Tenant privacy notice

The Grosvenor Estate strongly believes in protecting your privacy and the confidentiality of your personal information. In order to explain how the Grosvenor Estate collects, uses and protects personal information in connection with tenant management we have developed the following privacy notice. In this privacy notice, ‘We’ and ‘Us’ means the Grosvenor Estate.

The data controller for the purposes of the Data Protection Act and the General Data Protection Regulation is the 4th Duke of Westminster’s 1964 Settlement Trust.

This privacy notice applies to tenancy applicants, tenants, former tenants and owners of 'enfranchised' properties.

Contact details

You can contact us with any questions you may have about privacy and/or data protection. Our contact details are as follows:

About this privacy notice

We collect personal information as part of the tenant application process, and if you become a tenant, in the course of your tenancy. We explain in detail below the types of information that we collect, how and why we use that information, and what rights you have in connection with your personal information.

We must have a lawful basis to process your personal information, and this notice explains what our lawful basis is in respect of each purpose for which we keep and use personal information about you. Generally, we are allowed to process your personal information where it is necessary in connection with a contract between us (such as a lease or maintenance agreement), where it is necessary in order for us to comply with our legal obligations as your landlord, or where we have a legitimate interest to do so (but we will always consider whether your right to privacy overrides our interest).

We may keep certain, limited personal information about you for our historical records, on the basis that there is a public interest in our doing so. Occasionally, we may also use your personal information on the basis that you have given us consent to do so, such as where you provide us with particularly sensitive personal information.

What personal information do we collect about you and how do we collect it?

We will require you to provide certain personal information to us where it is necessary, both as part of your tenancy application and if you are a tenant, in connection with your tenancy contract. If you fail to provide certain personal information when requested, we may not be able to offer you a tenancy contract, perform the contract if we have entered into one with you, or it may prevent us from complying with our legal obligations.

We may collect personal information through the application process, either directly from applicants or a background check provider. We also may collect additional personal information from third parties including employers, credit reference agencies or other background check agencies.

We will collect additional personal information as required.

We may collect and use the following personal information about you:

  • Identification and contact information, such as your full name, date of birth, age, postal address, email address and telephone number(s)
  • Your next of kin and emergency contact details, and information about your dependants
  • Information about your employment, including your employment status, salary, job title
  • A copy of your identification documents (driving licence or birth certificate for example)
  • Confirmation of your right to live in the UK, references and other information included as part of the application process
  • Financial information, such as your bank account details, payroll records, tax status information.
  • In England, information about any outstanding County Court Judgments (CCJs) against you
  • In Scotland, information about any decrees for payment against you
  • More sensitive information about you, including information about your previous criminal convictions, and the health information

For those with commercial tenancies we may collect contact information, such as your organisation’s postal address, email address and telephone number.

Personal information we collect about you from other sources

We may collect personal information about you from other sources. This may include the following:

  • Publicly available information, from sources such as Companies House, the Electoral Roll, County Court Judgements, decrees for payment, and repossessions this may include details about your home, household, vehicles, financial situation and debts
  • Information you have shared publicly, including on social media
  • Information from third party databases or data suppliers, such as commercial property sites, auction sites and credit reference agencies, including details about your home, belongings and creditworthiness
  • Information provided to us in relation to your health, where we have a requirement to support you as a landlord (see ‘Personal information concerning health’ below)

This list is not exhaustive and, in specific instances, we may need to collect additional personal information for the purposes set out in this notice.

Personal information for those applying for a tenancy at the Reay Forest Estate

The senior management of the Reay Forest is undertaken on the Grosvenor Estate’s behalf by CKD Galbraith LLP (company number SO300208). CKD Galbraith LLP manage the tenancy application process on the Grosvenor Estate’s behalf.

How do we use your personal information?

We take data protection law seriously. We have set out in the table below how and why we use your personal information, and what our legal basis is to be able to use your personal information in each way. The principal legal bases on which we use your personal information are as: (a) to Allow us to enter into and perform a contract, (b) to enable us to comply with legal obligations, and (c) in order to pursue legitimate interests of our own or those of third parties (provided your interests and fundamental rights do not override those interests).

Basis for processing personal information

Allow us to enter into and perform a contract

Enable us to comply with legal obligations

In order to pursue legitimate interests of our own or those of third parties (provided your interests and fundamental rights do not override those interests)

Administering a tenancy if we have entered into one with you

X

 

 

Checking you are legally entitled to reside in the UK

 

X

 

Complying with our health and safety obligations

X

X

X

Dealing with any complaints you may have

X

 

X

Dealing with legal disputes involving you, or other tenants or other residences, including accidents on the Grosvenor Estate

 

X

X

Determining the terms on which you will be granted tenancy

X

 

 

Estate management and planning, including accounting and auditing

 

X

X

Making a decision about your application for a tenancy

X

 

 

Making decisions about rent reviews

X

 

X

Making decisions about your continued residency

X

 

X

Making arrangements for the termination of your tenancy or residency

X

 

X

Making repairs, alterations and improvements to your property

X

X

X

To detect and prevent fraud, money-laundering and other crimes

 

X

 

To inform you about the Grosvenor Estate including news that may be of interest to you as part of the community and events that may be happening on or around the Grosvenor Estate

 

 

X

To interact and respond to any communications you send us, including social media posts that you tag us in

 

 

X

To let you know about any important changes to our business or policies

 

 

X



Telling you about events and activities that we think may be of interest to you

We may use your personal information to identify and tell you about events and activities that we think may be of interest to you. We will only do this by email where you have informed us that you would like to receive these communications via email. Whether you choose to receive this information via email is entirely up to you. Your choice will not affect your tenancy. You can update your preferences by responding to our emails to you, or by contacting us (see contact details above).

We may also use your information to invite you to participate in market-research. If we do contact you about market-research, you do not have to participate. If you tell us that you do not want to receive market-research communications, we will respect this.

Grosvenor Estate‘s historical records

For those with residential and farming tenancies, we will also use some of your personal information for the purposes of keeping and maintaining the historical records of Grosvenor Estate. Grosvenor Estate’s historical records date back hundreds of years and there is a public interest in retaining these records, as such personal information may be used in certain circumstances for historical and genealogy research. The personal information kept for the purposes of historical records will be limited to basic identifying information and will not contain any health information.

In respect of current or recent personal information about you, we believe that your fundamental right to privacy is more important than any public interest in our records. We have a legitimate interest in keeping this personal information as it will later become an important historical record but, in order to protect your privacy, the personal information that we collate for use in our historical records will be kept confidential for a period of 100 years after collection. During that period, access to your personal information will be restricted to certain individuals within the Grosvenor Estate and will not be made available to the public.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Personal information concerning health

Personal information concerning health requires higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process this personal information in the following circumstances:

  • With your explicit written consent
  • Where we need to carry out our legal obligations and in line with this privacy notice
  • Where it is needed to assess any special requirements you may have due to any disabilities or health issues you may have, subject to appropriate confidentiality safeguards

Less commonly, we may process this type of personal information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the personal information public.

We do not need your consent if we use personal information concerning health in accordance with this privacy notice to carry out our legal obligations, or exercise specific rights, in the field of property and landlord and tenancy laws. In limited circumstances, we may require your written consent to allow us to process certain particularly sensitive personal information. If we do, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us (but, where we require such consent in connection with a particular service, we may not be able to provide that service to you without such consent).

Information about criminal convictions

We may only use personal information relating to criminal convictions where the law allows us to do so. We may use this information:

  • in connection with the application process to assess your suitability for a tenancy agreement; and
  • in limited circumstances, with your explicit consent.

Where we process such information it shall be in accordance with this privacy notice and subject to appropriate safeguards.

Who do we share your personal information with?

Sharing your personal information within the Grosvenor Estate

We may share your personal information with our employees where this is necessary, such as for internal administration purposes. Your personal information will only be shared with such employees as are reasonably necessary for these purposes.

Sharing your personal information with third parties

We may need to share your personal information with certain third parties, including third-party service providers, and we require third parties to respect the security of your personal information and to treat it in accordance with the law.

We will share your personal information with third parties where required by law, where it is necessary to administer your tenancy, support our relationship with you or where we have another legitimate interest in doing so. The following activities are carried out by third-party service providers:

  • Letting our properties
  • Providing energy supplies to our properties when tenants leave
  • Providing professional advice and support regarding estate management
  • Undertaking property compliance requirements
  • Undertaking maintenance and repair to our properties

There are also certain exceptional circumstances in which we may disclose your personal information to third parties. This would be where we believe that the disclosure is:

  • Required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings
  • Required due to the collection of debt and/or and tracing agencies
  • Required due to planning and/or building requirements
  • Required due to environmental schemes and designations
  • Required if we need to locate you but you are no longer residing at your last known address, or with whom contact has been lost
  • Necessary to protect the safety of our employees, our property or the public
  • Necessary for the prevention or detection of crime, including exchanging personal information with other companies or organisations for the purposes of fraud protection and credit risk reduction.

The senior management of the Reay Forest is undertaken on the Grosvenor Estate’s behalf by CKD Galbraith LLP (company number SO300208). CKD Galbraith LLP handle the tenancy management process at the Reay Forest on the Grosvenor Estate’s behalf.

Our property management IT system is provided by Qube Global Software Limited (company number 01656218). We may allow Qube Global Software Limited to access your personal information where it is necessary in order for them to provide this service. This may include preventing or addressing service or technical problems, and dealing with support issues.

Sharing your personal information with the general public

We will not make any personal information concerning you available to the public, except in the case of our historical records (please see “Grosvenor Estate Historical Records” above). These records will be stored securely and confidentially for a period of 100 years before being made available to the public

How long do we keep your personal information?

We will only keep your personal information on our mailing list, where you want to be kept informed about our residential properties, for only as long as you want to receive this information.

If you do not become a tenant or decide you no longer want to take up a tenancy then we will hold your personal information for three years.

For residential and farming tenancies, we will retain your personal information for six years after the end of your tenancy with us. We will additionally retain the following personal information indefinitely, for the purposes of keeping and maintaining Grosvenor’s historical records (but please note that these records will remain confidential for a period of 100 years):

  • Name
  • Dates of residence
  • Location of property
  • Lease

If you provide us with your personal information in relation to a commercial tenancy and you then leave that organisation, and we are then made aware of this, we will then remove your contact details and replace them with another contact. In all other circumstances we will we will retain your personal information for six years after the end of your tenancy with us.

How do we protect your personal information?

We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this notice.

All personal information you provide to us is stored securely, including in a physically secure environment, on our secure servers.

Access to your personal information will be restricted to such employees and other individuals as are necessary for the purposes for which the information was collected.

What rights do you have in respect of your personal information?

You have the right to be informed

We have a legal obligation to provide you with concise, transparent, intelligible and easily accessible information about your personal information and our use of it. We have written this notice to do just that, but if you have any questions or require more specific personal information, you can contact us (see contact details above).

You have the right to access your personal information

You have the right to ask us to confirm whether or not we hold any of your personal information. If we do, you have the right to have a copy of your information and to be informed of the following:

  • Why we have been using your personal information
  • What categories of personal information we were using
  • Who we have shared your personal information with
  • How long we envisage holding your personal information

In order to maintain the security of your personal information, we will have to verify your identity before we provide you with a copy of the information we hold.

You have the right to correct any inaccurate or incomplete personal information

You have the right to amend any inaccurate personal information about you which we hold. If you need any support please contact us (see contact details above).

You have the right to be forgotten

There may be times where it is no longer necessary for us to hold personal information about you. This only relates to the following:

  • The personal information is no longer needed for the original purpose that we collected it for
  • You withdraw your consent for us to use the personal information (and we do not have another lawful reason to use it)
  • You object to us using your personal information and we have no overriding reason to keep using it
  • We have used your personal information unlawfully
  • We are subject to a legal requirement to delete your personal information

In those situations you have the right to have your personal information deleted. If you believe one of these situations applies to you, please contact us (see contact details above).

You have the right to have a copy of your personal information transferred to you or a third party in a compatible format

Also known as Data Portability, you have the right to obtain a copy of your personal information for your own purposes. This right allows you to move, copy or transfer your personal information more easily from one IT system to another, in a safe and secure way. This right shall only apply where:

  • we are processing your personal information for the purposes of entering into or performing a contract; or
  • you have provided consent for us to process your information.

If you would like us to transfer a copy of your personal information to you or another organisation in a structured, commonly use and machine-readable format, please contact us (see contact details above).

You have the right to object to receiving emails from us about events and activities

You can tell us at any time that you would prefer that we do not use your email address to be contacted about events and activities. If you would like to stop receiving emails about events and activities please contact us (see contact details above) or respond to the emails that we send, and we will stop sending these immediately.

You have the right to object to us using your personal information for our own legitimate interests

Sometimes, we use your personal information to pursue our own legitimate interests, or those of third parties (please see ‘How do we use your personal information?’ above for more information about such interests).

We aim to always ensure that your rights and personal information are properly protected. If you believe that the way we are using your personal information is not justified due to its impact on you or your rights, you have the right to object. Unless we have a compelling reason to continue, we must stop using your personal information for these purposes.

In order to exercise your right to object to our use of your personal information for the purposes above, please contact us (see contact details above).

You have the right to restrict how we use your personal information

You have the right to ask us to stop using your personal information in any way other than simply keeping a copy of it. This right is available where:

  • You have informed us that the personal information we hold about you is inaccurate, and we have not yet been able to verify this
  • You have objected to us using your personal information for our own legitimate interests and we are in the process of considering your objection
  • We have used your personal information in an unlawful way, but you do not want us to delete your personal information
  • We no longer need to use the personal information, but you need it for a legal claim

If you believe any of these situations apply, please contact us (see contact details above).

Changes to our privacy notice

Any changes we make to this privacy notice in the future will be posted on this page. Please check back to see any updates or changes to this privacy notice.

Complaints

If you wish to make a complaint about our collection or use of your personal information, please contact us in the first instance so that we may seek to resolve your complaint.

If you are not satisfied with our response you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the statutory body which oversees data protection law in the UK. This is the link to the ICO website if you wish to lodge a complaint with the ICO.

Grosvenor Estate tenant privacy notice v1-0

This privacy notice was updated in May 2018