Common Ground Estate & Property Management Ltd is committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection as per the General Data Protection Regulation (as retained from the EU law version)(“UKGDPR”) and the Data Protection Act 2018 (“DPA”).

If you have any questions related to our GDPR compliance, please contact our Data Protection Officer or make a Data Subject Access Request.

About individuals in ways that comply with its obligations

Whenever we process the personal data of individuals, we will ensure that we are clear with those individuals about what we do (or may do) with their information.

This privacy policy explains what personal data (or “information”) we hold about individuals and contains important information on who we are, how and why we collect, store, use and share personal information, individuals’ rights in relation to their personal information and on how to contact us and supervisory authorities in the event you have a complaint. It is important that you read this privacy policy together with any other privacy policy or fair processing policy which we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your personal information. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Who we are

Common Ground Estate & Property Management Limited collects, uses and is responsible for certain personal information about individuals.

When we do so we are regulated under the UK GDPR and the Data Protection Act 2018 and we are responsible as the ‘controller’ of that personal information for the purposes of those laws. In this privacy policy, references to “we” or “us” mean Common Ground Estate & Property Management LTD.

We are a company registered in England and Wales with company number 07169211 and the registered address. Chiltern House, 45 Station Road, Henley-On-Thames, England, RG9 1AT

We are registered with the Information Commissioners Office – https://ico.org.uk/ESDWebPages/Entry/ZA100233

We operate accounts on the following third party platforms
https://www.dwellant.com
https://www.xero.com
https://www.adiuvo.org.uk
https://www.informdirect.co.uk

Contacting our compliance officer

We have a compliance officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your rights, please contact the compliance officer using the details set out below.

If you have any questions about this privacy policy or our privacy practices, including a request to exercise any of your rights, please contact our Data Protection Officer by post to Data Officer, Common Ground Estate & Property Management Ltd, Chiltern House, 45 Station Road, HenleyOn-Thames, England, RG9 1AT, or by email: enquiries@commongrounestates.co.uk

Our collection and use of this information is necessary for us to meet our key objectives, which include:

• Provision of estate management services
• Provision of company secretarial services
• Financial management (of the estates we manage)
• Meet our legal obligations
• Consultancy

The information we collect

Customers (Leaseholders)

• Name, address(es) – property address and correspondence address, email address(es), telephone number(s) and other contact details
• Financial data, including bank account and payment card details and details of your payments
• Details of any enquiry you have made, or any report you have submitted to us
• Profile data relating to your use of our website(s) including usernames and passwords, your interests, preferences, feedback and survey responses
• Technical data including your internet protocol address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you may use to access the website(s)

Resident Management Company/Right to Manage Company Directors

In addition to the information we hold about you as a “customer”, we retain the following information about directors

• Date of birth
• Occupation

Contractors

• Financial data, including bank account and payment card details and details of your payments
• Details of any enquiry you have made, or any report you have submitted to us
• Technical data including your internet protocol address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you may use to access the website(s)

We use different methods to collect information from and about you, including through:

• Information provided by previous managing agents and/or freeholders, right to manage companies and Resident management Companies
• Direct interactions: You may give us information by filling in forms or by corresponding with us by post, phone, email or otherwise.

This includes personal information you provide when you:

• Create an account on our website(s) subscribe to our services or publications, request marketing to be sent to you enter a competition, promotion or survey give us feedback or contact us
• Automated technologies or interactions: As you interact with our website(s), we will automatically collect technical data about your device, browsing actions and patterns. We may collect this information by using cookies, server logs and other similar technologies.
• Third parties or publicly available sources: We will receive personal information about you from various third parties and public sources as set out below:
• Technical information from analytics providers such as Google, based outside the UK and outside the EU contact details, financial and transactional data from providers of technical, payment and delivery services such as:
    – Stripe based outside the UK and outside the EU
    – SurveyMonkey based outside the UK and outside the EU
    – information relating to your identity and contact details from publicly available sources such as Companies House and the Electoral Register based in the UK.

Why we collect it

The collection of this information is required from our members so that we can:

• Provide our customer with services they expect to receive from us, including invoicing of services and estates charges, newsletters, updates, events
• Improve and develop our services and performance as an organisation
• Meet legal obligations.

Who we share it with

We may share your personal information with the following categories of recipients:

• Communication platforms and services (including Mailchimp) https://mailchimp.com/legal/privacy/
• Survey platforms and services (including Survey Monkey including https://www.surveymonkey.com/mp/gdpr/
• Marketing platforms and services
• Financial services, including Accountants
• Employees of Freeholders and their agents, resident management company directors, right to man age company directors, recognised tenants association directors

Data Security

We have security measures in place to seek to ensure that there is appropriate security for information we hold. Accountants will access information via the Xero accounts system and are required to access it using dual-factor authentication.

How long your personal information will be kept

We will retain your personal information for no longer than is reasonably necessary for the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, 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.

Details of retention periods for different aspects of your personal data are available on request from us by contacting us.

Our lawful basis

We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Our use of your personal data is necessary for us to carry out a contract that we have with a party that you have a legal agreement with such as a lease and/or membership
• 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 contractual obligation.

Generally, we do not rely on consent as a lawful basis for processing your personal information but there are certain circumstances where we will seek your consent to the processing of your personal information, such as where we carry out direct marketing activities.

Note that we may process your personal information for more than one lawful basis depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific lawful basis.