GENERAL PRIVACY NOTICE

Synergy Property Services Ltd considers your personal information to be very important. A description of what personal data we process and for what purposes is set out in this Privacy Notice.  We will always take into account your interests and rights.  This Privacy Notice sets out your rights and our obligations to you.

Who are we?

This Privacy Notice is provided to you by Synergy Property Services Ltd (Synergy) which is the data controller for your data.

Your personal data – what is it?

“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address).  Identification can be directly using the data itself or by combining it with other information which helps to identify a living individual.  The processing of personal data is governed by legislation relating to personal data which applies in the United Kingdom including the General Data Protection Regulation (the “GDPR) and other legislation relating to personal data and rights such as the Human Rights Act.

Synergy will process some or all of the following where necessary to perform its tasks:

• Names and titles
• Contact details such as telephone numbers, addresses, and email addresses
• We may process information such as gender, age and dependants but only where there is a need for a responsible adult to be present when visiting your property
• We do not need and therefore do not process sensitive or other special categories of personal data e.g. as criminal convictions, racial or ethnic origin, mental and physical health, details of injuries, medication/treatment received, political beliefs, trade union affiliation, genetic data, biometric data, data concerning and sexual life or orientation.
• Where you pay for services using bank transfer, we will provide you with details of our bank account but do not need to have details of yours unless we need to make a payment to you.

Synergy will comply with data protection law. This says that the personal data we hold about you must be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept and destroyed securely including ensuring that appropriate technical and security measures are in place to protect your personal data to protect personal data from loss, misuse, unauthorised access and disclosure.

We use your personal data for some or all of the following purposes:

• To deliver services requested or contracted by an individual or organisation to enable the delivery of those services and appropriate communication
• including to understand your needs to provide the services that you request and to understand what we can do for you and inform you of other relevant services
• To confirm your identity
• To contact you by post, email or telephone
• To enable us to meet all legal and statutory obligations
• To maintain our own accounts and records
• To notify you of changes to our services and staff
• To send you communications which you have requested and that may be of interest to you.

What is the legal basis for processing your personal data?

Synergy is a business providing a range of property services to private individuals, public authorities and corporate businesses. Most personal data is processed for delivery of a service (contract) or compliance with a legal obligation (e.g. EPBD, accounts or taxation).

We may process personal data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract.

For all other purposes we will first obtain your consent to that use.

Sharing your personal data

This section provides information about the third parties with whom Synergy may share your personal data.  These third parties have an obligation to put in place appropriate security measures and will be responsible to you directly for the manner in which they process and protect your personal data. It is likely that we will need to share your data with some or all of the following (but only where necessary):

• Our agents, suppliers and sub-contractors when engaged in helping to deliver our services to you (when necessary).
• We do not share, lend or give your personal data to others for their own marketing purposes.

Other data controllers we work with:

We may need to share personal data we hold with other organisations so that they can carry out their responsibilities. If we and the other data controllers are processing your data jointly for the same purposes, then the Synergy and the other data controllers may be “joint data controllers” which mean we are all collectively responsible to you for your data. Where another data controller is processing your data for their own independent purposes then each of us will be independently responsible to you and if you have any questions, wish to exercise any of your rights (see below) or wish to raise a complaint, you should do so directly to the relevant data controller.

How long do we keep your personal data?

In general, we will endeavour to keep data only for as long as we need it.  This means that we will delete it when it is no longer needed. We keep records only as long as we are legally required to do so. For example:

• it is currently best practice to keep financial records including accounts and invoices for a minimum period of 8 years to support HMRC audits or provide tax information.
• We retain contracts for 6 years in case of a claims, and we will retain some personal data for this purpose as long as we believe it is necessary to be able to defend or pursue a claim.

Your rights and your personal data 

When exercising any of the rights with respect to your personal data listed below, in order to process your request, we may need to verify your identity for your security.  In such cases we will need you to respond with proof of your identity before you can exercise these rights. You have the following rights:

The right to access personal data we hold on you

• At any point you can contact us to request the personal data we hold on you as well as why we have that personal data, who has access to the personal data and where we obtained the personal data from. Once we have received your request we will respond within 20 days.
• There are no fees or charges for the first request but additional requests for the same personal data or requests which are manifestly unfounded or excessive may be subject to an administrative fee.

The right to correct and update the personal data we hold on you

• If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.

The right to have your personal data erased

• If you feel that we should no longer be using your personal data or that we are unlawfully using your personal data, you can request that we erase the personal data we hold.
• When we receive your request we will confirm whether the personal data has been deleted or the reason why it cannot be deleted (for example because we need it for to comply with a legal obligation).

The right to object to processing of your personal data or to restrict it to certain purposes only

• You have the right to request that we stop processing your personal data or ask us to restrict processing. Upon receiving the request we will contact you and let you know if we are able to comply or if we have a legal obligation to continue to process your data.

The right to data portability

• You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.

The right to withdraw your consent to the processing at any time for any processing of data to which consent was obtained

• If your consent was needed to process the data in the first place, you can withdraw your consent easily by telephone, email, or by post (see Contact Details below).

The right to lodge a complaint with the Information Commissioner’s Office.

• You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Transfer of Data Abroad

Synergy does not transfer any data to countries or territories outside the European Economic Area (“EEA”).

Our website however is accessible from overseas so on occasion some personal data (for example in a newsletter) may be accessed from overseas. We will not publish personal data on the website without prior written consent of the individual concerned.

Further processing

If we wish to use your personal data for a new purpose, different to that for which it was originally obtained, then we will explain to you this new use, setting out the relevant purposes and processing conditions.  Where and whenever necessary, we will seek your prior consent to the new processing.

Changes to this notice

We keep this Privacy Notice under regular review and it was last updated in May 2018.

Contact Details

Please contact us if you have any questions about this Privacy Notice or the personal data we hold about you or to exercise all relevant rights, queries or complaints at:

The Data Controller, Synergy Property Services Ltd, Synergy House, 29, Church Lees, Great Linford, Milton Keynes   MK14 5EB

Tel: 01908 664040               Email:    [email protected]

You can contact the Information Commissioners Office at:

The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire   SK9 5AF.

Tel: 0303 123 1113               Email:    https://ico.org.uk/global/contact-us/email/