Purpose of this Privacy Policy
We are committed to protecting your personal information and to being transparent about the information we hold about you.
The purpose of this policy is to give you a clear explanation about how we collect and process your personal information through your use of our website, including any data you may provide through this website. It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using your personal information. This privacy policy supplements our other policies and is not intended to override them.
We will use the information that we collect about you in accordance with:
This policy explains:
If you have any questions, please contact the Data Controller at The Royal College of Occupational Therapists (RCOT) using the contact details at the end of this policy.
1. WHO WE ARE
Phoenix House is an office building with entrances on 106–114 Borough High Street London SE1 1LB. The local authority is Southwark Council. The freehold is owned by The Royal College of Occupational Therapists.
The property manager is Charlie Merritt (Knowlemore Limited).
2. INFORMATION WE MAY COLLECT ABOUT YOU
Personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed, i.e. anonymous data. We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal information
Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information 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 an online property portal). 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.
Users under 18
We understand that people aged under 18 may use this website. This policy applies equally to users under the age of 18.
3. HOW WE COLLECT YOUR DATA
We collect different information about you in a number of ways:
Information you give us
When you create an account on our website, setup keyholding rules or send any support requests, we will store the personal information you give to us such as your name, email address, postal address and telephone number. We will also keep a record of your messages.
Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns if you consent to us doing so. We collect this personal data by using cookies and other similar technologies. To view the Cookie policy please click here.
4. HOW WE MAY USE YOUR INFORMATION
We will only use your personal information when the law allows us to do so. Most commonly, we will use your personal information in the following circumstances:
Where we have your explicit consent before using your personal information in that specific situation. You have the right to withdraw consent at any time by contacting us. You will find the relevant contact details at the end of this policy.
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Purposes for which we will use your personal information
We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register you as a new user |
(a) Identity |
(a) Consent (b) Performance of a contract with you |
|
To provide the service and deliver your requests including: (a) Manage keyholding & deliveries (b) Responding to support requests (c) Sending important building announcements |
(a) Identity |
(a) Performance of a contract with you (b) Necessary for our legitimate interests |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (for running our business, to analyse and improve our services) |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or restructuring exercise) (b) Necessary to comply with a legal obligation |
|
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our website, products/services, marketing and communications with you, customer relationships and experiences |
(a) Technical |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity |
Consent |
Service related communications
A key aspect of the online property portal is to keep users updated of certain information by email and/or SMS (such as keyholding and delivery alerts and building notifications). The legal basis for such communications may depend on the precise circumstances, but will be the user’s consent, the performance of a contract or our legitimate interests (being the delivery of the service to the users).
For this reason, on registering for an account you will be automatically opted in to receive all available alerts from the online service.
Marketing communications
If you provide your consent, we may communicate with you about our own services or third party services. To do this, we use data that we have stored about you, such as any contact preferences you may have told us about. The legal basis for such communications will be our legitimate interests, being to expand the scope of products and services that will be available for the benefit of users.
Opting out of communications
We will give you an opportunity to opt out of receiving electronic communications in every email that we send you. Alternatively, you can use the contact details at the end of this policy or update your contact preferences in your online account with us.
5. DISCLOSURE OF YOUR DETAILS TO THIRD PARTIES
There are certain circumstances under which we may disclose your personal information to third parties. These are as follows:
We do not sell personal details to third parties for any purpose.
6. SECURITY OF YOUR PERSONAL INFORMATION
Security of your personal information
We have put in place appropriate safeguards (both in terms of our procedures and the technology we use) to keep your personal information as secure as possible. We will ensure that any third parties we use for processing your personal information do the same and that they will only process your personal information on our instructions. The third parties will also be subject to a duty of confidentiality.
We will not transfer, process or store your data anywhere that is outside of the European Economic Area, unless we have a contractual agreement in place that is of an equivalent standard to GDPR.
7. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data (and whether we can achieve those purposes through other means) and the applicable legal requirements.
In general, we will only retain your personal data during the time that you have access to the online property portal system (e.g. for as long as you are a resident in the block). However certain data may continue to be stored in back-ups which are retained for security or record-keeping purposes (e.g. historic records of key access logs).
8. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal information, as follows:
a) Request access to your personal information
You have a right to request a copy of the personal information that we hold about you. Please use the contact details at the end of this policy if you would like to exercise this right or any of the rights listed below. If you are a European citizen and consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK's supervisory authority, i.e. the Information Commissioner's Office.
b) Request correction of your personal information
You have the right to request that we correct the personal information we hold about you, although we may need to verify the accuracy of the new information you provide to us.
c) Request erasure of your personal information
You have the right to request that we delete or remove personal information where there is no good reason for us continuing to process it. Please note that we may not always be able to comply with your request for erasure if there are specific legal reasons (which will be notified to you at the time of your request).
d) Object to processing of your personal information
You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
e) Request restriction of processing your personal information
You have the right to request that we suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
f) Request transfer of your personal information
You have the right to request that the personal information we hold about you is transferred to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
g) Right to withdraw consent
In circumstances where we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Please also note the following:
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9. NOTIFICATION OF CHANGES TO OUR PRIVACY POLICY
This privacy policy may change from time to time. We will always communicate any changes to our residents where we have accurate contact details and where they would expect to receive communications from the building management staff. Please review this document periodically in order to keep up to date with changes in our privacy policy.
10. CONTACT DETAILS AND FURTHER INFORMATION
Please get in touch with us if you have any questions about any aspect of this privacy policy, and in particular, if you would like to object to any processing of your personal information that we carry out for our legitimate organisational interests.
Please also contact us if you have any questions about the information we hold about you or to change your contact preferences with us:
Email us: [email protected]
Write to us:
Data Controller
Royal College of Occupational Therapists
Phoenix House, 106–114 Borough High Street
London, SE1 1LB