Privacy Policy

Jim Townsend & Company

How we use your personal information

The new EU General Data Protection Regulation (GDPR) expands the rights of individuals to

control how their personal data is collected and processed.

In order to comply with the law, we need to collect and store personal information, including

identity proofs in order to fulfil our obligations under right to rent legislation.

This information can be stored electronically and/or in a printed format.

There are also occasions where we need to pass on your contact details in order to fulfil our

contractual obligations to you; this could be to another employee of Jim Townsend & Company or to a

contractor in order for them to carry out repairs or maintenance on the property.

Where our basis for collecting, storing or processing your personal information is to meet

legal obligations or to fulfil our contractual obligations, we do not require your explicit

consent to do this.

Where your information is passed to another employee or contractor, they may not use this

information for any purpose other than the reason it was given to them and we require our

contractors to sign to agree to this.

Under the new legislation, you also have the right to be ‘forgotten’, as such we will remove

your contact information from our systems unless we are legally obliged not to do so (such as

information stored in tenancy agreements or invoices etc).

In addition to this:

 We will also remove your information automatically from our systems 12

months after your tenancy has ended.

 Any emails sent to, or received from, you will also be deleted no later than 12

months after your tenancy has ended, including any printed copies which may

have been made.

 Legal documents containing your personal information will not be deleted

until 6 months after your tenancy ends.

 Invoices containing your personal information will not be deleted until 6 years

after their creation date.

This statement is a summary of our obligations and commitments. Our full privacy policy will shortly

be available to view on our website, or a copy is available on request.

Privacy Policy

Definitions:

Data: Collectively, all information that you submit to Jim Townsend & Company, its directors or

employees; including anything communicated verbally; in writing; electronically or by any

other means. This definition incorporates, where applicable, the definitions provided in Data

Protection Laws.

Data Protection Laws: Any applicable law relating to the processing of personal data

including, but not limited to the Directive 96/46/EC (Data Protection Directive), or the

GDPR, and any national implementing laws, regulations and secondary legislation, for as

long as the GDPR is effective in the UK.

GDPR: The General Data Protection Regulation (EU) 2016/679

We, Our or Us: Jim Townsend & Company

You or your: The tenant(s) or applicant(s)

Data Controller: The person(s) within the company who is responsible for determining the

purposes and means for processing personal data. This may be an individual, a department or

the company as a whole.

Processing: anything that is done to, or with, personal data; this can include simply

collecting, storing or deleting those data and refers to both manual or electronic means.

Data Processor: Data processors are responsible for processing personal data on behalf of

the data controller.

Section 1: Statement

i)Jim Townsend & Company is committed to protecting and processing your personal data in

accordance with the General Data Protection Regulations and the Data Protection Act 2018

(the legislation). For the purpose of the legislation and your personal data, the Data Controller

is Jim Townsend & Company. The named person responsible for Data Protection is Andy Townsend.

ii)The General Data Protection Regulations have been introduced to safeguard your

personally identifiable information or personal data. This privacy notice will be regularly

reviewed and updated.

Section 2: Information we collect

i)The personal data we process may include name, contact information, identification

documents (such as passport, ID card, driving licence etc), employment and salary

information, and information relating to benefit entitlement. Where the provision of data is

statutory, a contractual requirement or a requirement necessary to enter into a contract, a

refusal to provide the data may mean that we are unable to consider you as a tenant.

ii)To ensure that we provide you with the best service possible we will need to collect and

retain certain personal data. The data will be collected by the data controller and can be

sourced directly from you (verbally, in writing, electronically or by any other means) or from

a third party such as an employer or previous landlord.

Section 3: Lawful Basis for Processing

i) Under data protection laws, we must have a legal basis for processing your data. Your

data may be used for the following purposes: To be able to contact you; To use in a tenancy

agreement; To undertake referencing; To comply with Right to Rent legislation; To give to

contractors; To give to utility companies; To give to the Deposit Protection Service; To

pursue rent arrears; If legal action is required.

ii) Our lawful basis for processing your data falls under either ‘Legal Obligation’,

‘Contractual Fulfilment’ or ‘Legitimate Interest’. Further information regarding lawful basis

can be found in Appendix 1 of this policy.

iii) As described in paragraph i) above, it is often necessary for us to process or share some of

your personal data with a range of individuals, businesses and organisations. When this

happens the recipient of the data becomes a Data Processor and is subject to the same Data

Protection Laws.

iv) Any contractor who attends the property to carry out repairs or maintenance will be

signed up to our own Contractor GDPR compliance statement. A copy of this can be found

in Appendix 2 of this policy.

v) Where any processing of data falls outside of the bases mentioned above and in Appendix1,

we will need to obtain your consent before processing.

Section 4: Storing your Data

i) Your personal data can be stored manually and/or electronically.

ii) Where data is stored electronically, it is password protected on devices running anti-virus

software.

iii) Data is always stored within the European Union or outside of the European Union but

with an organisation operating under the General Data Protection Regulations.

iv) Where we have a legal requirement to retain some or all of your data after you cease to be

a tenant, this will be done in accordance with Data Protection Laws and for the time specified

in Appendix 1 of this policy.

v) Where you give us consent to process your data; you may withdraw this consent at any

time.

Section 5: Your Rights

i) You have a right of access to check your personal data to verify the lawful basis of

processing. We are obliged to respond to an access request within 30 days and may not

charge a fee unless the request is unfounded, excessive or repetitive. If a fee is charged it is to

be a reasonable fee based upon the administrative cost of providing the information.

ii) You have a right to rectification if the data we hold is either inaccurate or incomplete. If

your data has been disclosed to third parties then we must inform them of the rectification,

where possible.

iii) Where our basis for processing your data is consent, you have a right to require erasure of

your data (the right to be forgotten). You may request that your personal data be erased, for

example, where there is no compelling reason for its continued processing or where you

withdraw consent. We will comply with your request unless we have another basis of

processing which justifies our retaining the data (for example a legal requirement or the

defence of a legal claim).

Any Concerns:

If you have any concerns regarding the way in which your data is processed, or require any

further information, you can contact us by email jimtownsendco@btinternet.com or in writing:

Jim Townsend & Company, 7 Castle Crescent, Reading RG1 6AQ

How to lodge a complaint with the supervisory authority

The supervisory authority responsible for data protection is the Information Commissioners

Office (ICO) to whom concerns may be reported by phone on 0303 123 1113 or +44 1625

545 745 if calling from outside the UK, by email using the form on the website ico.org.uk or

the livechat function.

Jim Townsend & Company are Registered with the Information Commissioners Office;

Registration Number ZA410020

Appendix 1

* - This is the period of time the data will be retained from the end of the tenancy. Where

the information is obtained for a prospective tenant who does not take up a tenancy, the

information will be retained for 6 months, unless consent is given to hold it for longer.

** - This information can be shared or otherwise processed within Jim Townsend & Company by

directors or direct employees for the purposes of maintaining accurate records. It may not be

shared outside of Jim Townsend & Company without the explicit consent of the individual. (Except

where there is an overriding legal obligation to do so).

Appendix 2

This document is signed by any contractor instructed to carry out repairs or maintenance at

the property prior to any data being shared with them.

The completed and signed copies of these are available to view upon request.

CONTRACTOR DATA COMPLIANCE

Under the legislation of the General Data Protection Regulation (EU) (2016/679), (GDPR),

when we pass the personal information of a tenant to a contractor, the contractor becomes a

‘processor’ of that information.

We are required to ensure that the information we pass to you must not be used for any

purpose other than to allow you to complete the work you have been instructed to undertake.

As such, could you please read the statement below. In signing this form, you acknowledge

that you agree with and will adhere to its contents.

I acknowledge that under GDPR legislation, when I am passed personal information, I become a ‘processor’ of that information.

I agree that I will use the information provided for the sole purpose of enabling me to

undertake the work instructed by Jim Townsend & Company.

I will not pass any personal information to any third party without the explicit

permission of both the tenant and an employee or director of Jim Townsend & Company.

Name:

Company:

Signed:

Dated: