Privacy Policy
Overview
We respect your privacy and are committed to protecting your personal data. We are obliged to process your personal data in a lawful, fair, and transparent way.
This Policy explains what data we collect as well as how and why we use your personal data when you visit this website (regardless of where you visit it from), use our Customer Portal operated by Engage, or get in touch with us by post, email, and telephone. It also informs you about your privacy rights and how the law protects you.
It is important that you read this Policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data, and any that are referred to in any website accessed through this website. This Policy supplements other notices and privacy policies and is not intended to override them.
We are a high-growth, dynamic business. We will continue to assess this Policy against new technologies and services and business practices as well as our clients’ needs, and make changes to this Policy from time to time as we require. If we make any material changes to this Policy, we will make changes here and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Policy changes).
This website has not been designed to be used by children or anyone under the age of 18, and they should not visit this website (or any embedded website), nor provide any personal data.
Index:
1. Who are “we”?
2. The data we collect from you
3. If you fail to provide personal data
4. How your personal data is collected
5. How we use your personal data
6. Change of purpose
7. How and where we disclose your personal data
8. How we secure your personal data
9. Keeping your personal data
10. Your legal rights
11. Updating your personal data
12. Information Provided to Us About You by Third Parties
13. What to do if you are not happy
1. Who are “We”?
In this Policy, whenever you see the words ‘Anthem’, ‘we’, ‘us’, or ‘our’, it refers to Anthem Management Limited, unless otherwise expressed. Anthem Management Limited is part of the Cortland group of companies.
There will be some instances where we act as the data controller in relation to your personal data, for example, if you apply for a job with us. At other times, we will be the processor of your personal data, acting on behalf of a client, who is the data controller. From time to time, when performing obligations for our clients and acting as a processor, we may share your personal data with a sub-processor. More information on how we use your personal data is set out below.
We have appointed a Data Protection Administrator who is responsible for overseeing matters arising in relation to this Policy. If you have any matters regarding this Policy, including any requests to exercise your legal rights, please contact the Data Protection Administrator using the details set out below.
Email: data.protection.admin@cortland.com
Post: Data Protection Administrator, Cortland Development UK Limited, Leaf A, 9th Floor, Tower 42, 25 Old Broad Street, London, EC2N 1HQ
Telephone: 020 7016 0010
2. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include any data where the identity of the individual has been removed (known an anonymous data).
We collect, use, store, and transfer different kinds of personal data about you and we have grouped them together as follows:
2.1. Identity Data includes first name, last name, maiden name, username or similar identifier, marital status, date of birth, and gender.
2.2. Contact Data includes (personal and business) address, telephone numbers, and email addresses.
2.3. Rental Data includes your occupation, salary information, financial details, your budget, and other information necessary for us to assist you in a property search or renting one of our properties. When we conduct our Right to Rent checks, we will ask for documentation (such as a passport), to prove you have a right to rent in the UK.
2.4. Financial Data includes service charge balance, bank account and payment card details.
2.5. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2.6. Career Data includes a copy of your CV, career history information, employment references, and proof of ID such as your passport.
2.7. Profile Data includes your username and password, your interests, preferences, feedback, and survey responses.
2.8. Technical and Usage Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, other technology on the devices you use to access this website, and information about how you use our website and services.
Apart from the exception referred to below, 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). We also do not collect any information about criminal convictions and offences.
We may collect special category personal data when enquiring as to whether you have any health issues that affects your housing needs.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
3. If You Fail to Provide Personal Data
Where we need to collect personal data by law, 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 agreement or arrangement we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
4. How Your Personal Data is Collected
This data is collected by us in a number of ways. For example, it is collected when you complete the “Contact Us” form or the “Careers” form on this website. It could also be collected via post, email, telephone communication or through one of our property portals. We may also collect data from third party websites (for example, Rightmove), and social media sites (for example, when you “like” a post on social media platforms). In addition, we record some calls made to us for training, and quality and monitoring purposes.
When you visit our offices or attend events that we sponsor or organise, we may collect contact information from you. We may also collect visual information about you as a result of security measures we use in our facilities.
We may collect the data directly from you or in some cases it may be provided by someone authorised by you.
Technical data may be collected automatically as you interact with our website for example via the use of cookies and similar technologies. Please see our Cookie Policy for more information.
5. How We Use Your Personal Data
We are committed to using your personal information in a lawful, fair, and transparent way in order to deliver our services and run our business. We only use your personal information for a legal and legitimate interest, such as:
Managing our relationships with landlords and leaseholders
We use and process your personal information when we communicate with landlords and leaseholders (or their representatives), as part of our services. We may also process financial data in order to issue service charge invoices and to administer payments. We may need to pass your personal information on to third party contractors who we have engaged to carry out maintenance at a property. Please see Keeping your personal data below for how long we keep your personal data for.
Company Secretarial
We may process your personal data when we provide company secretarial services such as are minute taking, updating Companies House, and managing the appointments and resignation of directors.
Assisting with a property search
We will process your personal information when you get in touch with us to assist you with a property search. This may include acknowledging your interest in our properties, informing you of upcoming property availability and offers, and scheduling viewings with you. If you provide us with any special category data relevant to your housing needs, for example, in relation to any wheelchair access requirements, we use this to ensure that the housing we suggest is appropriate.
Referral to a referencing agency
If you apply to live in one of our properties that we manage, we will provide your personal information to a third-party referencing agency.
Administering your tenancy
When you become a resident at one of the properties that we manage, we will use and process your personal information in order to provide and deliver our services to you. For example, we will provide you with updates regarding the property, administering payments from you, and communicate ancillary matters such as events we may be holding and safety or service updates.
Answering enquiries
If you contact us with a comment, enquiry (for example, via one of our online forms), or if you want to speak to us, we use your personal information in order to respond to you.
Marketing and feedback
We may from time to time contact you with marketing communications such as to tell you about other services we offer which we think may interest you, or to seek your views and feedback on the services we provide.
To keep you informed about our latest news, communities, and events, we may send texts, emails, and marketing communications. We may also send out satisfaction surveys from time to time.
We comply with applicable laws when using your personal information for this purpose and, where applicable, relies on your express consent. If you opt–in for any of our email lists, newsletters or other promotional offerings and later change your mind, you may unsubscribe by following the instructions contained in each email we send to you.
Administering this website
We may process your personal information for administering and operating this website. This may include troubleshooting, data analysis, testing, system maintenance, and support. This helps us to continually improve this website and the services we can offer.
Recruitment
If you apply for a job with us, we will use your personal information to contact you, process your application, contact your referees, and, if applicable, offer you a job.
Legal obligations
We will use and process your personal information to comply with a legal obligation, and this includes using or processing personal information for satisfying any government reporting obligations and requests. We will also use your personal information to enforce any of our legal rights.
General business use
We may also use your personal information to evaluate and improve our business reach, and to improve our business processes.
Other legitimate interests
We will process your personal information for any of our other legitimate interests not described above. These include analysing use of our website or services, tailoring website and news content, setting preferences in our website or electronic mailings, improving our websites, offering and managing programs and events, fulfilling our obligations to our clients and others, and managing our client and vendor relationships.
6. Change of Purpose
We will only use your personal data for the purpose or purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we wish to use your personal data for a different purpose, we will first notify you and we will explain the reason or need to use it in this way, and the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7. How and Where We Disclose Your Personal Data
We will not sell, trade, rent, or share your personal information except in a way referred to in this Policy.
We do share your personal information with the following categories of third parties for the purposes described in this Privacy Policy:
7.1. Internal third parties: other companies in the Cortland Group acting as joint controllers or processors and who are based in the United Kingdom and the United States of America and provide IT and system administration services, support services, and undertake leadership reporting.
7.2. External third parties:
- 7.2.1. service providers acting as processors based the United Kingdom and the United States of America who provide infrastructure, IT, and system administration services, including cloud services.
- 7.2.2. service providers acting as processors based in the United Kingdom who provide credit checks and referencing services.
- 7.2.3. service providers acting as processors based in the United Kingdom who provide client relationship management software.
- 7.2.4. Agencies acting as processors based in the United Kingdom who provide marketing, advertising, and communications services.
- 7.2.5. Councils, acting as processors or joint controllers, for the purpose of setting up and dealing with your council tax account.
- 7.2.6. utility companies, acting as processors or joint controllers, for the purpose of setting up and dealing with your accounts.
- 7.2.7. professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in the United Kingdom and the United States of America who provide consultancy, banking, legal, insurance and accounting services.
- 7.2.8. HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- 7.2.9. contractors acting as processors based in the United Kingdom who provide maintenance services.
- 7.2.10. Service providers acting as processors based in the United Kingdom and the Unites States of America who provide cookie analytics, website testing, and website analytic services.
- 7.2.11. those to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data or we have entered into the requisite contract with the recipient. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
8. How We Secure Your Personal Data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They are only authorised to process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach when we are legally required to do so or we believe it appropriate to do so.
Unfortunately, despite such measures, no data transmission over the internet and no database or other depository of information can be one hundred percent secure. As a result, while we will strive to protect your personal information, we cannot and do not guarantee or warrant the security of any of your personal information. We will not be and are not liable for disclosures of your personal information due to errors in transmission, networks that we do not control, or unauthorised acts of third parties.
9. Keeping Your Personal Data
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you or one of our clients or suppliers.
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, regulatory, tax, accounting, or other requirements. As a guide, we will keep your personal data for not less than six years after you cease to have an interest in a property, you end your relationship with us, we fulfil a contractual obligation, and/or you cease being an employee.
In some circumstances you may ask us to delete your data: see Your legal rights below for further information.
In some circumstances we will anonymise or pseudo-anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, and these are listed below:
Request access to your personal data (a “data subject access request”). This means you can receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. You can ask us to remove personal data where there is no good reason for us continuing to process it. You also have this right where you have successfully exercised your right to object to processing, where we may have processed your data unlawfully or where we are required to erase your personal data to comply with the law. We may not always be able to comply with your request for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data. You can object where we rely 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.
Request restriction of processing. You can ask us to suspend the processing of your personal data: if you want us to establish the data’s accuracy; where our data use is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer need it to establish, exercise or defend legal claims; or you have objected to the use of data but we need to verify whether we have overriding legitimate grounds to use it.
Request a data transfer. We will provide to you, or your chosen third party, your personal data in a structured, commonly used, machine-readable format. This only applies to automated information which you provided consent for us to use or necessary to perform a contract with you.
Withdraw consent at any time. You can withdraw your consent where we rely on consent to process your personal data. This will not affect the lawfulness of processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
Exercising Your Rights
If you wish to exercise any of the rights set out above, please contact the Data Protection Administrator on the contact details set out above.
You will not have to pay a fee to access your personal data (or to exercise any other rights set out above). If your request is manifestly unfounded or excessive, or if you ask for further copies of your request, we may charge a reasonable fee. Alternatively, we may refuse to comply with your request if we consider it manifestly unfounded or excessive.
We may need to request specific information from you (such as a passport or driving licence, utility bill, third party references, and contact information such as your telephone number and email address) to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure personal data is not disclosed to a person who has no right to receive it. We may also contact you to ask you to clarify your request to speed up our response.
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 which case, we will keep you updated.
11. Updating Your Personal Data
Not only are we committed to the security of your information, but the accuracy too. It is important that you keep us informed if your personal data changes during your relationship with us.
If you provide us with information about any other person, for example, any other individuals within your organisation or your business partners, then you must ensure that you have their consent to pass those details to us and for us to use those details in accordance with this Policy. You should also make sure that you bring this Policy to their attention.
12. Information Provided to Us About You by Third Parties
We may present or embed content on our website, such as property listings, that is provided by our third-party vendors. This content may contain links to other sites not operated by us or may request personal information. For example, this content may ask for an email address to subscribe to alerts or share a listing with a friend. This information is collected by our vendors and not by us. In some cases, these vendors may share the personal information they collect from you with us. We are not responsible for the privacy practices of our vendors. We encourage you to review their privacy policies to understand how they will use and share the personal information you provide to them.
You may also separately share your information with other websites or entities, such as those that create professional marketing lists, to receive special offers and promotions from their affiliates. These websites or entities may share your information with us. We are not responsible for and accepts no liability if a partner or other website or entity collects, uses, or shares, any information about you in violation of its own privacy policy, or applicable law.
Where applicable law allows, we may purchase marketing data from third parties and add it to our existing user database to better target our advertising and to provide pertinent offers in which we think you would be interested. We may also associate this marketing data to the personally identifiable information that you provide to us.
13. What to Do if You Are Not Happy
We will only process your personal data in compliance with this Policy and all relevant laws and regulations. If you have cause for concern or are unhappy in any way, you may contact our Data Protection Administrator using the contact details set out above to raise your concern. Your concerns will be investigated, and the outcome of the investigation will be communicated to you within a reasonable amount of time.
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) which is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, like the opportunity to assist you with any concerns before you approach the ICO.