May 2018
Baxter Lambert Limited
Privacy Notice
Under the General Data Protection Regulation (GDPR), Baxter Lambert Limited is classified as Data Controllers. This means that we decide how your personal data is processed.
This privacy notice sets out how we will process personal data we collect from or about you, or which you provide to us. Please read this notice to understand why data is being collected and what we do with that data.
For the purpose of the Data Protection Act 1998 and General Data Protection Regulation EU 2016/679, the data controller is Baxter Lambert Ltd a company registered in England under company number 3119388, whose registered address 120 High Street, London SE20 7EZ.
Your personal data – what is it?
Baxter Lambert Limited as a firm deal with many aspects of property related matters which include flat and house sales and lettings, rent collection management, service charge collection management, professional services, insurance and generally anything connected to property related services. During providing these services certain types of personal data may be required and include any of the following:
- Full name and contact details (including your contact number, email and postal address)
- Information relating to your identity where we are required by law to collect this to comply with the Money Laundering Regulations 2017 and the Immigration Act
- Information on your close connections where we are required to conduct conflicts of interests under regulatory obligations
- Your banking details where required such as when you are letting a property or in order to pay rental payments. To make return payments when necessary or when obtaining references.
- Information on any access requirements you have necessary to enable us to find suitable properties for you, which may consist of special category personal data comprising details of any disability or other health information about you.
- Details about your areas of interest where we wish to send you marketing information about similar products and services.
- Sub tenant contact details.
- Emergency contact details of other parties.
- Vehicle registration information.
- CCTV recordings on particular premises.
- Your communications with us, including a record of the email or telephone correspondence created when you contact us as part of a product or service query
- Where we need to collect personal data by law (for example to meet our obligations to prevent fraud and money laundering) or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
Where we collect personal information?
- Direct from you, your personal representative or information you have made public.
- From other persons or organisations, including insurers or solicitors.
How do we use your personal data?
The legal grounds under data protection legislation for processing your personal data are as follows:
- We use your personal data for the purpose of providing our service as a sales, lettings and property management firm.
- It is necessary for the performance of a contract to which you are a party, or to take steps prior to entering into a contract with you, for us to provide you with our products and services.
- Where we need to comply with a legal obligation; or in rare circumstances
- Where we need to protect your interests (or someone else's interests); and/or
- Where it is needed in the public interest or for official purposes
What are we going to do with your information?
We will hold and use personal information about you in the following ways:
- To fulfil our obligations to you when providing you with our property services.
- To share your information with others where necessary to fulfil our property services for you or where acting as agent for a third party on your behalf.
- To comply with our statutory and regulatory obligations, including [verifying your identity, prevention of fraud and money laundering and to assess your credit worthiness
- Communicate with you during the course of providing our services, for example with your enquiries and requests.
- To notify you about changes to our service and other property related services this firm provides.
How long we keep your data for?
- We will retain your personal data for different periods depending on the service you have chosen to use us for.
- We will only use your data to fulfil, which may be a longer period than that for which we need to hold your data to provide those services, i.e. where we are under regulatory or statutory duties to hold your data for a longer period.
Who your information will be shared with
- Property solicitors where appropriate and those of the other party to your transaction.
- To utility companies for the purpose of notifying a change of occupier.
- Insurers in order to deal with claims.
- Contractors in order to undertake urgent repairs.
- Solicitors and debt collection agencies to obtain outstanding sums.
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If our company or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- We will not share your information with third parties for marketing purposes without first obtaining your prior consent.
Your rights
How you can access and update your information
You have a right to request a copy of the personal information we hold about you, known as a data subject access request. You also have the right to request that information we hold about you which may be incorrect, or which has been changed since you first told us, is updated or removed. These requests are free of charge and can be sent to the Data Protection Officer, Mr D Lambert, Baxter Lambert, and 120 High Street London SE20 7EZ
How you can request erasure of your data
You can ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where you have withdrawn consent for us to process it (as explained below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
How you can withdraw your consent
You have the right at any time to withdraw any consent you have given us to process your personal data. Please note if you withdraw your consent it will not affect the lawfulness of any processing of your personal data we have carried out before you withdrew your consent. Should you wish to do so you can change your consent preferences at any Data Protection Officer, Mr D Lambert, Baxter Lambert, 120 High Street London SE20 7EZ.
How you can restrict or object to us using your data
You can ask us to suspend the way in which we are using your information in certain scenarios, or object to our processing your data where we are relying on a legitimate interest ground (or those of a third party) and you feel it impacts on your fundamental rights and freedoms, or where we are processing your personal data for direct marketing purposes. In some cases where you object, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Please note that if you want us to restrict or stop processing your data this may impact on our ability to provide our services. Depending on the extent of your request we may be unable to continue providing you with our service.
Any queries or concerns about the way in which your data is being used can be sent to Data Protection Officer, Mr D Lambert, Baxter Lambert, 120 High Street London SE20 7EZ.
Complaints about the use of your personal data
If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated by writing to Data Protection Officer, Mr D Lambert, Baxter Lambert, 120 High Street London SE20 7EZ
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the UK data protection regulator, the Information Commissioner’s Office. Further details can be found at www.ico.org.uk or 0303 123 1113.