IPM Ltd recognises that data protection is the cornerstone of its operations and is committed to processing information about individuals in ways that comply with its obligations under the General Data Protection Regulation (GDPR).
As a managing agent, we will process the personal data of individuals. It is necessary for us to do so to perform our role as a managing agent. Whenever we process the personal data of individuals, we will ensure that we are clear with those indi-viduals about what we do (or may do) with their information.
This privacy policy explains what personal data (information) we hold about individuals and contains important information on who we are, how and why we collect, store, use and share personal information, individuals’ rights in relation to their personal information and on how to contact us and supervisory authorities in the event you have a complaint.
WHO WE ARE
IPM Ltd collects uses and is responsible for certain personal information about individuals. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
In this privacy policy, references to “we” or “us” mean IPM Ltd.
DATA PROTECTION PRINCIPLES
We will comply with the data protection principles set down by the GDPR when gathering and using personal information.
THE PERSONAL INFORMATION WE COLLECT AND USE
In the course of our duties as a managing agent, we collect and process information relating to individuals.
The information we collect (and how we handle that information) differs depending on who the individual is, and why we are collecting their information.
THE PERSONAL INFORMATION WE COLLECT AND USE RELATING TO OUR LEASEHOLDERS AND OTHER OCCUPIERS ON THE DEVELOPMEMT WE MANAGE
The personal information we collect and use relating to leaseholders and other occupiers on the estates we manage.
To enable us to do our job as a managing agent, we need to collect personal information on people who occupy flats, apartments and other dwellings on the estates where are instructed to manage. This includes leaseholders and other occupiers, for example sub-tenants.
The information we collect
We may collect the following types of information:
- Identity and Contact Data includes name, billing and correspondence addresses, email address(es), telephone number(s) and other contact details, title, date of birth, photographic identification and gender
- Property Data includes details regarding your property including full address, details of any lease and details of your lender (if applicable), sub-tenant and letting agent details
- Communication Data includes details of any enquiry you have made in writing, email, phone, or any report you have submitted to us
- Transaction and Financial Date includes details about payments to and from you and other details including bank account details
- Profile and Usage Data includes feedback and survey responses and information on how you use our website and tenant portal
- Health Data relating to accidents or incidents on site that we are required to collect under Health and Safety legislation
- Special Categories of Personal Data may also be collected, including information concerning your health
In addition, we will from time to time search from other sources as follows:
- Name and address from Land Registry to confirm property ownership
From time to time we may also be given personal information by third parties including (but not limited to) the following:
- Identify and Contact Data from Previous Managing Agents or direct from Clients
- Mortgage account numbers and references from banks
- Death certificates from executors of your estate
- Registered Power of Attorney
- Evidence of bankruptcy or insolvency
Why we collect it
The collection of this information is required to enable us to perform our role as managing agent for the block you live in. It helps us to:
- Provide our leaseholders and other occupiers of the blocks we manage
with services they expect to receive from us, as the appointed managing agent - Improve and develop our services and performance as a managing agent
- Develop and provide products and services in line with our role as managing agent
Who we share it with
From time to time, we may share your personal information with the following categories of recipients:
- Solicitors, Barristers and Debt Collection Companies
- Insurers, Insurance Brokers and Loss Adjusters
- Contractors, including maintenance contractors, out of hours services and emergency call providers
- Regulatory authorities, including the Fire Authority and Local Authority, other Emergency Services
- Regulatory authorities, including the Fire Authority and Local Authority, other Emergency Services
- Parking enforcement
- IT and software support
- Financial services, including Accountants
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other third party.
Where your personal information may be held
Information may be held at our offices, and third-party agencies, service providers, representatives and agents as described above.
We have security measures in place to seek to ensure that there is appropriate security for information we hold including those measures detailed in our GDPR data protection policy.
How long your personal information will be kept
We will retain your personal information whilst ever we are instructed to manage the development where you are a leaseholder and/or occupier. Following cessation of our management of your particular development, we will retain your personal information for twelve (plus one) years.
Our lawful basis
If you are a leaseholder (or own a dwelling on an development we manage), our basis for processing your data is contract.
If you are an occupier or other third party, then our lawful basis for processing your data is legitimate interests. It is necessary for us to process the personal information we have described so that we can perform our role as managing agent for the block where you live, and also to protect the legitimate interests of our client. Our processing activities are a targeted and proportionate way of achieving this. Occupiers, including sub-tenants etc.. reasonably expect that we will process their personal
information.
THE PERSONAL INFORMATION WE COLLECT AND USE RELATING TO ALL OTHER THIRD PARTIES
We will collect personal information from other third parties, including prospective clients and customers of IPM Ltd. We also collect personal information about individuals from previous managing agents and solicitors, and from our client(s) directly.
We may collect the following types of information:
- Identity and Contact Date details such as name, address, email address, telephone number(s) and other contact details
- Company Contact Data includes your company’s name, your position in the company, the company’s address and your company email address and telephone number
- Information required to provide you with a service and details of our service that you may be interested in or have shown an interest in
Why we collect it
The collection of this information is required to enable us to act as a residential managing agent, which helps us to:
- Provide our customers and occupiers within the blocks we manage with services they expect to receive from a managing agent
- Improve and develop our services and performance as a managing agent in the residential management sector
- Develop and provide products and services
Special Categories of Personal Data will be collected and processed where the data subject has given explicit consent to the collecting and processing.
Who we share it with
From time to time, we may share your personal information with the following categories of recipients:
- Website and IT support
- Marketing platforms and services
- Surveying platforms and services
Some of those third-party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’.
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other third party.
Where your personal information may be held
Information may be held at our offices, and third-party agencies, service providers, representatives and agents as described above.
We have security measures in place to seek to ensure that there is appropriate security for information we hold including those measures detailed in our GDPR data protection policy.
How long your personal information will be kept
We will retain information relating to you whilst ever our business relationship continues, and for up to two years thereafter.
Our lawful basis
We rely on legitimate interests as our lawful basis for processing this personal information. It is necessary for us to process the personal information we have described so that we can perform our job as a managing agent. Our processing activities are a targeted and proportionate way of achieving this.
TRANSFER OF YOUR INFORMATION OUT OF THE EEA
We may transfer your personal information to the following countries which are located outside the European Economic Area (EEA):
- United States of America
IPM Ltd is satisfied that any transfer of your personal data to platforms outside of the EEA has ap-propriate safeguards and adequate levels of data protection for your personal data, through those platforms confirming their compliance with safeguards such as Privacy Shield.
YOUR RIGHTS
Under the General Data Protection Regulation, you have a number of important rights free of charge.
In summary, those include rights to:
-
fair processing of information and transparency over how we use your use personal information
-
access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
-
require us to correct any mistakes in your information which we hold
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require the erasure of personal information concerning you in certain situations
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receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
-
object at any time to processing of personal information concerning you for direct marketing
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object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
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object in certain other situations to our continued processing of your personal information
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otherwise restrict our processing of your personal information in certain circumstances
-
claim compensation for damages caused by our breach of any data protection laws
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- Email us at data@inspiredpm.co.uk
- Let us have enough information to identify you (for example your full name and email address)
- Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- Let us know the information to which your request relates, including any account or reference numbers, if you have them
KEEPING YOUR PERSONAL INFORMATION SECURE
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
OUR DATA PROTECTION TEAM
If you have any questions with regard to this privacy notice, please contact our Data Protection Manager on the contact details below:
Ms Andrea Barnard
Data Protection Manager
Unit 6 Malton Way
Adwick-le-Street
Doncaster
South Yorkshire
DN6 7FE
Email: Data@inspiredpm.co.uk
HOW TO COMPLAIN
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at
https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
CHANGES TO THIS PRIVACY NOTICE
This privacy notice was published on 23rd May 2018 and last updated on 14th May 2023.
We may change this privacy notice from time to time, and when we do we will inform you.