WHO WE ARE
Casserly Property Management Ltd (CPM) collects, uses and is responsible for certain personal information about you. 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. CPM is a managing agent providing:
Block and estate management services to residential and commercial developments.
Statutory compliance management for schools, commercial properties and churches.
In this privacy notice, references to “we” or “us” means CPM.
DATA PROTECTION PRINCIPLES
We will comply with the data protection principles when gathering and using personal information, as set out in our GDPR data protection policy.
THE PERSONAL INFORMATION WE COLLECT AND USE: INFORMATION COLLECTED BY US
In the course of the performance of our contract as managing agent we collect the following personal information when you provide it to us:
Name, property address, correspondence address, home and mobile telephone numbers, e-mail addresses of leaseholders and tenants.
Name, email addresses, work and mobile telephone numbers, of client contacts such as School Business Managers and Site Managers.
Details of your visits to our website and which website you came to from ours.
Your comments and service reviews.
Your social media name if you interact with us through those channels to help us respond to your comments, questions or feedback.
The provision of data such as name, address and e-mail address etc is required from you to enable us to:
Perform our contract as appointed managing agent for the block/estate within which you own a freehold or leasehold property. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
Manage statutory compliance within your school, commercial property and church.
THE PERSONAL INFORMATION WE COLLECT AND USE: INFORMATION COLLECTED FROM OTHER SOURCES
We also obtain personal information from other sources as follows:
Name, property address, correspondence address, home and mobile telephone numbers, e-mail address and mortgage provider details from:
Land registry searches
Previous managing agent on handover
From solicitors or freeholders during the transfer of ownership or re-mortgage of a property
From arrears management companies
From letting agents during change of tenancy
HOW WE USE YOUR PERSONAL INFORMATION
We will typically collect and use this information for the following purposes:
For the performance of a contract you have with our client and pursuant to which we are appointed as managing agent or the performance of our contract with your school, commercial property or church. This includes but is not limited to:
To issue requests for service charge and rent payments and provide you with information about the property you own. We do this on the basis of our contractual obligations to our clients.
To respond to your queries and any complaints. Handling the information you have provided enables us to respond. We may also keep a record of these queries or complaints to help with any future communication and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to our clients, our legal obligations, our legitimate interest in providing you with the best service and understanding how we can improve our service based on your experience.
To send communications required by law or which are necessary to inform you about our charges to the services we provide you. If we do not use your personal data for these purposes, we would be unable to comply with our contractual obligations.
To process any contractor visits, e.g. if you have reported a leak from the flat above yours, we may need to ask a contractor to visit your property to establish the cause of the leak and any resultant damage. We would need to share your details with this contractor to enable the issue to be resolved. We do this on the basis of our contractual obligations to our clients.
To process contractor visits to your school, commercial property or church. We do this on the basis of our contractual obligations to our clients.
To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
If we discover any criminal activity or alleged criminal activity, we will process the data for the purpose of preventing or detecting unlawful acts. Our aim is to protect the individuals we interact with from criminal activities.
To send you relevant, personalised communications by post relating to the management of your development. We’ll do this on the basis of our legitimate business interest.
To comply with our contractual or legal obligations to share data with law enforcement, e.g. when a court order is submitted to share data with law enforcement agencies or a court of law.
To send client Directors or representatives survey and feedback request to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email. We do have a legitimate interest to do so as this helps make our services more relevant to you.
To send client representatives newsletters relevant to statutory compliance within your school, commercial property or church. This is when you have given us consent to do so.
We seek to ensure that our information collection and processing is always proportionate. We will notify you of any material changes to information we collect or to the purposes for which we collect and process it.
WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We routinely share the following categories of personal data:
Name, property address, correspondence address, home and mobile telephone numbers, e-mail addresses, service charge and rent arrears details of leaseholders and tenants.
Name, email addresses, work and mobile telephone numbers, of client contacts such as School Business Managers and Site Managers.
This personal information may be shared with the following categories of recipients
Operational companies such as contractors or surveyors who are attending your property
Residential Management Company Directors and Freeholder Clients
Client accountants or solicitors
Your solicitor during the sale of your property
Insurance companies in relation to your development only
Arrears management companies
Companies who we may use to help us manage our electronic communications with client Directors or representatives to send you survey and feedback request to help improve our services.
Companies who we may use to help us manage our electronic communications with client Directors or representatives to send you newsletters relevant to statutory compliance in your school, commercial property or church.
For fraud management. We may share information about fraudulent or potentially fraudulent activity in our premises or systems.
We will share personal information with law enforcement of other authorities if required by applicable law.
We provide only the information they need to perform their specific services.
This data sharing enables us to perform our contract as managing agent and comply with the law. We also have a legitimate interest to do so as this helps make our services more relevant to you.
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
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised.
REASONS WE CAN COLLECT AND USE YOUR PERSONAL INFORMATION
We rely on the following lawful bases on which we collect and use your personal data.
We need your personal data to comply with our contractual obligations e.g. we manage your property or development on behalf of our client under the terms of a management agreement or contract. For example:
Our client is the party within the lease/ transfer document which has the responsibility for looking after the communal areas, services and facilities and we act on their behalf in this respect. The lease or transfer relating to your property provides you to make a service charge or payment to our client and it is this money we use to maintain the development.
Our client is the school, commercial property or church which has appointed us to manage your statutory compliance.
If the law requires us to, we may need to collect and process your data, e.g. we can pass on details of people involved in fraud or other criminal activity to law enforcement
In specific situations, we can collect and process your personal data with your consent, e.g. when schools tick a box to consent to receiving email newsletters. When collecting your personal data, we’ll always make clear to you what data is necessary in connection with a particular service.
To process payments and to prevent fraudulent transactions
To send you relevant, personalised communications by post relating to the management of your development
To send client Directors or representatives survey and feedback request to help improve our services
TRANSFER OF YOUR INFORMATION OUTSIDE EEA
We do not transfer your data outside of the EEA
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
require the erasure of personal information concerning you in certain situations
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
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal information
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 e-mail, call or write to us at:
Casserly Property Management
10 James Nasmyth Way
Telephone: 0161 787 6197
let us have enough information to identify you e.g. full name, address and property 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.
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 23/05/2018 and last updated on 23/05/2018. We may change this privacy notice from time to time, and when we do we will inform you.