HES Estate Management Privacy Policy
PRIVACY NOTICE
HES Estate Management Limited is committed to protecting the privacy and security of your personal information. This notice provides details on what information we collect about you and how we will use it during the management of your estate or development and after it ends.
We do not use your data for direct marketing purposes and we will not sell or share your data at any time for 3rd party marketing or selling purposes.
Because this is about greater protection and transparency for you please ensure you read this notice, the most up to date version of our privacy notices will be kept available on our website at all times http://www.heseml.co.uk/ . This 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
HES Estate Management Limited is a block and estate management company who collect, use and is responsible for certain personal information about you held in this capacity. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including the United Kingdom). 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 HES Estate Management Limited.
2. DATA PROTECTION PRINCIPLE
We will comply with the data protection principles when gathering and using personal information and as set out in our GDPR data protection policy.
3. INFORMATION COLLECTED BY US
Personal data is information which directly or indirectly identifies you. In the course of managing your Estate or Block for our clients we collect the following personal information:
• Your name; contact details including the property address (and other addresses if different to that under management); your home mobile and other numbers; your email contact details.
• We may also collect details of your mortgage provider, any tenants names and contact numbers if your property is let out, or other contact details you provide to us for us to liaise with you or others about your property.
• Occasionally we may collect sensitive information in relation to your health, disability or financial circumstances where this is appropriate for resolving an issue directly relating to the management of the estate or block.
• We may collect other information given by you during interactions or correspondence.
• We may collect information from other sources such as solicitors, the previous managing agents, the freeholder or superior lease owner, your RMC or RTM, their directors or any of their professional advisors, joint owners, your letting agent or others that act on your behalf such as accountants and other professional advisors.
The provision of your personal data is required from you or these other sources to enable us to perform our contract as managing agent appointed for and on behalf of the freeholder or superior landlord of your block or your estate owner. We will only collect information where there is a lawful basis to do so.
4. HOW WE USE YOUR PERSONAL INFORMATION
We will typically collect and use this information for the following purposes:
• For the performance of a contract eg your lease that you have with our clients; the freeholder, superior leasehold owner, RMC, RTM or other owner of the block or estate under management, pursuant to which we are appointed as their agent;
• or the performance of a contract with us directly;
• 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;
• Where we believe it is necessary to use your information to comply with a legal obligation to which we are subject.
The use of your data could include, but is not limited to, verifying your identity, providing you with services, managing your account and the contractual relationship with you as noted above. 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.
We do not use your data for direct marketing purposes and we will not sell or share your data at any time for 3rd party marketing or selling purposes.
5. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We routinely share the following categories of personal data:
•Your name, your address or addresses, your contact telephone numbers, your contact emailaddresses, your agent or tenants personal data;
We will only share sensitive financial or health information when it is necessary for the performance of our or your contract.
This personal information may be shared with the following categories of recipients:
•The freeholder or superior leasehold owners or estate owners or their directors or their appointed agents or professional advisors;
•Contractors that we employ for the maintenance and upkeep of your block or estate or who are appointed to undertake assessments;
•Professional advisors including brokers, insurers, loss adjustors, surveyors, project managers, accountants, payroll, solicitors, debt collectors;
•Professional bodies that regulate us;
•Our service providers for IT, data storage, or IT management; these include Bytemark, Microsoft Office 365, Propman and Eurolink;
•We may also use ‘Google Analytics’ and ‘Share this’ third party services for visitors to our website once we ensure our use and they are GDPR compliant;
•Our professional advisers;
•We will also share personal information with any law enforcement agency, tax authority, court,regulator or other government authority or other third party where we believe this is necessary tocomply with a legal or regulatory obligation, applicable law or otherwise to protect our rights.
Please be aware that the GDPR does not apply to information held in the public domain, such as Companies House data.
This data sharing enables us to perform our contract as managing agent. We require other parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and the GDPR. We will not share your personal information with any other third party.
6. WHERE YOUR PERSONAL INFORMATION MAY BE HELD
Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above. The data may be held physically or digitally using multiple servers.
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 and security policy.
Our investigation shows that all our third party IT agencies now store all data in the EU and are subject to the GDPR.
7. HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
• We may retain your personal data for a period of at least 6 years from the end of the relationship to fulfill our record-keeping obligations;
• Other data will not be retained for any longer than is necessary unless there is a legal or regulatory reason for extended retention.
8. REASONS WE CAN COLLECT AND USE YOUR PERSONAL INFORMATION
• The primary basis we collect and use your personal details is under contract, either directly or through the principal of agency.
• Additionally, we may collect your personal data where we have a legitimate interest in doing so. When this is the case we will only collect your personal data where our reasons are not overridden by your interests, rights, and freedoms.
9. TRANSFER OF YOUR INFORMATION OUT OF THE EEA
We may transfer your personal information to ‘Google Analytics‘, ‘Share This‘ which have servers located outside the European Economic Area (EEA) once we have established that they are GDPR compliant.
In these cases where the country may not have the same EEA laws, we will make sure your personal data is protected in accordance with the applicable data protection laws. We will not otherwise transfer your personal data outside of the United Kingdom or EEA.
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:
• the fair processing of information and transparency over how we use your personal information;
• access - you have a right to request a copy of the personal information that we hold about you, in a structured, commonly used and machine-readable format;
• recitification – you have the right to require us to correct any mistakes in your information that we hold;
• be forgotten – in certain circumstances you can ask for the data we hold to be erased;
• restrict processing – where certain conditions apply you can restrict the processing of your data;
• portablility - to transmit your data to a third party in certain situations;
• object - at any time to processing of personal information concerning you for certain types of processing such as direct marketing;
• object in certain other situations to our continued processing of your personal information;
• otherwise restrict our processing of your personal information in certain circumstances;
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.
11. CONTACT US
If you would like to exercise any of those rights, please:
•email, call or write to us at [email protected], 01372 677977 or GDPR request, HES Estate Management Limited, 2 Chartland House Old Station Approach Leatherhead Surrey KT22 7TE.
•provide us with enough information to identify you including your full name, your address, the property address,
•let us have proof of your identity and address (a copy of your driving licence or passport and a utility or credit card bill not more than 3 months old), and
•let us know the information to which your request relates, including any account or reference numbers, if you have them.
In the event we refuse your request we will provide you with a reason as to why, which you have the right to legally challenge.
12. KEEPING YOUR PERSONAL INFORMATION SECURE
We take steps to protect your personal data against loss or theft as well as from unathorised access, disclosure, copying use or modification. 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.
13. HOW TO COMPLAIN
In the event of a complaint your request can be made to us by email, telephone or in writing to the contact details noted at ‘CONTACT US’. 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
14. CHANGES TO THIS PRIVACY NOTICE
This privacy notice was published on 18/05/2018 and last updated on 18/05/2023. We may change this privacy notice from time to time and the most up to date version will be available as above.
15. IF YOU NEED EXTRA HELP
If you would like this notice in large print, please contact us at the details provided above.
If you would like further information please contact Suzanne Palmer.
HES Estate Management Limited is committed to protecting the privacy and security of your personal information. This notice provides details on what information we collect about you and how we will use it during the management of your estate or development and after it ends.
We do not use your data for direct marketing purposes and we will not sell or share your data at any time for 3rd party marketing or selling purposes.
Because this is about greater protection and transparency for you please ensure you read this notice, the most up to date version of our privacy notices will be kept available on our website at all times http://www.heseml.co.uk/ . This 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
HES Estate Management Limited is a block and estate management company who collect, use and is responsible for certain personal information about you held in this capacity. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including the United Kingdom). 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 HES Estate Management Limited.
2. DATA PROTECTION PRINCIPLE
We will comply with the data protection principles when gathering and using personal information and as set out in our GDPR data protection policy.
3. INFORMATION COLLECTED BY US
Personal data is information which directly or indirectly identifies you. In the course of managing your Estate or Block for our clients we collect the following personal information:
• Your name; contact details including the property address (and other addresses if different to that under management); your home mobile and other numbers; your email contact details.
• We may also collect details of your mortgage provider, any tenants names and contact numbers if your property is let out, or other contact details you provide to us for us to liaise with you or others about your property.
• Occasionally we may collect sensitive information in relation to your health, disability or financial circumstances where this is appropriate for resolving an issue directly relating to the management of the estate or block.
• We may collect other information given by you during interactions or correspondence.
• We may collect information from other sources such as solicitors, the previous managing agents, the freeholder or superior lease owner, your RMC or RTM, their directors or any of their professional advisors, joint owners, your letting agent or others that act on your behalf such as accountants and other professional advisors.
The provision of your personal data is required from you or these other sources to enable us to perform our contract as managing agent appointed for and on behalf of the freeholder or superior landlord of your block or your estate owner. We will only collect information where there is a lawful basis to do so.
4. HOW WE USE YOUR PERSONAL INFORMATION
We will typically collect and use this information for the following purposes:
• For the performance of a contract eg your lease that you have with our clients; the freeholder, superior leasehold owner, RMC, RTM or other owner of the block or estate under management, pursuant to which we are appointed as their agent;
• or the performance of a contract with us directly;
• 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;
• Where we believe it is necessary to use your information to comply with a legal obligation to which we are subject.
The use of your data could include, but is not limited to, verifying your identity, providing you with services, managing your account and the contractual relationship with you as noted above. 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.
We do not use your data for direct marketing purposes and we will not sell or share your data at any time for 3rd party marketing or selling purposes.
5. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We routinely share the following categories of personal data:
•Your name, your address or addresses, your contact telephone numbers, your contact emailaddresses, your agent or tenants personal data;
We will only share sensitive financial or health information when it is necessary for the performance of our or your contract.
This personal information may be shared with the following categories of recipients:
•The freeholder or superior leasehold owners or estate owners or their directors or their appointed agents or professional advisors;
•Contractors that we employ for the maintenance and upkeep of your block or estate or who are appointed to undertake assessments;
•Professional advisors including brokers, insurers, loss adjustors, surveyors, project managers, accountants, payroll, solicitors, debt collectors;
•Professional bodies that regulate us;
•Our service providers for IT, data storage, or IT management; these include Bytemark, Microsoft Office 365, Propman and Eurolink;
•We may also use ‘Google Analytics’ and ‘Share this’ third party services for visitors to our website once we ensure our use and they are GDPR compliant;
•Our professional advisers;
•We will also share personal information with any law enforcement agency, tax authority, court,regulator or other government authority or other third party where we believe this is necessary tocomply with a legal or regulatory obligation, applicable law or otherwise to protect our rights.
Please be aware that the GDPR does not apply to information held in the public domain, such as Companies House data.
This data sharing enables us to perform our contract as managing agent. We require other parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and the GDPR. We will not share your personal information with any other third party.
6. WHERE YOUR PERSONAL INFORMATION MAY BE HELD
Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above. The data may be held physically or digitally using multiple servers.
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 and security policy.
Our investigation shows that all our third party IT agencies now store all data in the EU and are subject to the GDPR.
7. HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
• We may retain your personal data for a period of at least 6 years from the end of the relationship to fulfill our record-keeping obligations;
• Other data will not be retained for any longer than is necessary unless there is a legal or regulatory reason for extended retention.
8. REASONS WE CAN COLLECT AND USE YOUR PERSONAL INFORMATION
• The primary basis we collect and use your personal details is under contract, either directly or through the principal of agency.
• Additionally, we may collect your personal data where we have a legitimate interest in doing so. When this is the case we will only collect your personal data where our reasons are not overridden by your interests, rights, and freedoms.
9. TRANSFER OF YOUR INFORMATION OUT OF THE EEA
We may transfer your personal information to ‘Google Analytics‘, ‘Share This‘ which have servers located outside the European Economic Area (EEA) once we have established that they are GDPR compliant.
In these cases where the country may not have the same EEA laws, we will make sure your personal data is protected in accordance with the applicable data protection laws. We will not otherwise transfer your personal data outside of the United Kingdom or EEA.
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:
• the fair processing of information and transparency over how we use your personal information;
• access - you have a right to request a copy of the personal information that we hold about you, in a structured, commonly used and machine-readable format;
• recitification – you have the right to require us to correct any mistakes in your information that we hold;
• be forgotten – in certain circumstances you can ask for the data we hold to be erased;
• restrict processing – where certain conditions apply you can restrict the processing of your data;
• portablility - to transmit your data to a third party in certain situations;
• object - at any time to processing of personal information concerning you for certain types of processing such as direct marketing;
• object in certain other situations to our continued processing of your personal information;
• otherwise restrict our processing of your personal information in certain circumstances;
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.
11. CONTACT US
If you would like to exercise any of those rights, please:
•email, call or write to us at [email protected], 01372 677977 or GDPR request, HES Estate Management Limited, 2 Chartland House Old Station Approach Leatherhead Surrey KT22 7TE.
•provide us with enough information to identify you including your full name, your address, the property address,
•let us have proof of your identity and address (a copy of your driving licence or passport and a utility or credit card bill not more than 3 months old), and
•let us know the information to which your request relates, including any account or reference numbers, if you have them.
In the event we refuse your request we will provide you with a reason as to why, which you have the right to legally challenge.
12. KEEPING YOUR PERSONAL INFORMATION SECURE
We take steps to protect your personal data against loss or theft as well as from unathorised access, disclosure, copying use or modification. 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.
13. HOW TO COMPLAIN
In the event of a complaint your request can be made to us by email, telephone or in writing to the contact details noted at ‘CONTACT US’. 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
14. CHANGES TO THIS PRIVACY NOTICE
This privacy notice was published on 18/05/2018 and last updated on 18/05/2023. We may change this privacy notice from time to time and the most up to date version will be available as above.
15. IF YOU NEED EXTRA HELP
If you would like this notice in large print, please contact us at the details provided above.
If you would like further information please contact Suzanne Palmer.
