You’ve probably heard about the EU’s new regulation, the General Data Protection Regulation (GDPR). It’s a new set of laws aimed at enhancing the protection of EU citizens’ personal data and increasing the obligations of organisations to deal with that data in transparent and secure ways. The GDPR applies not only to EU-based businesses, but also to any business that controls the processes of data of EU citizens.
In accordance with the General Data Protection Regulation and related UK data protection legislation, we are committed to protecting confidentiality and security of the information that you provide to us.
This Privacy Notice is designed to help you understand how we collect and use your information.
We may collect information from you or about other people, for example, family members who may part own the apartment, accountants, solicitors. If you give us information about another person it is your responsibility to ensure and confirm that:
You have permission from the individual to provide that personal information to us and for us to use it, as set out in this Privacy Notice. If you have any questions or queries about this policy please contact us.
Who we are:
William Hemming Associates Limited (also referred to in this Notice as ‘we’, or ‘our’)
How to contact us:
William Hemming Associates Limited. Nell Gwynn House, Sloane Avenue, London, SW3 3AX.
Why we need and how we use your personal information:
We only collect, use and store your information where we have lawful grounds and legitimate business reasons to do so. Eg where the disclosure is necessary for the purposes of the prevention and/or detection of crime.
We collect, use and store your personal information to fulfil requests for bookings, products and services as part of our serviced apartments management and lettings business. It may also be used to verify your identity, to administer payments and to enable us to carry out anti-money laundering and other financial crime checks where required. We do not store credit card details nor do we share financial details with any 3rd parties.
The use of your data is essential for us to manage your property as per the appointment contract and for our business to let your apartment for example. We may also use it to keep our records up to date, to notify you about changes to our service and to help us develop new products and services.
If you do not provide the information required we would be unlikely to be able to arrange the management of your property and maintain it on your behalf and other certain services to you.
Withdrawal of Consent
Where you have provided your specific consent to the use of personal data, you may withdraw consent by contacting us at our trading address.
How to make a complaint
If you wish to make a complaint about how we hold or use your data, please contact us at our trading address.
If you are dissatisfied with how we deal with your complaint, you may contact the Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
Information from other sources
We may use legal public sources to contact you if necessary, eg electoral role. Such information will only be obtained from reputable sources which operate in accordance with the General Data Protection Regulation.
We may use your information for purposes such as statistical and analytical research which may include computerised processes. Automatic profiling helps us understand, predict and forecast customer preferences and to improve the product and service we provide.
We never share your information outside our organisation for marketing purposes.
You understand however that we may need to disclose some of the information you provide to the relevant other parties for the purposes of general management, eg utilities etc.
Transfer of personal data outside the UK
Certain personal information held on our Information Technology systems may be transferred across geographical borders in accordance with applicable law. For reasons of off line backup/storage of data, electronic Bank Transfer.
By providing us with your information, you consent to the collection, international transfer, storage and processing of your information. These transfers are governed by European Union (EU) standard contractual clauses or equivalent data transfer agreements to protect the security and confidentiality of personal information.
How long will we keep information about you
We will keep your information for as long as it is required to enable us to administer the management of your apartment. In line with HMRC this will usually be a minimum of seven years or otherwise determined by law or regulation. Once we decide that we no longer need your information it will be securely and confidentially destroyed.
Your data protection rights
You have certain legal rights under UK data protection law and regulations, summarised as follows:
The right to be informed about our data processing activities, including through Privacy Notices such as this
The right of access to the personal information we hold about you. To request a copy of this information you must make a subject access request in writing to us
The right of rectification – you may ask us to correct any inaccurate or incomplete data within one month
The right to erasure and to restrict processing – you have the right to have your personal data erased and to prevent processing except where we have a legal obligation to process your personal information. You should bear in mind that by exercising this right you may hinder or prevent our ability to provide our services to you.
The right to data portability – on your request, we will provide you with your personal data in a structured format
We would like to keep you updated about our relevant products and services by email.
Nature of personal information
Personal data is any information that may identify a living individual.
We collect personal information such as name, contact details, bank account details.
Children’s Personal Data
You must be over 18 years of age to reserve an apartment with William Hemming Ltd. If children are travelling with you, we will need to know their age but we do not require their personal details and you will never be asked for their information at any stage in the reservation process. We may ask simple questions to help form your requirements, for example, if you require a cot or a high-chair.
Security of Information
Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. We take every reasonable measure to ensure your data is secure and only accessed by those requiring it to process your reservation.
When you make a reservation and enter payment details, this information is encrypted. This helps ensure your data is not transferred in a readable format and can’t be unlawfully accessed in transit.