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:
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:
How do we collect personal data?
We collect your personal data:
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 may contact you by email, post or via the telephone. If you do not wish to receive these communications, please let us know by contacting email@example.com.
We rely on one or more of the following lawful conditions to process your personal identifiable data:
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:
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
If you want to update the information you have previously given to us (e.g. if you have recently moved office or changed your email address), you can contact HR Department, Lower Richmond Properties Ltd, Diamond House, 179/181 Lower Richmond Road, Richmond, Surrey TW9 4LN or email firstname.lastname@example.org.
As an individual you have a number of rights under the relevant data protection laws, including:
These rights may be limited to certain defined circumstances and we may not be able to comply with your request. If you request to exercise these rights, we aim to respond to you within one month. We will not charge a fee for dealing with your request. If you wish to receive a copy of your personal data or exercise these rights, please write to our HR Department, Lower Richmond Properties Ltd, Diamond House, 179/181 Lower Richmond Road, Richmond, Surrey TW9 4LN or email email@example.com.
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.
Lower Richmond Properties Ltd always strives to deliver an excellent service, but we recognise that you may not be happy with the way that we have handled your personal information. If you are dissatisfied with how we are using your personal information or if you wish to complain about how we have handled a request, then please contact HR Department, Lower Richmond Properties Ltd, Diamond House, 179/181 Lower Richmond Road, Richmond, Surrey TW9 4LN or email firstname.lastname@example.org we will try to resolve any issues. However, you also have the right to complain to the Information Commissioner’s Office, which is the statutory regulator for data protection law. Details of how to complain to the ICO can be found at https://ico.org.uk/concerns/.
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.