General Data Protection Regulation
General Privacy Notice
Your personal data – what is it?
“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be by the information alone or in conjunction with any other information. The processing of personal data is governed by [the Data Protection Bill/Act 2017 the General Data Protection Regulation 2016/679 (the “GDPR” and other legislation relating to personal data and rights such as the Human Rights Act 1998].
Who are we?
The Granville Cliff Estate Company Ltd (company registration number 3272458) was set up in 1998 to take ownership and manage the roads, paths, banks and verges on behalf of and to the benefit of the residents. The Company was formed by the residents for the residents, and their visitors, to retain the ‘private status’ of the Estate.
What data do the data controllers listed above process?
They will process some or all of the following types of data, where necessary to perform their tasks:
- Names, titles, and aliases;
- Contact details such as telephone numbers, addresses, and email addresses;
- Records of payments to the Granville Cliff Estate Company Ltd relating to service charges, new build fees and any other payments.
- Records of share ownership of the Granville Cliff Estate Company Ltd
How do we process your personal data?
The data controllers will comply with their legal obligations to: keep personal data up to date; to store and destroy it securely; to not collect or retain excessive amounts of data; to keep personal data secure, and to protect personal data from loss, misuse, unauthorised access and disclosure and to ensure that appropriate technical measures are in place to protect personal data.
We use your personal data for some or all of the following purposes:
- To enable us to meet all legal and statutory obligations;
- To maintain our own accounts and records;
- To maintain communication relating to estate matters including collection of service charges, notifications of building work, invitations to meetings;
- To send you communications in the interests of the residents of the estate including neighbourhood watch notifications, community announcements, company announcements;
What is the legal basis for processing your personal data?
Most of our data is processed because it is necessary to retain communication with our residents for community and company business.
We process collection of service charges via e-mail / letters to residents contact addresses and store records of payments for accounting purposes.
Sharing your personal data
Your personal data will be treated as strictly confidential and will not be shared with third parties with the exception of any legal requirements.
How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is current best practice to keep financial records for a minimum period of 7 years to support HMRC audits. In general, we will endeavour to keep data only for as long as we need it. This means that we may delete it when it is no longer needed.
Your rights and your personal data
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
You have the following rights with respect to your personal data
- The right to access information we hold on you
At any point you can contact us to request the information we hold on you as well as why we have that information, who has access to the information and where we obtained the information from. Once we have received your request we will respond within one month.
There are no fees or charges for the first request but additional requests for the same data may be subject to an administrative fee.
- The right to correct and update the information we hold on you
If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
- The right to have your information erased
If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold.
When we receive your request we will confirm whether the data has been deleted or the reason why it cannot be deleted (for example because we need it for our legitimate interests or regulatory purpose(s)).
- The right to object to processing of your data
You have the right to request that we stop processing your data. Upon receiving the request we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or to bring or defend legal claims.
- The right to data portability
You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
- The right to withdraw your consent to the processing at any time for any processing of data for which
consent was sought.
You can withdraw your consent easily by telephone, email, or by post (see Contact Details below).
- The right to object to the processing of personal data where applicable.
- The right to lodge a complaint with the Information Commissioner’s Office.
Transfer of Data Abroad
Any electronic personal data transferred to countries or territories outside the EU will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union. Our website is also accessible from overseas so on occasion some personal data (for example in a newsletter) may be accessed from overseas.
Further processing
If we wish to use your personal data for a new purpose, not covered by this Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Contact Details
Please contact us if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant rights, queries or complaints at:
Daniel Rafferty – GDPR Officer / Director – The Granville Cliff Estate Company Ltd
daniel.rafferty@granvillecliffestate.co.uk