Your Privacy – updated in line with GDPR
Welcome to the Blair Group of Companies privacy notice, which sets out how we comply with the General Data Protection Regulation (GDPR), which will apply in the United Kingdom from 25 May 2018.
1. Important information and who we are
Purpose of this privacy notice
The privacy and security of your personal data is extremely important to us. This privacy notice explains how and why we use your personal data in the delivery of our activities, to make sure you stay informed and can be confident about giving us your data, and tell you about your privacy rights and how the law protects you.
- We will never sell your personal data and will only share it with organisations we work with when it is necessary and the privacy and security of your data is assured.
- We will never buy personal data from third parties.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller – who we are
The Data Controller, is Blair Estates Limited of Unit 3, Edge Business Centre, Humber Road, London NW2 6EW. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at email@example.com or please write to us at the above address.
If you are not happy with the way in which your personal information is held or processed, please contact us using the details above. You also have the right to complain about data protection matters to the Information Commissioner's Office (ICO).
Changes to the privacy notice and your duty to inform us of changes
This version of our privacy notice was last updated on 23/05/2018. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name and family name. This may include two documentary forms of identification, one of which must be photographic identification.
- Contact Data includes postal address, email address and land line and/or mobile telephone numbers.
- Financial Data includes payment information such as credit or debit card or direct debit details
- Technical Data includes internet protocol (IP) address browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to contact us by email or to access our website.
- Communications Data includes your communication preferences.
- Contractual Data includes any information we may collect in the course of pre-contractual discussions with you, and any information we may collect in the provision of our services to you
- CCTV and ANPR Images includes any photographic images we may record in the process of carrying out surveillance of public spaces and common arears across any of the properties we manage via closed circuit television cameras and Automatic Number Plate Recognition image processing technology. These images are captured for crime prevention, detection, apprehension and prosecution of offenders, and maintaining the safety of members of the public, staff and visitors.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with an answer to an enquiry). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
You may give us your Identity Data, Contact Data, Financial Data, Communications Data and Contractual Data by providing it to our staff in meetings, filling in forms or by corresponding with us by phone, email, post, fax or SMS. This includes personal data you provide when you:
- complete a contact details form
- complete a direct debit mandate form
- enter into a contract with us
- volunteer it to us in the course of using our services; or
- submit an enquiry
Automated technologies or interactions.
- When you visit public areas or common parts of any properties which we manage your images may be recorded by our closed circuit television monitoring equipment.
- As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- where we need to perform the contract we are about to enter into or have entered into with you;
- to make contact with you for the first time (for example, where you have made an enquiry to our offices);
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
- where we need to comply
with a legal or regulatory obligation.
In order to comply with our contractual, statutory, and management obligations and responsibilities, we process personal data, including ‘sensitive’ personal data
Such data can include, but is not limited to, information relating to health, racial or ethnic origin, and criminal convictions. In certain circumstances, we may process personal data or sensitive personal data, without explicit consent. Further information on what data is collected and why it is processed is given below.
- Contractual responsibilities: Our contractual responsibilities include those arising from the contract of employment. The data processed to meet contractual responsibilities includes, but is not limited to, data relating to: payroll, bank account, postal address, sick pay; leave, maternity pay, pension and emergency contacts.
- Statutory responsibilities: Our statutory responsibilities are those imposed through law on the organisation as an employer. The data processed to meet statutory responsibilities includes, but is not limited to, data relating to: tax, national insurance, statutory sick pay, statutory maternity pay, family leave, work permits, equal opportunities monitoring.
- Management responsibilities: Our management responsibilities are those necessary for the organisational functioning of the organisation. The data processed to meet management responsibilities includes, but is not limited to, data relating to: recruitment and employment, training and development, absence, disciplinary matters, e-mail address and telephone number.
- CCTV is used to provide security and protect residents, businesses, and the public spaces or common parts of properties that we manage. CCTV images will only be viewed when necessary (e.g. to detect or prevent crime).
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose / Activity
Type of Data
Lawful basis for processing including basis of legitimate interest
To provide our estate management services to you
Performance of a contract with you
To procure goods and services from you
Performance of a contract with you
To employ you
Performance of a contract with you
To provide closed circuit television monitoring services
(a) CCTV Images
(b) ANPR Images
(a) Necessary for our legitimate interests
(b) Necessary in the public interest
To respond to your enquiry submitted at one of our offices or via phone, email, post, SMS or via the website
(a) Performance of a contract with you; or
(b) Necessary for our legitimate interests (where you have made contact with us prior to entering into a contractual relationship with us.)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security or to prevent fraud)
(b) Necessary to comply with a legal obligation
To use data analytics to improve our website
Necessary for our legitimate interests (to keep our website updated)
We will not use your information for marketing purposes.
Change of purpose
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
5. Disclosure of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
- External third parties for the purpose of maintaining security
- We may from time to time need to share your personal data with other authorised contractors working on our properties where it is necessary for our legitimate interests.
- Where you have instructed professional advisers in connection with the purchase or sale of a property or the acquisition or disposal of an interest in property (for example a commercial lease), we may need to share your personal data with your professional advisers in order to respond to their queries or requests for information.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
There are no external third parties referred to above which are based outside the European Economic Area (“EEA”) so their processing of your personal data will not involve the transfer of data outside the EEA.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention – how long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In most circumstances we will keep your personal data for up to twelve years after your relationship with us ends, unless we are required to keep it longer to comply with a legal or regulatory obligation.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. For more information on Your Legal Rights, please see section 10 below.
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Glossary of Terms