- To promote our legitimate business interests
- Where there are no other lawful conditions, we may process information with your consent
Sharing personal data with third parties
Lower Richmond Properties Ltd does not sell, trade, or rent any personal information to other organisations.
Most of our business activities are conducted inhouse. Where we work with external suppliers, to provide our IT support services, for telephone campaigns, mailing activities, hosting events or administrative services, we ensure that we have a contract in place to require our suppliers to treat your personal data appropriately. We check that our suppliers have appropriate policies and procedures, keep your information confidential, only use it in accordance with our instructions.
We may disclose personal information to third parties in the following circumstances:
- When explicitly requested by you;
- When required to deliver publications or reference materials as requested by you;
- Where necessary to facilitate events hosted by us or a third party;
- For our regulatory compliance purposes.
Lower Richmond Properties Ltd may disclose your personal information to any member of our associated or subsidiary companies for our legitimate business purposes.
Lower Richmond Properties Ltd, any member of our associated or subsidiary companies may disclose your personal information in the event that it sells or buys any business or assets to the prospective seller or buyer of such business or assets.
We may also disclose your personal information to law enforcement, regulatory and other government agencies and to professional bodies and other third parties, as required by and/or in accordance with applicable law or regulation, or where our assets are acquired by a third party.
Although we do not routinely transfer personal information outside the European Economic Area (EEA), we may be required to transfer your personal data to provide you with a specific service at your request, or to our partners or suppliers if they are based outside of the EEA. Where this is the case, we will make sure that they agree to: keep it secure; apply the same levels of protection as we are required to apply to information held in the UK, and to use it only for the purpose of providing the service to us. By submitting your personal data, you acknowledge this transfer, storing or processing.
Storing and retaining personal information
We will hold your personal information on our systems for as long as it is necessary for the purpose for which it was collected, and we will review this retention periodically.
When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.
Lower Richmond Properties Ltd treats all personal information and confidential; we regularly train our staff to treat all personal information the same way. Where we record your information electronically we have implemented accepted standards of organisational and technical security measures to protect and secure it, for example, using secure passwords; ensuring our staff are trained, and only recording the minimum data sets necessary to complete a specific task.
Lower Richmond Properties Ltd takes the protection of your information very seriously. All the information provided to Lower Richmond Properties Ltd is stored securely once we receive it.
Lower Richmond Properties Ltd stores your personal data on secure servers.
Your rights under the protection law
As an individual you have a number of rights under the relevant data protection laws, including:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure (also known as the ‘right to be forgotten’)
- The right to restrict processing
- The right to data portability
- The right to object
- Rights with respect to automated decision-making and profiling
For further information on each of these rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individual’s rights under the General Data Protection Regulation.
Implementation of this policy
This policy shall be deemed effective as of 25th May 2018. No part of this policy shall have retrospective effect and shall only apply to matters occurring on or after this date.