Privacy Policy

Overview

At Blake Property Management Limited (hereafter referred to as BPM) we value your privacy and know how important it is to you that your data is handled confidentially. We would, therefore, like to assure you that we comply with all the statutory requirements for data privacy and data security. This statement explains the nature, scope and purpose of the data BPM collects and stores from you, through our interactions with you and how we use the data supplied.

In accordance with the requirements of the General Data Protection Regulations (GDPR), you have various rights these include the right to file an objection against the data we hold. More information on this is given in the ‘Your Rights’ section of this statement.

Please ensure that you read this document carefully. If you have any queries please contact us at dataprotection@blakepm.com

Definitions

GDPR: General Data Protection Regulations (2018). New legislation that came into law on 25 May 2018.

Data Protection: The process of safeguarding Personal Data from unauthorised or unlawful disclosure, access, alteration, processing, transfer or destruction by an individual or individuals.

Personal Data: Any information relating to an identified or identifiable natural person.

Identifiable Individual: An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or one or more factors specific to their physical or social identity.

Data Controller: Is a person who (either alone or jointly or in common with other persons) determines the purpose for which and the manner in which any personal data are, or are to be, processed.

Data Processor: Any person who processes the data on behalf of the Data Controller in relation to information or data means.

Data Subject: Is a living individual to whom personal data relates.

Supervisory Authority: The Information Commissioners Office (ICO). The UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals.

Consent: Any freely given specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him or her.

Details of the entity responsible for processing data and contacting the Data Controller

This data information applies to data processing conducted by the responsible body which is as follows:


Blake Property Management Limited
PO Box 741
Aylesbury
Buckinghamshire
HP22 9BD

Tel: 01296 614882

The Data Controller may be contacted at the above address or via email datacontroller@blakepm.com

Data Controller/Data Processor

Due to the variety of customers and clients we serve, in some instances we are the Data Controller and others we are the Data Processor. Please see definitions at the top of this Privacy Statement in accordance with the GDPR.

Statement Policy

This policy applies to our customers and clients, including but not limited to Leaseholders, Tenants and Residents for whom we collect and process personal data.

Data collected and how it is processed

All data that BPM collects will be processed lawfully, fairly and in a transparent manner. It will only be used to administer your account for specific and legitimate purposes, and only information that is relevant and limited to what is necessary will be collected. This means that BPM must not store any personal data beyond what is strictly required. All information you provide will be given voluntarily and only used with your consent. The data that is held will be accurate to our knowledge and where necessary and with your consent, updated to reflect changing circumstances.

Type of Personal Data collected:

The following is a list of the type of information which we may hold for you:

  • Your name
  • Contact address
  • Leasehold/freehold property/development address
  • Mobile and landline telephone numbers
  • Email address/s
  • Third party emergency contact details for you if submitted to us
  • Telephone calls to BPM
  • Email correspondence to BPM
  • Financial records relating to maintenance/service/ground rent charge
  • Insurance claims for notified leasehold property
  • Dealings with contractors such as loss adjusters, solicitors, building maintenance contractors/personnel.

Legitimate interests for processing Personal Data

Legitimate interests, where applicable, for processing personal data may include:

  • Keeping our records up to date
  • Seeking consent when we need to contact you
  • Complying with regulations that apply to us
  • Being efficient about how we fulfil our legal and contractual duties to your respective Residential Management Company
  • Keeping you informed of items which are relevant to your development/leasehold property and which may affect you
  • Dealing with issues relevant to the development/leasehold property where applicable.

How we collect Personal Data

We collect personal data via the following methods:

  • Our website at www.blakepm.com
  • Calls to our offices
  • Written communication
  • Third parties such as insurance companies, loss adjusters, solicitors, accountants, contractors.

How long do we hold Personal Data for?

We will keep your personal information for as long as your Residential Management Company (RMC) is a client of BPM.

However, should the RMC not continue as a client of BPM we may keep your personal information for a period of up to seven years for one of these reasons:

  • To respond to any questions or complaints from the new managing agent
  • To maintain records according to legal requirements and documented business needs.

We may keep your personal information for longer than seven years if we cannot delete it for legal, regulatory or technical reasons. In these circumstances we will make sure that your privacy is protected and only use it for legal or regulatory purposes.

Please note under HMRC regulations all financial records must be kept for a minimum of six years. For BPM to comply with this regulation all personal data held by BPM will be held for a minimum of seven years after which a review will take place to determine as to whether BPM will delete or archive any or all data held.

Sharing of your Personal Information

We may share your personal information in the following ways:

  • If required to do so for legal and regulatory compliance
  • Preventing or detecting financial crime
  • Complaints handling or improving customer service
  • Via solicitor or other professional involvement in the sale or purchase of properties
  • To a third party as part of a sale of the business and assets to the third party. (However, steps will be taken to ensure that your privacy rights continue to be protected and that the data is used in accordance with our Privacy Statement).
  • In an emergency, we may be required to give your contact details out to a contractor to contact you. We will always try and contact you beforehand
  • As part of our process for collecting development/company funds, where there has been no contact made by you to advise why no payment has been made. We may pass your details on to a Debt Collecting Agency. The agency we use has undergone checks to ensure they are GDPR compliant and will not share your details further
  • When required to do so we enlist the expertise of external solicitors for legal advice. Your data may be passed on to them to give them a better understanding of specific legal situations;

There may be instances where we share data with the Freeholder, Residential Management Company and Directors of a development. We will query the use of the data to ensure the reason is a ‘Legitimate Interest’ before giving information and to ensure they have adequate protection in place to store your data

Should we lose management of a site we will give all information we hold to the new Managing Agents to ensure they can manage the development from the moment they take control.

Other than the points listed above we will not disclose your personal information without your permission. We do not sell your information to third parties and your personal data is treated with the up most care.

Data Security

Personal data shall be processed in a manner that ensures appropriate security of the personal data provided, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. Our security measures undergo continuous improvement in accordance with technological development. Personal data is held on PC’s, security protected and with external data security agencies.

Sending Personal Information outside of the EEA

Data protection law holds all countries in the European Economic Area (EEA) to the same high standards. If we transfer information outside of the EEA, we will make sure that it is protected to these standards. We will only send your personal information to countries outside of the EEA to:

Follow your instructions; or

Comply with a legal duty.

We will always use one or more of these safeguards:

  • Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA
  • Put in place a contract with the recipient that means they must protect it to the same standards as the EEA; or
  • Transfer it to organisations that subscribe to Privacy Shield. This is a framework that sets privacy standards for personal information sent between the US and EU countries.

Subject Access Request (SAR)

You have the right to request data that we hold on you. Please either email us at datacontroller@blakepm.com or write to us at


Blake Property Management Ltd
PO Box 741
Aylesbury
Buckinghamshire
HP22 9BD

Please mark your correspondence “Subject Access Request” and include specifics of the data that you wish to receive.

Timeframe

The maximum amount of time that we will take on your request is one month from receipt of the request unless we advise in writing of a specific reason as to why we cannot complete it in this time.

Fees

There is no charge for providing this information unless the request is unfounded, excessive or repetitive in which case a fee may apply.

Format of information to be provided

We will ask as to how you would like the information to be provided and whether this should be electronically or in printed copy.

Where the request relates to data held over a long timeframe we may ask you to be more specific to assist us in searching for the information you are requesting.

Where we are the Data Controller we will process your request. Where we are the Data Processor we will communicate with the Data Controller who may wish to take ownership of the request.

Your Rights

In order to exercise your rights under data protection law we will need to verify your identity for your security.

How to get a copy of your Personal Data

You can request a copy of your personal information, as well as why we have that personal information, who has access to that personal information and where we got that personal information from at any time. Once we have received your request we will respond within one month.

Personal Data Amendments

You can amend your personal data by either writing to us at the following address or by sending us an email quoting your property details:


Blake Property Management Limited
PO Box 741
Aylesbury
Buckinghamshire
HP22 9BD

Email: datacontroller@blakepm.com

If you want us to stop using your Personal Information

You have the right to object to our use of your personal information, or to ask us to delete, remove or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and the ‘right to erasure’ (or ‘right to be forgotten’).

We may be able to restrict the use of your personal information so that it can only be used for certain things, such as legal requirements applicable to your leasehold property or to exercise legal rights in general.

In this situation we would not use or share your information in other ways while it is restricted.

You can ask us to restrict the use of your personal information if:

  • It is not accurate;
  • It has been used unlawfully but you don’t want us to delete it;
  • You have already asked us to stop using your personal information and are waiting for us to assess your request and confirm whether we are permitted to continue using your personal information under data protection law.

If you want us to erase your Personal Information

If you feel that we should no longer be using your personal information, or that we are illegally using your data, you can request that we erase the personal information we hold on you.

When we receive your request, we will confirm whether the personal information has been deleted or tell you the reason why it cannot be deleted. There may be legal reasons as to why we need to keep your personal information.

Data Protection Complaints

If you wish to raise a complaint in regards to the way we have handled your data or you have a concern with your data please raise this with our Data Controller using the contact details within this Privacy Statement.

If we are unable to come back to you with a satisfactory response you can raise your concerns with the Supervisory Authority (ICO). This can be done via the following methods:


Email: - casework@ico.org.uk

Phone: - 0303 123 1113

Post:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Blake Property Management Limited is registered with the ICO and has been since April, 2004. Our registration reference is Z854144

We hope that you find this Privacy Statement useful. We believe it to be an honest and transparent view to what information we hold on you and how we use it.

Should you have any comments please direct these to the Data Controller whose contact details are listed in this Privacy Statement.