GDPR Privacy Notice

(Last updated 11th August 2020)

Introduction and background

The purpose of this privacy notice is to outline how HomeGround Management Limited has established measures to protect your privacy and information rights.
If you have any questions in respect of this notice, or would like to exercise your rights as a data subject (for example, to correct data or to exercise your right to access), HomeGround can be contacted as follows: enquiries@homegroundonline.com or PO Box 6433 London W1A 2UZ, marked for the attention of the Data Protection Officer.

Your rights

We recognise that you have rights as a ‘data subject’, and that we have an obligation to uphold these.

This privacy notice aims to outline how we maintain these rights.  In particular, it outlines:

  • How we collect and process your information;
  • Why we do this;
  • What type of personal information we collect;
  • How you can exercise your rights; and
  • Who to contact in the event you’re unhappy with our performance.

Under current UK data protection law, you have rights including:

Right Explanation
Right to be informed This means that we have to be transparent in how we collect and use your personal data.
Right to access You have the right to access your personal data.
Right to rectification If the information we hold about you is inaccurate or incomplete, you can request that we correct this.
Right to erasure You can request that we delete or remove personal data in certain circumstances.
Right to restrict processing

You have the right to request that we cease processing your data, if:

  • you consider it inaccurate or incomplete; and/or
  • you object to the reason we are processing your data.

We will review the validity of your request and respond to you with our decision.

Right to data portability Where you have consented to our processing your data, or where the processing is necessary for us to deliver a contract, you can request a copy of that data be provided to a third party in electronic form.
Right to object

You have the right to object to our processing in certain circumstances. For example, you can object to:

  • direct marketing; and
  • processing for the purposes of scientific/historical and statistics.

For the avoidance of doubt, we do not process data for these purposes.

Rights relating to automated decision making including profiling

Where we apply automated decision making, we must:

  • give you information about the processing;
  • introduce simple ways for you to request human intervention or challenge a decision;
  • carry out regular checks to make sure that our systems are working as intended.

We do not use automated decision making or profiling.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. If you exercise your right of access, we will require proof of identification and the one-month timeframe for a response begins from receipt of your identification document.

Please get in touch with us at enquiries@homegroundonline.com or PO Box 6433 London W1A 2UZ, marked for the attention of the Data Protection Officer to find out more or to exercise your information rights. There are circumstances in which we will decline your request, but we will explain this clearly to you.

Information we collect

Please find below a summary of the information we hold and how we use this to deliver services to you.

Information we collect Examples of Information Why we collect the information How we obtain the information

Core customer records

Customer correspondence

Customer billing

Customer  documentation (hardcopy)

Property Details, Name, Contact Details

Any Details provided by the customer

Payment and billing details

Lease or other title documents

We collect your information in order to perform a contract (your lease or title document). This includes, for example, administering and processing billing or consents and other obligations under your lease or title document. 

Most of the information we obtain is provided to us directly by your landlord or rentcharge owner.

 

We also receive information from customers directly and indirectly from managing agents or management companies, insurers, solicitors or payment processors in relation to the legal performance of your lease or title document.

Employee details

Contact details, financial details including tax, pension details, HR records including performance, disciplinary and recruitment We process this information about our employees to allow us to administer their employment and benefits pursuant to contract and for prospective employees in relation to recruitment 

Most of the information we process is provided to us by the employee or prospective employee directly.

Cookies Analytical information e.g. browsing patterns and statistical data We use the information to improve customer experience on our website Certain cookies are essential for the performance of the website and do not require consent. For analytical cookies we require your consent and there is an option on the website to modify your cookie preferences.

Sharing data

We share data with a number of third parties in the course of delivering our services.  These are summarised below:

  • Our IT service provider provides offsite backup services for us.
  • We use an offsite document scanning and storage facility. This allows us to make sure that our primary internal records are electronic.
  • We have a firm of accountants who operate payroll on our behalf and carry out auditing.
  • We use solicitors to deal with all legal aspects of our business.
  • We use surveyors and valuers to deal with freehold sale and lease extension valuations and matters relating to alterations.
  • We use insurance brokers to assist with sourcing and putting in place insurance policies for the buildings which we manage. Please refer to the short form Privacy Notice from Arthur J Gallagher Insurance Brokers Limited and Lockton Companies LLP below.
  • We share data with management companies and managing agents in order to administer the obligations in your lease or title document.
  • We use a cloud-based HR management system, to help us administer employee records.
  • We share employee data with training, benefits, pension and healthcare providers and in compliance with any audit obligations imposed on us in relation to our business activities.
  • We use confidential waste disposal for confidential documents.
  • We have a leasing arrangement with a photocopier provider.
  • We use property management software.
  • We use a cloud-based software system to operate our customer call centre.
  • We use a printing software provided by an external contractor to generate customer correspondence including secure printing and postal services.
  • We use a secure eCommerce portal to enable customer payments via our website or via telephone.
  • We use the Office 365 suite provided by Microsoft to handle our email and other office automation. 

Retention of data

With the exception of call recordings, HomeGround retains personal data for seven (7) years from our point of last contact.  Call recordings are kept for a period of 6 months from the date of call. We hold this information to support our legal and regulatory requirements. 

Securing your information

HomeGround applies technical and organisational security measures in line with industry good practices such as ISO 27001.  HomeGround has achieved the Cyber Essentials accreditation.

Short Form Privacy Notice from Arthur J Gallagher Insurance Brokers Limited

Arthur J. Gallagher Insurance Brokers Limited is the data controller of any personal information you provide to us or personal information that has been provided to us by a third party. We collect and process information about you in order to arrange insurance policies and to process claims. Your information is also used for business purposes such as fraud prevention and detection, and financial management. This may involve sharing your information with third parties such as insurers, reinsurers, other brokers, claims handlers, loss adjusters, credit reference agencies, service providers, professional advisors, our regulators, police and government agencies or fraud prevention agencies.

We may record telephone calls to help us monitor and improve the service we provide. For further information on how your information is used and your rights in relation to your information please see our privacy notice at www.ajginternational.com/Privacy-Policy/. If you are providing personal data of another individual to us, you must tell them you are providing their information to us and show them a copy of this notice.

Short Form Privacy Notice from Lockton Companies LLP

Lockton Companies LLP is committed to protecting the privacy and security of your personal data.

Who we are

As an intermediary providing regulated insurance broking services, Lockton Companies LLP is a “data controller”.

The basics

We collect and use relevant information about you to provide our insurance broking services to you, including (as applicable) risk consulting, arranging the insurance cover from which you benefit or handling your claims, and to meet our legal obligations.

This information includes details such as your name, address and contact details and any other information that we collect about you in connection with the insurance broking services we provide to you. This information may include more sensitive details such as information about your health and any criminal convictions you may have.

In certain circumstances, we may need your consent to process certain categories of information about you (including sensitive details such as information about your health and any criminal convictions you may have). Where we need your consent, we will ask you for it separately. You do not have to give your consent and you may withdraw your consent at any time. However, if you do not give your consent, or you withdraw your consent, this may affect our ability to provide our insurance broking services to you, including (as applicable) arranging the insurance cover from which you benefit and may prevent us from providing cover for you or handling your claims.

The way insurance works means that your information may be shared with, and used by, a number of third parties in the insurance sector for example, insurers, agents or brokers, reinsurers, loss adjusters, sub-contractors, regulators, law enforcement agencies, fraud and crime prevention and detection agencies and compulsory insurance databases. We will only disclose your personal information in connection with the insurance broking services that we provide and to the extent required or permitted by law.

Other people’s details you provide to us

Where you provide us with details about other people, you must provide this notice to them.

Want more details?

For more information about how we use your personal information please see our full privacy notice, which is available online on our website (https://www.locktoninternational.com/privacy-notice) or in formats on request.

Contacting us and your rights

You have rights in relation to the information we hold about you, including the right to access your information. If you wish to exercise your rights, discuss how we use your information or request a copy of our full privacy notice, please contact our Data Protection Manager at:

Lockton Companies LLP
The St Botolph Building
138 Houndsditch
London
EC3A 7AG

Email: dataprotection@uk.lockton.com
Tel: 020 7933 0000

Marketing communications from us

As part of our service to you, we will send you marketing communications from time to time which may include risk or insurance related information or details of services, or products, or events, which we think, may be of interest to you.

Managing your Marketing Preference (including Opting out)

You can manage your marketing preferences or ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing unsubscribe@uk.lockton.com.

Contact Us

We recognise that you may have questions on how we process and/or store your data, or may want to change either the data we hold on you or how we communicate with you in the future.

If you have any questions in respect of this notice, or would like to exercise your rights as a data subject (for example, to correct data or to exercise your right to access), Homeground Management Limited can be contacted as follows: enquiries@homegroundonline.com or PO Box 6433 London W1A 2UZ, marked for the attention of the Data Protection Officer.

If you are unhappy with our response to your query, of if you would like to escalate a concern, The Information Commissioner’s Office can be contacted on 030 3123 1113 or you can visit their website https://ico.org.uk for further details.