What is the scope of this privacy notice?
This Privacy Notice applies to you if you contact us to request to purchase, lease land or acquire rights in, on or over land or buildings or other assets owned by the Guinness Partnership.
How will we manage our obligations?
Our obligations under Data Protection Regulations are overseen by the Information Governance Team who can be contacted on firstname.lastname@example.org
The Guinness Partnership has appointed a Data Protection Officer to monitor our compliance with Data Protection Regulations. If you have any concerns they can be contacted on:
- Data Protection Officer
1 Stable Street
What information is collected?
For us to progress your request, we will be asking for some or all of the following personal information:
- Contact name
- Contact details such as your phone number, email and postal address
- Registered address (for companies)
- Copies of 3 years trading accounts if available
- 12 months bank statements (if a lease is to be registered to a person)
- Company or charity registration number (if applicable)
- Financial information such as your bank details and credit rating.
- Bank Details (only if a lease is granted where we may be required to make payments to you)
- Details of contact we have had with you such as previous enquiries.
Why do we need this information?
We require this information in order to:
- enable Guinness or its agents to make contact and progress lease discussions
- enable Guinness to make contact and notify you of a suitable property becoming available
- allow Guinness to undertake due diligence checks to ensure compliance with laws and our own governance procedures
- set up a rent account where a new tenancy is agreed
- enable Guinness or its agent to arrange future access for property inspections or repairs where a tenancy is agreed
- ensure there is no unacceptable risks posed to you, our staff and contractors
- ensure we are fair and transparent with our customers
We need a lawful basis to use your information. The information provided through your request will be used under one of the following conditions:
- Necessary to take steps or for the performance of a contract – if you have applied to purchase, lease land or acquire rights in, on or over land or buildings or other assets owned by the Guinness Partnership. Without this we will not be able to process your request
- If it is required by law
Who will have access to my information?
Your information will be used by internal Guinness Teams including:
- The Commercial Assets Team
- Our Customer Support Team
- Legal Services Team
- Customer Accounts Team
- Income Team
- Management Accounting Team
- Asset Compliance Team
- Data Assurance Team
- Asset Maintenance Team
- Fixed Assets Team
- Customer Accounts Team
For us to be able to provide you with effective services, we will be required to share and/or receive your personal data from external organisations and/or people such as:
- Credit check providers such as Dun and Bradstreet
- Solicitors instructed by The Guinness Partnership
- Your solicitor
- Other authorised agents of The Guinness Partnership may also be passed information about you to help us maintain and manage the property
- Local Authorities
- Land Registry
How will you keep my information safe?
Your information will not be transferred outside of the European Economic Area.
We have ensured that appropriate safeguards are in place in relation to this information such as:
- Contracts in place with third party providers
- Access is restricted to those members of staff involved in supporting you
- We have secure methods of transferring information to third parties
- We ensure that our processes are aligned to Information security Standards such as ISO27001.
- To help us keep your personal information confidential, we may ask you (and any of your representatives) security questions to confirm your identity when you call us (this may also be necessary when we call you too). We will not discuss your personal information with any unauthorised person other than you, unless you have given us prior written or verbal permission to do so (as a one-off circumstance).
- We also make sure all our staff complete mandatory Data Protection training, so they understand their responsibilities to protect your data.
How long we keep it?
Where a lease, legal agreement or property agreement is granted, we will keep information about you throughout the duration of those agreements.
When your lease expires, legal agreement of property agreement, information about you will be kept for 12 years.
If a lease, legal agreement or property agreement is not granted, information about you will be deleted after 2 years unless you request that it is retained by us.
What rights do I have?
The General Data Protection Regulations gives you rights to exercise greater control over how we use your information. To ask us to consider any of your information rights as indicated below please write to:
The Information Management Governance and Risk Team
1 Stable Street
We will consider each and every request and respond within one month. If your request is particularly complex we may extend this, by exception, for up to a further 2 months. We will let you know if this is the case at the earliest opportunity.
Right of Access
You have the right to request access to your own records which, with some exceptions, means that people are entitled to a copy of information held about them.
You can apply by giving your name, address and date of birth and stating the information you require. Alternatively, you can complete a Subject Access Request form which can be found on our website www.guinnesspartnership.com
We will need to make sure that it is you making the request so, if required, we will ask for two forms of identification. This is so that we do not disclose any of your information to someone not entitled to receive it.
Right to have inaccurate data corrected (Right to rectification)
If you consider that any part of the information held in your record is inaccurate you can apply to have this corrected. If we agree that that information is incorrect, we will amend the record. If we are not satisfied that the information is incorrect, we will note down of what information you consider is inaccurate. You will be given a copy of either the correction or the note.
If there are any changes your circumstances e.g. change of name, telephone number etc, please let us know so we can make sure information kept about you is correct and up to date.
Right to have data deleted (Right to erasure)
We will do our best to ensure that all the information we collect is required to enter into and manage your lease, property and other legal documents. If you believe that we should no longer hold certain types of data about you, you can let us know, with your reasons as to why, to have this data ‘erased’.
We will then take a look at your request and let you know if we agree and when you can expect to have confirmation that your data has been deleted.
Right to stop use of personal data (Right to restriction of processing)
You have the right to request, in writing, for us to restrict the use of your personal details under one of the following circumstances:
- You have requested inaccurate data to be corrected. We cannot use your data until we have verified your request;
- You feel our use is unlawful but would prefer the data to be restricted rather than deleted;
- We no longer need to retain the information, but you feel it is required for legal proceedings;
- You dispute the legitimate interests of us collecting and using your information.
What to do if you if you are unhappy with the way your information is being processed?
If at any point you believe the information we process on you is incorrect, wish to have it corrected or deleted or you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, you can complain to the Information Commissioner’s Office (ICO). www.ico.org.uk