All data subjects whose personal data is collected, in line with the requirements of the GDPR and the Data Protection Act.
We review our policies regularly to ensure they reflect current legislation and guidance for all aspects of our business.
2.1 The Compliance Officer is responsible for ensuring that this notice is made available to data subjects prior to BRNS Group collecting/processing their personal data.
2.2 All Employees/Staff of BRNS Group who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.
3. PRIVACY NOTICE
3.1 Who are we?
BRNS Group “BRNS” is property company offering Management Services, as well as Lettings services for landlords based in the United Kingdom.
Our Data Protection Officer and data protection representatives can be contacted directly here:
• 020 8442 7434
The personal data we collect will be used for the following purposes:
• Contacting you in relation to assisting with your specified brief of finding a property for let.
• Undertaking the necessary verifications in relation to referencing checks.
• The inclusion of any detail specific to the necessity of completing and binding contracts or agreements (tenancy agreement, terms of business, holding/ payment receipts completion documentation)
• Arranging access for maintenance, inspections or viewings of the property
• Making contact in relation to the renewal or termination of the tenancy
• Making contact in relation to payments associated with scheduled rentals or invoices
Our legal basis for processing this personal data will be in relation to:
• Our compliance to retain for a fixed period specific records or documentation as required to satisfy set obligations put in place by law.
• The review of any tenancy agreements
• Any possible legal action which may need to be implemented
Any legitimate interests pursued by us, or third parties we use, are as follows:
• Utilities providers, block management/freeholders, collections agencies
• Contractors (maintenance, surveyors, inventory clerks, referencing, etc.)
• Solicitors acting on behalf of the landlord or agent, insurers of the landlord
The special categories of personal data concerned are:
• Name, D.O.B, Title (Mr/Mrs Etc)
• Validity documents (proof of ID, Visa, right to rent)
• Contact details (telephone/mobile number, email address, property address)
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.
Consent is required for BRNS GROUP to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data, we will always tell you why and how the information will be used.
You may withdraw consent at any time.
BRNS will not pass on your personal data to third parties without first obtaining your consent. The following third parties that will receive your personal data for the following purpose(s) as part of the processing activities are:
Credit referencing agencies, authorised maintenance companies and landlords, utility companies, deposit schemes and ombudsman schemes where appropriate.
3.4 Retention period
BRNS will process personal data for the period of your tenancy, or until you request that we stop, and will store the personal data for 6 years in the event of you entering into a tenancy or other legal agreement as specified by legislation.
3.5 Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: if BRNS refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.
In the event that you wish to make a complaint about how your personal data is being processed by BRNS (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with BRNS, you also have the right to escalate the matter to the Office of the Information Commissioner.
The details for each of these contacts are:
Information Commissioners Office
Wycliffe House, Water Lane
Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113
149 Northwold Road
Telephone: 0208 442 7434
4. ONLINE PRIVACY STATEMENT
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person ('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”.
How we use your information
This privacy notice tells you how we, BRNS, will collect and use your personal data.
Why does BRNS need to collect and store personal data?
In order for us to provide you with a service we need to collect personal data to enable us to process your application and fulfil our obligations to you by maintaining the property appropriately In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
In terms of being contacted for marketing and subscription purposes BRNS would contact you for additional consent.
Will BRNS share my personal data with anyone else?
We may pass your personal data on to third-party service providers contracted to BRNS in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with BRNS Group`s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
For the avoidance of doubt, BRNS does not sell nor purchase personal data, data files, metadata, demographic information.
How will BRNS use the personal data it collects about me?
BRNS will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. BRNS is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will BRNS contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I find out the personal data that the organisation holds about me?
BRNS at your request, can confirm what information we hold about you and how it is processed. If BRNS does hold personal data about you, you can request the following information:
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of BRNS or a third party, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• If we intend to transfer the personal data to another country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will I need to provide in order to access this?
BRNS accepts the following forms of ID when information on your personal data is requested:
Passport, driving licence, birth certificate, utility bill (from last 3 months), etc.
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