COLIN BIBRA ESTATE AGENTS LIMITED (CBEA)
GENERAL DATA PROTECTION REGULATION (GDPR)
Colin Bibra Estate Agents (CBEA) collects, holds and processes data only respecting the sale, ownership and rental of property in a way which:
1. Is necessary for the administration of the multiple interests involved in the management of leasehold and rental property and the sale and purchase of leasehold and freehold property.
2. Our clients would reasonably expect.
3. Has a minimal impact on our clients’ personal privacy.
The personal data that we collect, hold and process is of a limited nature and consists of the following:
1. Contact information: names, addresses, telephone numbers, email addresses.
2. Account information connected with the rent or service charge due for the individual property, including debit and credit information and balances.
CBEA deals with the above data on a ‘legitimate interests’ basis where, according to Article 6 (1) (f) of GDPR, “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child”. We do not collect or hold any data on children under the age of 18.
The legitimate interests are primarily those of our clients, specifically (1) the owners of property on behalf of whom we let, manage and sell houses, apartments and commercial units, and (2) the appointed directors of the residential management companies who have engaged CBEA to act as their managing agent. Our legitimate interests assessment has identified no significant risks to the interests or privacy of the individual data subject.
CBEA also relies on contract as a lawful basis for processing the personal data of leaseholders. While there is no direct contract with leaseholders, CBEA is appointed as the managing agent of the estate by the landlord or residential management company, who have a contractual relationship with each leaseholder by means of the lease.
Data is primarily stored on the property management applications running on the CBEA computer system, protected by adequate password-based access and firewalls. Data may be transferred for secure storage to servers both inside and outside the EEA (European Economic Area). We retain the data for as long as it is necessary for the management of the estate and your personal interest in it.
We may on occasion share contact information (name, address, telephone number, email) with selected contractors and service providers in order to enable us to perform the obligations in our contract as managing agent to repair and maintain the property. We will share personal information with law enforcement or other authorities if required by applicable law. We will not share your personal information with any other third party.
The collection, storage, processing and sharing of data is supervised by our Data Administration Department, which operates as a section of the CBEA Estate Management Accounts and Legal Team. The Data Administration Department ensures compliance with the data protection principles enshrined in GDPR, and is the first resort for questions on data collection and control. The department is answerable to the main CBEA management team.
GDPR recognises the following rights that our clients have with respect to their personal data:
- The right to request a copy of the data (CBEA will supply this free of charge within 30 days of receiving the request).
- The right to request that any inaccuracies are corrected.
- The right to request that personal data is erased where it is no longer necessary for it to be retained.
- The right to restrict further processing of data where there are inaccuracies.
- The right to complain to the Information Commissioner’s Officer if the client believes there is a problem with the way we handle the data. The Information Commissioner may be contacted at https://ico.org.uk/concerns or on 0303 123 1113.
This Privacy Notice was published on 23 May 2018. We may change this Notice from time to time; when we do so we will inform you.
Colin Bibra Estate Agents Limited
Data Administration Department
204 Northfield Avenue
London W13 9SJ
020 8567 0077