JA Management Commercial Privacy Policy

This policy (together with any other documents referred to) sets out the basis on which we will process personal data we collect from you, or that you provide to us, as a result of your use of our website or services. It supplements and should be read in addition to other terms and conditions that you have agreed to in connection with your use of our website or our services. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Information We May Collect From You

We may collect and process the following data about you:

  • Information that you provide to us.
  • Details of your visits to our site and the resources that you access.

JA Management is committed to protecting and processing your personal data in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. For the purpose of the legislation JA Management is the Data Controller.

Information held and lawful basis of processing

All the personally identifiable information we hold for all parties we interact with is listed in the tables below under the Information Held column. The purpose of our holding it is listed in the Why is it held column. There are six lawful bases for processing your data including consent, a legitimate interest, contract fulfilment, a legal obligation and a vital interest. Under the Lawful Basis of Processing column we have listed the relevant basis for each piece of data. 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 services. 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, details of potential recipients are included under Who will it be shared with.

Data collected will vary depending upon your relationship with this Company. If you are a Landlord and we rent out a property on your behalf see ‘Rental Landlords’, if you are a rental tenant see ‘Rental Tenants’, etc. Be aware there may be overlap between categories and you may fall under more than just one category (for example, if you are a rental tenant in a block we manage you will fall under ‘Rental Tenant’ and ‘Block Management; residents’).

Rental Landlords;

INFORMATION HELD WHY IS IT HELD LAWFUL BASIS OF PROCESSING WHO MIGHT IT BE SHARED WITH
Name & address of rental propertyTo use on Management contractContract FulfilmentN/A
To use on Rental ContractsContract FulfilmentRental tenant(s), Local Authority, Utilities
To inform Utility Companies during a void periodContract FulfilmentUtility suppliers, Local authority
To use on Deposit Protection Certificate (Prescribed Information)Legal ObligationDeposit Protection Scheme
If legal action (such as a Section 21 Notice) is requiredLegal ObligationRental tenant(s), Solicitor (if appropriate) and Local Authority
If HMRC request a rental income returnLegal obligationHMRC
Landlord contact details. These are;
- Contact telephone number
- Postal address
- E-mail address
To contact Landlord regarding property (repairs, invoices, etc.)Contract FulfilmentN/A
To use on Management contractContract FulfilmentN/A
To use in prescribed informationContract FulfilmentDeposit Protection Scheme
To chase rent arrearsContract FulfilmentSolicitor
If HMRC request a rental income returnLegal obligationHMRC
Bank Account detailsTo transfer balance of rentContract FulfilmentN/A

Rental tenants;

INFORMATION HELD WHY IS IT HELD LAWFUL BASIS OF PROCESSING WHO MIGHT IT BE SHARED WITH
Tenant contact details. These are;
- Name
- Previous address
- Current address (rented property)
- Contact telephone number
- E-mail address
- Forwarding address (upon moving out)
To contact tenantContract FulfilmentN/A
To use on Rental Contract (name & current address only)Contract FulfilmentLandlord, Local Authority, Utilities.
To inform Utility Companies upon move in and move outContract FulfilmentUtility suppliers
To use on Deposit Protection Certificate (Prescribed Information)Legal ObligationDeposit Protection Scheme
If legal action is required Legal ObligationLawyer(s), Police
In the event of an emergencyVital InterestEmergency Services
Tenant reference documentation. These are;
- Photo page of passport (and work visa if required)
- Employment details and/or a details of University study)
- Bank Statements
- Previous address
- Any other documents or information provided
Referencing & assessmentContract Fulfilment, except passport photo page and work visa which is a Legal Obligation Referencing Company(ies), passport photo page and work visa may be shared with the Home Office

Block Management; leaseholders / owners

Data collected may vary from block to block depending on what is required. Generally, the following is correct;

INFORMATION HELD WHY IS IT HELD LAWFUL BASIS OF PROCESSING WHO MIGHT IT BE SHARED WITH
Name of all leaseholders / owners and which property is theirsTo contact regarding maintenance issue(s)Contract FulfilmentN/A
To confirm legal owner of propertyContract FulfilmentN/A
To be used on correspondence such as AGM notification and Service Charge invoicesContract FulfilmentN/A
To be used by the Accountants at the end of year re. service chargeContract FulfilmentCertified Accountants
Should any form of legal action be requiredContract Fulfilment & / or Vital InterestLawyer(s), Police
In the event of an emergencyVital InterestEmergency Services
Leaseholder /owner contact details. These are;
- Contact telephone number
- Postal address
- E-mail address
To contact regarding a maintenance issue(s)Contract FulfilmentN/A
To be used on correspondence such as AGM notification and Service Charge invoicesContract FulfilmentN/A
Should any form of legal action be requiredContract Fulfilment & / or Vital InterestLawyer(s), Police
CCTV cameras (if there are cameras on the premises)Residents securityContract FulfilmentPolice (in the event of a reported crime)

Block Management; residents

Data collected may vary from block to block depending on what is required. Generally, the following is correct;

INFORMATION HELD WHY IS IT HELD LAWFUL BASIS OF PROCESSING WHO MIGHT IT BE SHARED WITH
Name To contact you regarding maintenance issue(s)Contract FulfilmentN/A
Should any form of legal action be requiredContract Fulfilment & / or Vital InterestLawyer(s), Police
In the event of an emergencyVital InterestEmergency Services (Police, Fire Service, Ambulance, etc.)
Resident contact details. These are;
- Contact telephone number
- Postal address
To contact you regarding a maintenance issue(s)Contract FulfilmentN/A
Should any form of legal action be requiredContract Fulfilment & / or Vital InterestLawyer(s), Police
CCTV camera footage (if there are cameras on the premises)Residents securityContract FulfilmentPolice (in the event of a reported crime)

Where is the data stored?

Your personal data is stored electronically on our computer system and through paper records. It may be stored within or outside the European Union but with an organisation operating under GDPR.

Retention period and criteria used to determine the retention period

We may retain some elements of your personal data for up to 6 years after we cease to be your agent. The information will be that which is 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 such 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 require 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).

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.

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.

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