1. Introduction and General Terms
This Privacy Notice sets out how the landlord (“Landlord”) named in your lease (“Lease”) and the Grosvenor’s property management company (“PMC”) named in your tenant information letter obtain, use and protect your personal information that you provide to us, or that is otherwise obtained or generated by us, in connection with the Lease. The contact details for your Landlord and PMC are set out alongside their names in Appendix 1 and Appendix 2 to this Privacy Notice, respectively. For the purposes of this Privacy Notice (unless expressly stated, or the context requires, otherwise), ‘we’, ‘us’ and ‘our’ refers to each of your Landlord and your PMC and ‘you’ refers to you the lessor.
This Privacy Notice explains the following:
- what personal information we may collect from you;
- how we keep your personal information safe;
- what we may use your personal information for;
- who we may share your personal information with; and
- your rights regarding your personal information.
The Landlord and PMC are each a data controller in respect of your personal information for the purposes of applicable data protection legislation.
2. Legal ground for processing personal information
We will process personal information relating to you (except for electronic marketing purposes (see section 2b below)) on the ground that such processing is necessary to: (i) further our legitimate interest in the effective administration and management of the Lease; and/or (ii) comply with our legal obligations, including those obligations relating to anti-money laundering checks and ‘Right to Rent’ checks under immigration laws.
We may also process personal information relating to you in order to send you electronic marketing communications about news, events, products and services that we believe may be of interest to you, provided we have received your consent to do so. You may withdraw such consent at any time and choose not to receive such marketing communications from us by either selecting the unsubscribe option at the bottom of each communication that we send to you or by contacting us using the details in section 10.
3. Personal information we may process about you
a. How do we collect personal information about you?
We collect personal information that you provide to us or which is provided to us on your behalf by your legal advisors and/or managing agents, in each case in relation to the Lease. You do not have to provide any personal information that we request from you, but it may not be possible for us to effectively administer and manage the Lease (or grant you the Lease at all) if that personal information is not provided.
b. What types of personal information may we process about you?
We may process any or all of the following personal information that relates to you:
your name, date of birth, place of birth and nationality;
your email address, postal address, telephone and mobile number;
your bank account details;
identifiers from your passport, driving licence or other ID card; and
details of the products and services that you specify in your marketing preferences, provided we have received your consent to do so (see section 2b).
4. Keeping your personal information safe
a. Where the personal information is held
We store your personal information on our property management software system, Yardi Voyager, which is provided and hosted by a third party, Yardi.
Your personal information is also stored on our repairs and maintenance system, which is provided and hosted by a third party, Planon.
The Yardi Voyager and Planon systems are secure and comply with industry standards, so as to protect your personal information from unauthorised access. Access to both the Yardi Voyager and Planon systems is limited to representatives of the Landlord and PMC as well as certain of our service providers (see section 6).
b. Retention of your personal information
For audit and financial reasons, we will hold your personal information on our systems for 3 years following the date on which the Lease terminates or expires. We may continue to hold your personal information for a longer period if required to do so by applicable law.
5. What we may process your personal information for
We process your personal information for the following purposes:
- carrying out background checks relating to you prior to you entering into the Lease (including anti-money laundering, financial and credit checks);
- managing and administering the Lease and the property to which the Lease relates, including the billing of sums payable under the Lease and the management of any alterations to the property that are requested by you;
- carrying out our obligations under the Lease, including the refunding of the appropriate proportion of your deposit on the termination or expiry of the Lease and the arrangement of your access to nearby secured gardens and squares (if provided for under the Lease);
- enforcing the terms of the Lease;
- notifying you about changes to the Lease;
- arranging our access to your property as and when required, including where our access is required in order for us to comply with our legal obligations;
- if relevant, enforcing the terms of the ‘Belgravia Estate Management Scheme’ and ‘Grosvenor Mayfair Estate Management Scheme’, which provide a framework of management for the continued conservation of the Belgravia and Mayfair areas of London;
- sending you electronic marketing communications about news and events that we believe may be of interest to you, provided we have received your consent to do so (see section 2b);
- complying with any applicable present or future law, rule, regulation, guidance or directive, and complying with any applicable industry or professional rules and regulations or any applicable voluntary codes;
- complying with demands or requests made by local and foreign regulators, governments and law enforcement authorities, and complying with any subpoena or court process, or in connection with any litigation; and
- activities connected with any sale, merger, acquisition, disposal, recognition or similar change of our business.
6. Who we may share your personal information with
We may share your personal information with any of the following recipients as may be necessary or desirable for the purposes described in section 5:
- other members of our company groups and their respective employees;
- our service providers, including legal and financial advisors, managing agents, management surveyors, insurance brokers, debt recovery agents (such as Boodle Hatfield, Murray Birrell and NG Bailey) and hosting service providers (such as Yardi and Planon);
- local and foreign regulators, governments and law enforcement authorities;
- local and foreign courts, tribunals and arbitrators, other judicial committees and enactments of laws; and
- persons connected with any sale, merger, acquisition, disposal, reorganisation or similar change to our business (including any potential or actual purchaser or that business and that purchaser’s advisors).
All third parties to whom we transfer personal information relating to you will be under an obligation to protect the confidentiality and security of that personal information.
7. Your rights regarding the personal information you provide to us
The accuracy of the personal information we hold about you is important to us. Under applicable data protection legislation you have rights concerning your personal information.
have a right to correct any inaccurate or incomplete personal information we hold on you. You have a right to receive a copy of the personal information we hold on you, which we must provide to you in a structured, commonly-used and machine-readable format. You have a right to require us to stop or to restrict our processing of your personal information. You have a right to require the erasure of personal information we hold on you once it is no longer necessary in relation to the purposes for which the personal information was collected or is being processed.
Please contact us if you wish to exercise any of these rights using the details in section 10.
If you have a complaint about how we manage your personal information, please contact us. Our contact details are in section 10. If you are still not satisfied after going through our internal complaints procedure you can complain to The Information Commissioner’s Office by telephone on 0303 123 1113 or through the following link: https://ico.org.uk/global/contact-us/email/
We will review and may update our Privacy Notice from time to time. Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice on grosvenolondon.com website. Please check our website frequently to see any updates or changes to our Privacy Notice, a summary of which we will set out in section 9 below. In any event, we will provide you with a copy of this Privacy Notice when you first become a tenant with us. All important changes made to our Privacy Notice will be notified to you by email or post.
This Privacy Notice was last reviewed and updated in May 2018.
Contact details amended (section10) and amendment to appendix 2
If you have any questions, comments or requests regarding any aspect of this Privacy Notice, please call your principal Grosvenor contact or:
By post: GBI Data Protection, The Grosvenor Office, 70 Grosvenor Street, London, W1K 3JP
By email: dataprotectionGBI@grosvenor.com
Issued May 2018