This privacy notice explains what personal data (information) HME Home Management Excellence holds about you, how we collect it, and how we use and may share information about you when we provide services for you or your development and after those services end. 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. This privacy notice will be subject to regular review and will be updated to reflect changes in the collection or use of personal information.
Who we are
HME Home Management Excellence Limited 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 HME Home Management Excellence Limited.
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.
The personal information we collect and use: Information collected by us
In the course of business in providing services to you such as housekeeping, tenancy cleaning, communal area cleaning, void management solutions and customer care and defect management of developments, we collect personal information or provided to us this may include:
- Your up-to-date contact details: your name, property address, alternative contact address (if applicable), telephone numbers and email address.
- Your bank account information.
The provision of these details is required to enable us to perform our contracts for services, such as housekeeping, void management, customer care and defect management under the terms of our contract (e.g. to arrange access, to arrange third parties to carry out essential services, to collect payment, providing you with information about a property, capturing your image on CCTV systems to assist with personal security, prevention and detection of crime, responding to queries and complaints, to process payments and to prevent fraudulent transactions.
We will inform you at the point of collecting information from you, whether you are required to provide the information to us. Data collection points will include start of a new contract or service, transfer of management of a development, assignment, sub-letting or of a property.
The personal information we collect and use:
Information collected from other sources
We also obtain personal information from other sources including from other leaseholders or occupiers, credit reference agencies, solicitors, accountants and auditors, the police or fire services or local authority. We also gather sensitive (or special category) personal information from other leaseholders or occupiers or for example via CCTV images.
How we use your personal information
We will typically collect and use this information for the following purposes:
- For the performance of a contract we have with you or with the Management Company or landlord or developer, and
- 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.
Who we share your personal information with?
In delivering our services and providing support to you and our clients we routinely share the following categories of personal data, such as your name, your address, your mobile telephone number and your e-mail address. This personal information may be shared with the following categories of recipients:
- Contractors to obtain access for repairs and maintenance, if applicable;
- Our client, insurance brokers and companies, financial institutions such as banks, accountants and auditors
- Utility providers, local authorities, the police and fire services.
This data sharing enables us to perform our contracts. We will also 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.
Where your personal information may be held
Information may be held at our offices and those of our group companies, with 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 hold your personal data (e.g. name and contact details) for up to 13 years from the end of your contract with us or the end of the management of the development. We are required to retain some information by UK tax law for 6 years and as some types of claims that may arise from the lease can be arise within a period of up to 12 years. We will only keep it for as long as is necessary for the purpose for which it was collected. Certain data such as CCTV and telephone recordings will be held for shorter periods of time.
Rwasons we can collect and use your personal information
We rely on our contracts as the lawful basis on which we collect and use your personal data. We need to process your personal data to comply with our contractual obligations.
We also rely on legitimate interests as the lawful basis on which we collect and use your personal data.
We have a legitimate business interest where you live in a development, but are not a leaseholder in order to provide the best service and levels of management of the development.
We also rely on legal compliance as the lawful basis on which we collect and use your personal data. If the law requires us to, we may need to do this e.g. we can pass on details of people involved in fraud or other criminal activity to law enforcement.
Transfer of your information out of the EEA
In providing our services, we may process information in our support centre in South Africa which is contracted, operated and managed to the same GDPR secure standards as if it were within the EEA. As the data controller, we determine the purposes and means of processing the personal data. Any provider of services will be expected to exhibit the same standards as if it were within the EEA.
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.
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 for the attention of our Data Protection Officer at 9a Macklin Street, London WC2B 5NET Telephone: 020 7438 1030 or
email dataprotection@l-r-m.co.uk
- Let us have enough information to identify you [e.g. full name, address and property address]
- 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)
- Let us know the information to which your request relates, including any account or reference numbers, if you have them.
Changes to this privacy notice
This privacy notice was published on 6th October 2020 and last updated on 6th October 2020. We may change this privacy notice from time to time, and when we do, we will inform you.
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].
Do you need extra help?
If you would like this notice in another format (for example: audio, large print, braille) please contact us.