Pristine Block Management

 Privacy Notice

This notice sets out how we will use your personal data, and your rights. It is made under Articles 13 and/or 14 of the General Data Protection Regulation (GDPR).

YOUR DATA

 Purpose

The purposes for which we are processing your personal data are to:

- carry out our business which involves block management and leaseholder service charge management.

- conduct internal administration of our business, such as the production of accounts or dealing with regulators; and

- bring or defend legal proceedings or to cooperate with law enforcement agencies where we are legally required to.

 The data

We will process the following personal data:

- contact details for leaseholders or ex-leaseholders (address, email addresses, phone numbers etc.) that we work for.

- contact details for tenants and ex-tenants who live or lived within the flats  rented out by leaseholders that we work for.

- personal data included in leases that we manage or have managed.

- banking details and records for client accounts in Pristine Block Management’s name where monies are held and administered on behalf of our clients.

- accounts and expenditure records for service charge funds used to run the blocks.

 - invoices and quotes relating to running the blocks on behalf of our clients.

- contact details for a variety of companies, individuals, accountants, local authorities, solicitors and possibly others who provide or may provide in future services to our clients.

- account statements produced by us showing a historical and current record of service charge demanded and paid.

- correspondence and emails relating to our work from contractors, professionals, leaseholders, tenants and our clients.
 

Legal basis of processing

 Where we process your personal data we do so on one of the following lawful bases:

 - It is necessary for the purposes of the legitimate interests pursued by Pristine Block management or by a   third party except where such interests are overridden by the interests of the data subject. This would typically involve use of personal data for the carrying on of our legitimate business.

 - It is necessary for the performance of a contract to which you are a party. This could be a contact between you and a third party for example a tenancy agreement you hold with a leaseholder.

 - It is necessary in order to take steps at your request prior to entering into a contract. For example if you send us personal data about your clients or tenants in order to price our services.

- It is necessary to comply with a legal obligation placed on us as the data controller.

- It is necessary to protect your vital interests, or the vital interests of another person. This would apply for example if we had to provide data to law enforcement or medical services in order to protect life.

- Because you otherwise consent to us doing so.

Special category personal data is personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

Pristine Block Management does not actively collect special category personal data, but if we receive such data our lawful bases for processing will be because you consent to us doing so, or because it is necessary for the establishment, exercise or defence of legal claims, or because it is necessary to protect your vital interests, or the vital interests of another, where you or the other person is physically or legally incapable of giving consent.

Recipients

Your personal data will be shared by us with:

- the leaseholder if you are the tenant of a leaseholder.

- the building freeholder or resident management company where we are acting on their behalf.

- third party suppliers where necessary to carry out our block management functions. For example we may need to give our resident details where repair services are requested.

- our own third party suppliers where necessary to obtain services such as accounting, legal advice or auditing.

- Our own third party IT services, including web hosting, email and document storage services.

- law enforcement agencies, public bodies or regulators where we are required to do so.

- any successor organisation in the event that our business is acquired by or merged with a third party.

- otherwise with your consent.

 
Retention

 We will hold tenant details until we are notified that they have been replaced by a new tenant, and all outstanding business matters with that tenant are concluded.

We will hold data about our current clients and their blocks for the duration of the service. We will then hold the minimum necessary data as part of our financial records for a further seven years.

We will hold correspondence and emails relating to our work from contractors, professionals, leaseholders, tenants and our clients for the duration of the service.  We will then hold the minimum necessary data as part of our financial records for a further seven years.

Where personal data have not been obtained from you.

For leaseholders tenants, if we did not obtain your personal data from you, it was obtained from your leaseholder landlord.

For leaseholders, if we did not obtain your personal data from you, it was obtained from your building freeholder or from the residents management company or Her Majesty’s Land Registry.

Data in leases, titles or title plans may be obtained from Her Majesty’s Land Registry.

Data about actual or potential suppliers or clients will be obtained from public sources including the internet.

 
YOUR RIGHTS

You have the right to request information about how your personal data are processed, and to request a copy of that personal data. You may in certain circumstances have the right to obtain data that you have provided in a structured, commonly used and machine-readable format.

You have the right to request that any inaccuracies in your personal data are rectified without delay, and that any incomplete personal data are completed, including by means of a supplementary statement.

You may have the right to request that your personal data are erased if there is no longer a justification for them to be processed.

You have the right in certain circumstances (for example, where accuracy is contested) to request that the processing of your personal data is restricted.

You have the right to object to the processing of your personal data where it is processed for direct marketing purposes.

Where the processing is necessary for the pursuance of a legitimate interest or Pristine Block Management or a third party, you have the right to object to the processing of your personal data.

Where the personal data is processed on the basis of consent, you have the right to withdraw consent to the processing of your personal data at any time.

INTERNATIONAL TRANSFERS

As your personal data is shared with our IT suppliers, it may be transferred and stored securely outside the United Kingdom. Where that is the case it will be subject to equivalent legal protection through the use of Model Contract Clauses, the Privacy Shield scheme, or through an “adequacy decision” relating to that territory. Further information is available here: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-transfers/

CONTACT DETAILS

The data controller for your personal data is Pristine Block Management.

The contact details for the data controller are: pristineblockmanagement@fastmail.co.uk, or 07748 768 585.

COMPLAINTS

If you consider that your personal data has been misused or mishandled, you may make a complaint to the Information Commissioner, who is an independent regulator.  The Information Commissioner can be contacted at:  Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, or 0303 123 1113, or casework@ico.org.uk.