Tenant Privacy Notice

TENANT PRIVACY NOTICE

1. Introduction
2. How do we obtain your personal information?
3. What personal information do we collect about you?
4. How do we use your personal information?
5. On what basis do we use your personal information?
6. How long will we keep your personal information?
7. With whom do we share your personal information?
8. Transfers of your personal information outside of your home country
9. Protecting your personal information
10. Your rights
11. Contact us
12. Data controller and representative

1. Introduction

1.1 We want to make sure you understand what personal information we may collect about you when you interact with us and our group of companies (Liberty, we, us and our), how we use your personal information, and how we keep it safe. See section 12 below for details of the Liberty company that is the controller of your personal information.

1.2 This privacy notice explains:

(i) how we obtain your personal information;

(ii) what personal information we collect about you;

(iii) how we use your personal information;

(iv) on what basis we use your personal information;

(v) how long we keep your personal information;

(vi) with whom we share your personal information;

(vii) the countries to which we transfer your personal information;

(viii) how we protect your personal information; and

(ix) your rights regarding your personal information.

1.3 We may change this privacy notice from time to time and, where we make any material changes, we will inform you of these.

1.4 If you have any questions, feel free to get in touch via one of the methods set out in the Contact us section below.

2. How do we obtain your personal information?

2.1 We gather information about you when you provide it to, or interact with, us or third parties that we work with; e.g. when you get in touch in relation to your tenancy, or when you engage with one of our representatives. We may gather information about you from various public sources. We may also receive information from law enforcement agencies, for example where the police are involved with incidents relating to any of our properties.

3. What personal information do we collect about you?

  • 3.1 The personal information that we process includes:
  • Contact information – including name, email address, address and phone numbers;
  • Information relating to the identity of tenants, prospective tenants and related persons (such as guarantors) – including date of birth, photographic identification (such as driving licence, passport or ID card), proof of address (such as utility bills), and information relating to immigration status;
  • Financial information relating to tenants, prospective tenants and related persons (such as guarantors) – including bank account details and credit checks;
  • CCTV images from our properties; and
  • Criminal data – for example, where the police are involved with incidents relating to any of our properties.

4. How do we use your personal information?

4.1 We use your personal information for the following purposes:

      • to perform our role as landlord and to maintain and manage our properties – including record-keeping, accounts, inspections and audits, collection and payment of rent, insurance and other sums, and property repairs;
      • to contact you – for example with information about our properties, and notifications relating to upcoming rent reviews, renewals of tenancies, and surrenders;
      • to operate our business – including to:
      1. receive services from our suppliers and financial services providers;
      2. respond to your requests;
      3. comply with applicable laws, rules, regulations, guidance, codes and industry and professional rules and regulations;
      4. comply with demands or requests made by regulators, governments, courts and law enforcement authorities;
      5. investigate and take action against illegal or harmful behaviour; and
      • for the establishment, exercise or defence of legal claims or proceedings.

5. On what basis do we use your personal information?

5.1 We use your personal information for the following reasons:

      • to comply with legal and regulatory obligations;
      • because you have given your consent – at times we may ask for your consent to allow us to use your personal information for one or more purposes;
      • for legitimate business purposes – using your personal information helps us to operate and improve our business and minimise any disruption to the services that we may offer to you. It also allows us to make our communications with you more relevant to you;
      • to perform a contract to which you are a party – we may need to process your personal information in relation to your tenancy of one or more of our properties, or to receive services from our suppliers;
      • for the establishment, exercise or defence of legal claims or proceedings; and
      • because it is necessary for reasons of substantial public interest, on the basis of applicable laws.

6. How long will we keep your personal information?

We will always keep your personal information for the period required by law in Jersey, the Isle of Man, Luxembourg and the United Kingdom. We will also keep your personal information where we need to do so in connection with legal action or an investigation involving us or any member of the Liberty group of companies.

Otherwise, we keep your personal information:

      • for the duration of your tenancy or otherwise for as long as needed to provide you with property-related services; and
      • for as long as it is necessary and relevant for our operations.

Personal information that is no longer necessary or relevant for our operations will be de-identified and/or disposed of securely. In addition, we may retain information from closed accounts to comply with the law, prevent fraud, resolve disputes, troubleshoot problems, assist with investigations, enforce our terms and conditions and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Notice.

7. With whom do we share your personal information?

7.1 We may share certain of your personal information with:

      • members and affiliates of the Liberty group of companies;
      • the following trusted third parties:
      1. selected business partners, including Global Mutual Properties Limited;
      2. selected sub-contractors and suppliers, such as estate agents and property managers (e.g. Savills), and our corporate services provider; and
      3. banks and other financial services providers;
      • our professional advisors and auditors; and
      • courts, regulators, governments and law enforcement authorities.

7.2 See section 9 (Protecting your personal information) for information on how we keep your personal information secure when sharing it with others.

8. Transfers of your personal information outside of your home country

8.1 Your personal information will be processed by Liberty, its affiliated entities and Liberty’s trusted third party suppliers in the United Kingdom, the Isle of Man, Jersey, Luxembourg and Ireland.

8.2 It may also be processed in countries such as the United States and other jurisdictions where data privacy laws may not be equivalent to, or as protective as, the laws in your home country.

8.3 We will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside of your home country, in accordance with applicable data protection and privacy laws. These measures include data transfer agreements implementing standard data protection clauses. You can find more information about data transfer agreements at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

9. Protecting your personal information

9.1 We use a variety of security measures and technologies to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection and privacy laws.

9.2 When Liberty uses a third party service provider, they are carefully selected and required to use appropriate measures to protect the confidentiality and security of personal information.

9.3 The transmission to us of information via the internet or a mobile phone network connection may not be completely secure and any transmission is at your own risk.

10. Your rights

10.1 Data privacy laws provide you with a number of rights over your personal information. You may be entitled to:

      • ask us about the processing of your personal information, including to be provided with a copy of your personal information;
      • request the correction and/or deletion of your personal information;
      • request the restriction of the processing of your personal information, or object to that processing;
      • withdraw your consent to the processing of your personal information (where we are processing your personal information based on your consent);
      • request receipt or transmission to another organisation, in a machine-readable form, of the personal information that you have provided to us; and
      • complain to your local supervisory authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal information.

10.2 Where you are given the option to share your personal information with us, you can always choose not to do so.

10.3 If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

10.4 This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described (see section 4 – How do we use your personal information?) or that you are unable to make use of the services offered by us.

11. Contact us

11.1 If you have questions or requests about the processing of your personal information, or need additional information, you can contact us at: cust.serve@TheLiberty.co.uk.

12. Data controllers and representative

12.1 Controllers: The trustees of Liberty Centre Unit Trust (Liberty Centre (Trustee No.1) Limited and Liberty Centre (Trustee No.2) Limited), the trustees of the Liberty Square Unit Trust (Castle Hill Nominees No.7 Limited and Castle Hill Nominees No.8 Limited) (together, the Liberty Trustees) and Romford Investment Holding S.À R.L. are each a controller of your personal information, and can be contacted via the email address in section 11.1.

12.2 Representative: The representative of the Liberty Trustees in the United Kingdom and the European Union is BM Data Services Ltd, who will also be the representative of Romford Investment Holding S.À R.L. in the United Kingdom after the United Kingdom leaves the European Union. The contact details of BM Data Services Ltd are: 50 Oxford Road, High Wycombe, HP11 2EE and all correspondence should be marked for the attention of James Simpson.

This Privacy Notice was last updated on: October 2019.