LEMC PRIVACY INFORMATION NOTICE
This privacy information notice tells you
- who we are
- what data we hold on you
- the legal bases for holding your data that we rely on
- how we collect your data
- what we use your data for
- how we store your data
- when we might share your data
- when we delete your data and
- your individual rights.
Who we are
We are Lacuna Estate Management Company or LEMC, a company set up to manage and administer the freehold and leasehold properties within an area known as Lacuna Estate on Kings Hill. Each of our 180 homeowners own one share in our company. Pauline Marsh and Jenny Vanbergen are both data controllers and data processors for LEMC, and we can be contacted at email@example.com or by writing to us at Suite 167, 5 Liberty Square, Kings Hill, West Malling, ME19 4AU.
What data we hold on you
We hold details of your name, address, and service charge payment history. If you have emailed us, we hold your email address, and if you have ever asked us to call you, we hold your telephone number. We hold copies of your deeds of covenant and your transfer documents that you signed at the time of purchase. We do not hold your bank account details, as we only collect service charge monies by standing order (that you set up with your bank) or by cheque (which you send us). We do not gather any information from your use of our website.
Explaining the legal bases we rely on
The General Data Protection Regulations (GDPR) require us to specify our legal basis for collecting your data. Our legal basis for collecting and holding your data arises as a result of our mutual contractual obligation. You are required to pay service charges to us, and we are required to provide services to you, according to the transfer document and deed of covenant which you signed at the time of purchase.
We may also have a legal obligation to process your information (i.e. pass it on) to law enforcement agencies if you are involved in fraud or any other criminal activity.
How we collect your data
We are given your data by your conveyancing solicitors at the time of purchase. You may also have provided your data to us via our online portal on our website, or by emailing us or giving us your telephone number.
What we use your data for
We use your data to send service charge demands to you, carry out services as required of us in the covenants, to carry out repairs & maintenance as required and to respond to any complaints and queries that we may receive. We do not use your data for any other purpose.
How we store your data
During the latter half of 2018, we are proposing to move our data from Microsoft Office to a cloud based property software system to ensure continued complete security. Email addresses and the content of emails will continue to be stored in folders on the aol.com server. We do not keep hard copies of your data. We do keep hard copies of all our invoices (expenses payable) and bank statements. Bank statements are shredded after the accounts to which they pertain have been certified by our Chartered Accountant, as we can refer to them if need be via the Santander online banking system.
When we might share your data
We shall never sell your data. We never share it with anyone, except:
- law enforcement agencies if required (under the GDPR legal basis of legal obligation) and/or
- our insurance company and broker who insures your building (under the GDPR legal basis of contract) and/or
- Companies House shareholder register (under the GDPR legal basis of legal obligation) and/or
- debt collection agencies (under the GDPR legal basis of contract) and/or
- our trusted contractors who might be carrying out works on your property (under the GDPR legal basis of contract) and
- our Chartered Accountant (under the GDPR legal basis of contract) who certifies our budgets and balance sheets.
When we delete your data
We erase your data from our current data base when you sell your property, assuming your service charges have been settled in full. We are, however, required to keep our Estate records for at least six years, and so your data will remain stored in our historical online files until that time has lapsed. Bank statements are shredded after two years once the certified accounts are signed and published.
Your individual rights
- You have the right to request access to the personal data we hold on you; this will often be only your name and address plus, in some cases, your email address. We shall not normally charge a fee for responding to such requests.
- You have the right to be informed of the way we collect and process your data. We inform you in this privacy information notice which is published on our website. Companies are permitted to publish privacy information notices on a website so long as they draw attention to it. We propose to draw our residents' attention to our Privacy Information Notice's publication on our website via our bi-annual newsletter which is hand delivered twice a year to all the properties on Lacuna Estate, Kings Hill.
- You have the right to ask us to correct your data whenever you find it to be incorrect, out of date or incomplete.
- If you feel your data is not being handled correctly, or you are unhappy with our response to any request you have made concerning the handling of your data, please advise us giving your reasons. You also have the right to lodge a complaint with the Information Commissioner's office by calling 0303 123 1113