Contour Property Services Privacy Notice
1. Aim of this Notice
1.1. In order to help provide you with the best and most appropriate service, we need you to help us by providing us with the most up-to-date information as possible.
1.2. We will keep your personal data secure and only keep it as long as we need to, although please bear in mind we are legally obliged to keep some records for an extended period of time, before it’s safely destroyed.
2. Who is responsible for your data?
2.1. Our Privacy Notice applies to all the personal data that Contour Property Services collects and uses.
2.2. References in this Privacy Notice to “CPS”, “we”, “us” or “our” mean Contour Property Services.
2.3. CPS is a subsidiary of Onward Group. Colleagues are employed by Onward and will provide services to CPS customers so you will often see the Onward branding in our communications. The information you provide is kept on Onward’s systems but it will be clear within those systems that you are a CPS customer and that CPS is responsible for that information.
2.4. We control the ways your personal data are collected and the purposes for which your personal data are used by CPS and are the “Data Controller” for the purposes of the UK GDPR and the Data Protection Act (2018).
3. What personal data do we collect about you?
3.1. When using the term “personal data” in our Privacy Notice, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold.
3.2. Your personal data may include, for example, your name, your contact details, information relating to your lease (e.g. your Reference Number) or information on how you use our website and online services or how you interact with us.
3.3. We collect personal data from you, for example when you first become a leaseholder, use our website or contact us. We may also receive your personal data from our contractors/suppliers who provide services to you on our behalf or your legal representatives.
3.4. The majority of the personal data we collect and use is on the basis of managing your leasehold contract or in the legitimate interests of you or the business.
3.5. We may collect and process the following categories of information about you:
- Your name and contact details for use across the organisation and by our contractors/suppliers;
- Detailed personal data, such as:
- Bank details
- Contact details of individuals who you want us to communicate with on your behalf
- Landlord / agent details
4. How and why we use your personal data
4.1. We use your personal data for the following purposes:
4.1.1. Entering into and managing your leasehold, and contacting you about:
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- Details relating to the repair and maintenance of communal areas;
- Records of payments for the services provided to you;
- Details about complaints about our service or other individuals, accidents or incidents involving communal areas;
- We may also record factual information whenever you contact us or use our services, so we have a record of what happened.
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Without this we cannot progress or manage your leasehold.
4.1.2. To provide security and ensure health and safety:
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- We operate CCTV systems, which collect and record images, and are used in accordance with CCTV relevant government guidance;
- We may hold information about your history, for example, related to offences, to look after our staff, business or anyone else.
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4.1.3. To communicate with you and manage our relationship with you:
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- We (including our contractors/suppliers) may need to contact you by telephone, email and/or SMS for administrative or operational reasons
- To seek your feedback to improve our services and experiences.
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4.1.4. To personalise and improve your customer service experience
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- We may use your personal data to evaluate your preferences and our performance. Some of these contacts may be automated, however we will ensure that any such processing of this kind does not have any legal or similarly significant effect on you;
- If you are in the process of making a request under your account and you leave our website before your request has been completed, we may contact you in order to help you easily complete your request or make payment;
- Voice recordings for quality management;
- With your written consent, your name, photo, video or story could be used for brochures, advertising,press releases or internal news stories;
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4.1.5. To fulfil our administrative purposes and support our business interests
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- The business purposes for which we will use your information include accounting, billing and audit, credit or other payment card verification, fraud screening, safety, security and legal purposes, statistical and marketing analysis, systems testing, maintenance and development.
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4.1.6. To comply with our legal obligations
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- For example, our obligation to provide your information to HM Revenue and Customs (HMRC).
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5. Your Privacy Rights
5.1. The UK GDPR provides all UK citizens with specific privacy rights. CPS is committed to upholding these rights and takes its responsibilities regarding our customers privacy very seriously.
5.2. These include, your rights to request that CPS:
- Responds to your Subject Access Requests providing copies of your personal data where required;
- Corrects any inaccurate or incomplete personal data which CPS holds about you;
- Provides you with a copy of your personal data for you to move elsewhere;
- Stop processing your personal data, whilst an objection from you is being resolved;
- Permanently erase all your personal data promptly, and confirms this has been done.
5.3. We will consider each and every request and respond within one month of receiving a valid request. If your request is particularly complex we may extend this, by exception, for up to a further 2 months.
5.4. If you have questions in relation to exercising any of your privacy rights, please contact the Data Protection Officer in the first instance at data.protection@onward.co.uk
5.5. If, for any reason, CPS does not address your request, or fails to provide you with a valid reason why it is unable to do so, you have the right to contact the Information Commissioner’s Office (ICO) to make a complaint. They can be contacted via their website www.ico.org.uk or by telephone 0303 123 1113.
6. Security of your personal data
6.1. CPS are committed to taking appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage. When you provide your personal data through our websites or online portal, this information is transmitted across the internet securely using appropriate strength encryption.
6.2. As detailed in this Notice, we may in some instances disclose your personal data to third parties. Where CPS does disclose your personal data to a third party, we require that third party to have appropriate technical and organisational measures in place to protect your personal data; however in some instances we may be compelled by law to disclose your personal data to a third party, such as the Police, and have limited control over how it is protected by that party.
6.3. We will retain your personal data for as long as we need it in order to fulfil our purposes set out in this Privacy Notice and in order to comply with appropriate laws and standards.
7. Sharing your personal data
7.1. On occasions it’s in everyone’s best interests for us to share some of the information we have about our customers with other organisations. This may be to fulifil a legal obligation or to ensure you get the best service possible.
7.2. If you decide to end your leasehold without paying or arranging to pay any arrears you are in we may decide it’s necessary to share your details with a Debt Collection Agency to help us recover these arrears.
7.3. We will also provide some details to our contractors/suppliers, so they can contact you in relation to communal repairs or scheduled improvement work, to arrange a suitable time to visit.
7.4. In certain circumstances we may feel it’s necessary to provide your details to partner agencies (e.g. Police Local Authority) where there are concerns of criminal activity, an individuals health and safety or we have been made aware of potentially anti-social behaviour.
7.5. We’d like to stress that under no circumstances do we ever sell or pass on your information to business or organisations so they can get in touch with you directly either by phone, email or in writing in order to sell you their products or services.
7.6. Listed below are the categories of third parties we may share some of your personal data with. We will ensure that any information sharing is undetaken in compliance with the UK GDPR.
- Banks and Financial Service providers to process secure payments;
- Contractors and suppliers who provide services to you, or who provide services on our behalf
- Debt Collection Agencies
- External Auditors
- Insurance companies
- Organisations that support CPS and the services we provide such as Local Authorities, statutory agencies
- Solicitors
- Survey & Research organisations
- Utility companies
7.7. In some cases we may also have a duty to disclose your information by law to:
- Central Government Departments
- Courts & Tribunals
- Statutory agencies
- Local Authorities
- Organisations who support crime prevention or detection, the prevention and detection of fraud, and for the purposes of the National Fraud Initiative
- Regulators
7.8. CPS will not share or disclose your information with anyone who claims to represent you or be acting on your behalf unless we have verified you have appointed them or they are acting in some recognised official capacity.
8. Transferring information outside the UK/European Economic Area (EEA)
8.1. We will endeavour to limit the occasions where your personal data is transferred outside of the UK/EEA.
8.2. Where your data is transferred outside of the UK/EEA, we will make sure that transfers are only made to countries in which the UK has made an ‘adequacy decision’, or where appropriate safeguards are in place e.g. contractual conditions.
8.3. We may share your personal data with third parties or companies that perform services on our behalf, all third parties operate in accordance with legally binding contracts.
9. Updates to our Privacy Notice
9.1. We may make changes to our Privacy Notice from time to time. Any updates to the Privacy Notice will be published on our website where we will publish a new version of this Notice.
10. Contact information
10.1. Any questions or requests regarding this Privacy Notice should be addressed to Data Protection Officer at data.protection@onward.co.uk