Privacy Policy

Aspen Property Management Ltd 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, Aspen Property Management Ltd, is the Data Controller, Angus Watson is the person responsible for data protection and can be contacted at 2a Victoria Terrace, Cullompton, Devon, EX15 1DQ or angus@aspenproperty.co.uk .

The General Data Protection Regulations are to safeguard your personally identifiable information or personal data. This privacy notice will be regularly reviewed and updated.

Information held

The personal data we process may include the information in column A of the appendix below and may also include other sensitive data concerning health, if relevant to your application. Where the provision of data is a 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 provide you with our service.

To ensure that we provide you with the best service possible we will need to collect and retain certain personal data. The data may be collected and processed by those listed in columns B and F. How we source the data is identified in column C. We may source data from 3rd parties or via third parties e.g. Land Registry or local authority licensing schemes.

Lawful basis of processing

Your personal data will be used for the activities in column D. There are 6 lawful basis of processing your data including consent, a legitimate interest, contract fulfilment, a legal obligation and a vital interest. For each usage of the date the lawful basis of the processing of your data will be identified in column E. A legitimate interest is when we have a business or commercial reason to process your personal data which needs to be balanced with your interests i.e. what is right and best for you.

Where we state that we have a legitimate interest, the fact that we have a legitimate interest and what that legitimate interest is, will be stated in column E, e.g. to keep in touch with you during the tenancy; to contact you when we need your consent.

Online identifiers, IP addresses and cookie identifiers

Where you visit our website we may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns.

We may obtain information by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:

  • To estimate our audience size and usage pattern.

  • To store information about your preferences, and so allow us to customise our site according to your individual interests.
  • To speed up your searches.
  • To recognise you when you return to our site.

    You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site. You can find more information about cookies at www.allaboutcookies.org

    This policy only applies to our site. If you leave our site via a link or otherwise, you will be subject to the privacy policy of that website provider. We have no control over that privacy policy or the terms of the website and you should check their privacy policy before continuing to access the site.

    Recipients of personal data

    It will be necessary for us to process or share all or some of your personal data with a range of individuals, businesses and organisations and these may include those listed in column F.

    Where is the data stored?

    Your personal data is stored in the way described in column G and the 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.

    Retention period and criteria used to determine the retention period

    We will retain some elements of your personal data for up to the time defined in column H after we cease to be your agent. What information can be anonymized will be when no longer required for either contractual fulfilment or a legitimate interest. If the lawful basis for processing your data was consent then you may withdraw consent at any time.

    Your rights

    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.

    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.

    You have a right to erasure of your data when consent is our basis of processing (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 justifying our retaining the data (for example a legal requirement or the defence of a legal claim).

    You have some rights to ask us to restrict processing i.e. to block or supress processing where, for example, the data may be incorrect and whilst the accuracy is verified. We are permitted to store the data.

    Your right to object

    You do have a right to object to further processing of your personal data. We may be required to stop processing unless there is some other legitimate basis of processing such as a legitimate interest or a requirement for the exercise or defence of a legal claim.

    Withdrawal of consent

    Where the lawful basis for processing is your consent, you may withdraw consent at any time by writing to, Angus Watson, Aspen Property Management Ltd at 2a Victoria Terrace, Cullompton, Devon, EX15 1DQ or emailing angus@aspenproperty.co.uk .

    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.

  •  Appendix
Data controller
A B C D E F G H
Information held Who is collecting it How is it collected Why is it collected Lawful basis for processing Who will it be shared with How stored When will it be deleted
Tenant name Staff In office, over the phone, email, self-registration, tenant application form To use on contract Contract fulfillment Landlord, staff, local authority & utilities, contractors, Paper / electronic 6 years after tenant leaves
Add to property management software Contract fulfillment Staff, Contractors, Software provider Software During tenancy & 6 years beyond
Referencing Contract fulfillment Credit check Co., Employer, current landlord, referencing co. paper / electronic During tenancy & 6 years beyond
To be able to contact tenant e.g. property management Contract fulfillment Contractors, staff, Software system 6 years after tenant leaves
To use on prescribed information Legal oblgiation Staff, Deposit scheme, relevant person Paper / electronic 6 Years after tenant leaves
To offer extra services - insurance Consent staff, 3rd party Paper / electronic Within a month of the end of tenancy
If legal action is needed Legal work Solicitor, Court Services Paper / electronic 6 years after tenant leaves
Services Contract fulfillment Council Tax & utility providers Paper / electronic 6 years after tenant leaves
Tenant contact details Staff In office, over the phone, email, self-registration, tenant application form To use on contract Contract fulfillment Landlord, staff, local authority & utilities, contractors, Paper / electronic 6 years after tenant leaves
Add to management software Contract fulfillment Staff, Contractors, Software provider Software 6 years after tenant leaves
Referencing Contract fulfillment Staff Credit check Co., Employesr, current landlord, referencing co. paper / electronic During tenancy & 6 years beyond
To be able to contact tenant e.g. property management Contract fulfillment Contractors, staff, Software system 6 years after tenant leaves
To use in prescribed information Legal oblgiation Staff, Deposit scheme, relevant person Paper / electronic 6 years after tenant leaves
To offer extra services Consent staff, 3rd party Paper / electronic Within a month of the end of tenancy
If Legal action is needed, for example possession claim Legal Work Solicitors, Court Services Paper / electronic 6 years after tenant leaves
Notify utilities & council tax Contract fulfillment Council Tax & utility providers, landlord Paper / electronic 6 years after tenant leaves
Tenant Employer information Staff Tenant application form Referencing & assessment Contract fulfillment Staff, Credit check Co., landlord, referencing co. Paper / electronic 6 years after tenant leaves
Tenant's current landlord information Staff Tenant application form Referencing & assessment Contract fulfillment Staff, Credit check Co., landlord, referencing co. Paper / electronic 6 years after tenant leaves
Tenant Next of Kin details Staff Tenant application form Contact in case of emergency alternative correspondence address Legitimate interest Staff, Public bodies Paper / electronic 6 years after tenant leaves
Tenant bank details Staff Tenant application form Setting up standing orders Contract fulfillment Staff, landlord Paper / electronic 6 years after tenant leaves
Tenant's Children details Staff Tenant application form To identify permitted occupiers to include on tenancy agreement Contract fulfillment Staff, landlord Paper / electronic 6 years after tenant leaves
Credit score results, history Credit Check Co. Email or online To assess suitability Contract fulfillment Staff, landlord Paper / electronic 6 years after tenant leaves
Other returned references Credit Check Co, agent Email, online, hardcopy To assess suitability Contract fulfillment Staff, landlord Paper / electronic 6 years after tenant leaves
Tenant passport or ID documents Staff Photocopy of original, face to face To comply with right to rent checks Legal obligation, contract fulfillment Staff, landlord, Home Office Paper / electronic 6 years after tenant leaves
Landlord name To use on contract Contract fulfillment
To be able to contact landlord Contract fulfillment
To use no deposit prescribed information Legal obligation
To offer extra services Consent
If legal action is needed Legal work
Landlord contact details To use on contract Contract fulfillment
To be able to contact landlord Contract fulfillment
To use in prescribed information Legal oblgiation
To offer extra services Consent
To provide details to contractor Contract fulfillment
To chase rent arrears Contract fulfillment
If Legal action is needed, for example possession claim Legal Work
Applicant Name Face to face, email, tel To add to database Consent Staff, landlords, back up / cloud / software provider
To be able to contact app. Consent Staff, landlords
To give to landlord Consent Landlord
To create a tenant record Consent Staff, back up / cloud / software provider
To create application process Consent Staff, back up / cloud provider
To create Tenancy Agreement Consent Staff, back up / cloud provider
To carry out Right to Rent checks Legal obligation Staff / landlord
Applicant contact details Face to face, email, tel To add to database Consent Staff, landlords, back up / cloud provider
To be able to contact app. Consent Staff, landlords
To give to or discuss with landlord Consent Landlord
To send marketing details to Consent Staff, 3rd party
To create a tenant record Consent staff, back up / cloud provider
To create application process Consent Staff,
To create Tenancy Agreement Consent Staff & landlord
To carry out Right to Rent checks Legal obligation Staff & landlord
Referencing
Referees privacy
Contractor Name To add to database
To be able to contact contactor
To give details to tenant
Contractor contact details To add to database
To contact contractor
To send worksheets
To process payments
To create contract
To give details to tenant
Referencing
Referees privacy

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