ASPIRE BLOCK & ESTATE MANAGEMENT LIMITED PRIVACY POLICY

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 during our management of your block or estate and after it ends. We are required to notify you of this information under the General Data Protection Regulation.

 

Please ensure you read this notice (sometimes referred to as a “privacy 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.

 

1. WHO WE ARE

Aspire Block & Estate Management Limited collects, uses and is responsible for

certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) 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 Aspire Block & Estate Management Limited.

 

2. DATA PROTECTION PRINCIPLES

We will comply with the data protection principles when gathering and using personal information, as set out in our GDPR data protection policy.

 

3. THE PERSONAL INFORMATION WE COLLECT AND USE: INFORMATION COLLECTED BY US

In the course of our duties as managing agent, we collect the following personal information when you provide it to us:

 

  • Name, correspondence address, email address, telephone number, mobile number and  backup numbers

  • Access information, non-resident address, email address, (only if required to carry out our contract).

  • Financial details such as bank details and transaction records.

  • Images on documents and CCTV images (where installed)

  • Mortgage Details

 

The provision of the above information is required from you to enable us to perform our contract as managing agent appointed for and on behalf of your landlord or resident management company. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.

 

4. THE PERSONAL INFORMATION WE COLLECT AND USE: INFORMATION COLLECTED FROM OTHER SOURCES

 

We also obtain personal information from other sources as follows:

 

  • Access information, names, address, email addresses, telephone numbers, mobile numbers, backup numbers and mortgage details from the Landlord, Residents Management Company, solicitors, contractors, your neighbours and managing agents who previously managed your development.

  • CCTV images are obtained from the following source: CCTV cameras on the developments where there is surveillance present.

 

5. HOW WE USE YOUR PERSONAL INFORMATION

We will typically collect and use this information for the following purposes:

 

  • For the performance of a contract you have with our client and pursuant to which we are appointed as their 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.

 

We seek to ensure that our information collection and processing is always proportionate. We will notify you of any material changes to information we collect or to the purposes for which we collect and process it.

 

6. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We routinely share the following categories of personal data:

 

  • Names

  • Addresses

  • Telephone numbers

  • Mobile numbers

  • Backup numbers

  • Access information

  • Non-resident address

  • Relatives’ details

  • Mortgage details

  • Email addresses

 

This personal information may be shared with the following categories of recipients:

 

  • External accountants

  • Insurance providers

  • Solicitors

  • Debt recovery firms

  • Surveying firms

  • Maintenance Contractors

  • Parking enforcement companies

  • Freeholders/landlords

  • Management Company Directors

  • Companies House

  • Technical and emergency support providers

  • (internal) Software providers

  • Regulatory bodies

  • Managing Agents for management handovers

  • Bank

  • Emergency services

  • Local authorities

  • Out-of-hours emergency service providers

 

This data sharing enables us to perform our contract as managing agent.

 

Some of those third party recipients may be based outside the European Economic Area - for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’.

 

We will share personal information with law enforcement or other authorities if required by applicable law.

 

We will not share your personal information with any other third party.

 

7. WHERE YOUR PERSONAL INFORMATION MAY BE HELD

Information may be held at our offices and those of our group companies, 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.

 

8. HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT

  • We will hold personal information for the duration of management and up to 10 years from the end of management.

  • CCTV images will be retained for a period of time as dictated by the system’s recording capability. This period of time will vary from system to system. This may mean that images may not always be available when requested via a Subject Access Request.

  • For prospective clients we will hold names, addresses, email addresses, telephone numbers, mobile numbers, backup numbers, access information, non-resident address, email address, relatives’ details for 6 years or upon written request of a previously-interested party.
     

 

9. REASONS WE CAN COLLECT AND USE YOUR PERSONAL INFORMATION

We rely on contract as the lawful basis on which we collect and use your personal data.

 

10. YOUR RIGHTS

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

 

  • Fair processing of information and transparency over how we use your use personal information

  • Access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address

  • Require us to correct any mistakes in your information which we hold

  • Require the erasure of personal information concerning you in certain situations

  • Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations

  • Object at any time to processing of personal information concerning you for direct marketing

  • Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you

  • Object in certain other situations to our continued processing of your personal information

  • Otherwise restrict our processing of your personal information in certain circumstances

  • Claim compensation for damages caused by our breach of any data protection laws

 

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

 

If you would like to exercise any of those rights, please:

 

  • Email, call or write to us

  • Let us have enough information to identify you

  • Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and

  • Let us know the information to which your request relates, including any account or reference numbers, if you have them
     

 

11. KEEPING YOUR PERSONAL INFORMATION SECURE

We have appropriate security measures in place to prevent personal information from being accidentally lost, or 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.

 

12. HOW TO COMPLAIN

We hope that we can resolve any query or concern you raise about our use of your information.

 

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.

 

13. CHANGES TO THIS PRIVACY NOTICE

This privacy notice was published on May 2018 and last updated on August 2019.

 

We may change this privacy notice from time to time, and when we do we will inform you.

 

14. DO YOU NEED EXTRA HELP?

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see ‘How to contact us’ above).

© 2019 Aspire Block & Estate Management Limited

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Aspire Block and Estate Management Limited is an appointed representative of Arthur J. Gallagher Insurance Brokers Limited which is authorised and regulated by the Financial Conduct Authority. Registered Office: Spectrum Building 7th Floor 55 Blysthwood Street, Glasgow G2 7AT. Registered in Scotland. Company Number: SC108909