This privacy notice explains what personal data (information) we hold about you, how we collect it, and how we use and may share information about you both during our management of the property that you own and/or live in and in the future should our management cease. We are required to notify you of this information under the General Data Protection Regulation.
Please ensure you read this notice and any other similar notice we may provide to you from time to time when we collect or process personal information about you. This privacy notice contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
Who we are
Revolution Property Management Ltd collects, uses and is responsible for certain personal information about you, as our customer. When we do so, we are regulated under the General Data Protection Regulation and the Data Protection Act 2018, and we are responsible as ‘controller’ of that personal information for the purposes of those laws. In this privacy notice, references to “we” or “us” means Revolution Property Management Ltd.
The personal information we collect and use: information collected by us
In the course of property management, when providing support to customers, performing accounting and service administration, arranging maintenance works, controlling safety and security, communicating with you on all matters concerning the property (including through our online portal) and dealing with any insurance matters we collect the following personal information that you provide to us:
• Your identity – first name, surname, title. This can be updated by you using our online portal or by emailing us at email@example.com or write to us at Revolution Property Management Ltd, 384a Deansgate, Manchester, M3 4LA.
• The address of the property that we manage which you own and/or live in.
• Your terms of occupancy for the property – whether you are a leaseholder or a rental tenant.
• Your contact information including correspondence address, e-mail address, and telephone numbers. This can be updated by you using our online portal or by emailing us at firstname.lastname@example.org or write to us at Revolution Property Management Ltd, 384a Deansgate, Manchester, M3 4LA.
• Communications – if you write to us by email or otherwise, or you talk to us on the phone.
• Transactions – includes details about payments you have made to us and charges applied to your account.
• If you access any of our online services then we collect your user details, along with technical details on the devices and technology you use to access those services, internet protocol (IP) address, your login and usage data.
• Visual data – includes visual images, personal appearance and behaviours from any CCTV monitoring and recording equipment installed in the communal parts of your building.
• If you are a director of a management company then we collect your date of birth, place of birth, nationality and occupation.
The personal information we collect and use: information collected from other sources
We also obtain personal information from other sources as follows:
• Your identity, contact information, and information about the ownership of your property including details of any mortgage company from publicly available sources such as HM Land Registry and Companies House.
• Your identity, contact information, and information about the ownership of your property from a conveyancing solicitor acting under your instruction.
• Your identity, contact information, information about the ownership of your property and transaction data from another property manager whose responsibilities are transferred to Revolution Property Management Ltd.
We will typically collect and use this information for the following purposes:
• For the performance of a contract you have entered into with that contract being the lease for the property and pursuant to which we are appointed as the managing agent.
• For the purposes of our legitimate interests or those of a third party, but only if these are not overridden by your interests, rights or freedoms.
Whether information has to be provided by you, and why?
The personal information listed above must be provided by you to us, to enable us to perform our contract as managing agent of the property that you own and/or live in. When we collect information from you, we will inform you whether you are required to provide this information to us.
Who we share your personal information with
We have relationships with a number of third parties that we routinely share the following categories of personal data:
• Your identity and contact information – shared with approved suppliers to enable direct contact with you in respect to any matter concerning you or your property.
• Your identity, contact information, information about the ownership of your property, communications and transaction data – shared with a professional firm acting on behalf of our client in respect to legal or accounting matters.
• Your identity, contact information, information about the ownership of your property and transaction data shared with any party connected to the lease document of your property including the Lessor, Freeholder, and where applicable, Management Company and Head Lessor.
• Your identity, contact information, information about the ownership of your property, communications and transaction data – shared with providers of IT services to Revolution Property Management Ltd.
• Your identity, contact information, information about the ownership of your property and transaction data shared with another property manager to whom the responsibilities of Revolution Property Management Ltd are transferred.
• Your identity and contact details relating to any insurance claim affecting the property shared with an insurer, insurance broker, insurance loss assessor, or any other party affected by an insurance event.
• We will share personal information with law enforcement agencies if required by applicable law.
• We will not share your personal information with any other third parties without your consent.
This data sharing enables us to perform our contract as managing agent.
Where your personal information may be held
Information may be held at our offices, and third-party agencies, service providers, representatives and agents as described above.
We have security measures in place to seek to ensure that there is appropriate security for information we hold including those measures detailed in our GDPR data protection policy.
How long your personal information will be kept
We will only retain your personal data for a maximum of 6 years after you cease to be a customer to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Please note that by law we have to keep basic information about our customers for six years after they cease being customers for tax purposes.
Legal reasons we collect and use your personal information
For leaseholder customers the lawful basis on which we collect and use your personal data is that it is necessary for the performance of a contract with you, with that contract being the lease for your property.
For rental tenant customers the lawful basis on which we collect and use your personal data is that it is necessary for our legitimate interests in managing the property where you live. These include maintaining the communal parts of the property, controlling security and access, notifying you about important issues that affect the property, and ensuring compliance with the terms of the lease.
Transfer of your information out of the EEA
It may be necessary to transfer your personal information outside the European Economic Area (EEA) or to an international organisation to facilitate our customer support administration. Below is a list of the countries which are located outside the European Economic Area (EEA) that we may share data with:
• The United States of America
Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal information will be subject to the Zendesk Data Processing Agreement that offers three types of compliance allowing transfer of data outside the EEA; Privacy Shield Framework, Standard Contractual Clauses and Binding Contract Rules as permitted under GDPR ARTICLE 46 of the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. To learn more about the Privacy Shield Framework please visit www.privacyshield.gov.
We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Under the General Data Protection Regulation, you have a number of important rights that you can exercise free of charge. In summary, these rights are:
• Transparency over how we use your personal data and fair processing of your information;
• Access to your personal information and other supplementary information;
• Require us to correct any mistakes or complete missing information we hold on you;
• Require us to erase your personal information in certain circumstances;
• Receive a copy of the personal information you have provided to us or have this information be sent to a third party, this will be provided to you or the third party in a structured, commonly used and machine-readable format;
• Object at any time to processing of your personal information for direct marketing;
• Object in certain other situations to the continued processing of your personal information;
• Restrict our processing of your personal information in certain circumstances;
• Request not to be subject to automated decision making which produce legal effects that concern you or affect you in a significantly similar way;
If you want more information about your rights under the GDPR please see the Guidance from the Information Commissioners Office on Individual’s rights under the GDPR.
If you want to exercise any of these rights:
• Please write to us at Revolution Property Management Ltd, 384a Deansgate, Manchester, M3 4LA or email us at email@example.com.
• Please provide enough information to identify you (full name, correspondence address).
• We may need to contact you to request further information to verify your identity.
• Let us have proof of your identity and address.
• State the right or rights that you wish to exercise.
We will respond to you within one month from when we receive your request.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We adhere to IT industry best practice to ensure that firewalls, software updates, security software and all other IT procedures are in place and up to date.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information. Please contact us on 0161 850 0022, email us at firstname.lastname@example.org or write to us at Revolution Property Management Ltd, 384a Deansgate, Manchester, M3 4LA.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
We do not intend to process your personal information for any reason other than stated within this privacy notice. If this should change, we will inform you in writing.
Changes to this privacy notice
This privacy notice was published on 24 May 2018 and last updated on 11 July 2018. We may change this privacy notice from time to time, and when we do we will inform you in writing.
Get in touch
If you have any questions about this privacy notice or the information we hold about you, please contact us on 0161 850 0022, email us at email@example.com or write to us at Revolution Property Management Ltd, 384a Deansgate, Manchester, M3 4LA.
If it would be helpful to have this notice provided in another format (for example, in another language, audio, braille) please contact us (see ‘Get in touch’ above).