Digs Swansea Lettings LLP Privacy Policy  

This Privacy Policy outlines Digs Swansea Lettings LLP (" we ", " our " or " the Company ") practices with respect to information collected from users who access our website at www.digsswansea.biz (" Site ") or otherwise share personal information with us (collectively: " Users "). 
This Privacy notice is provided by Digs Swansea Lettings LLP for prospective tenants and applicants, tenants and guarantors to tell you what information we hold about you, why we collect it, what we do with it and who it may be shared with. We collect and handle personal information to fulfil our role to provide rental accommodation. This includes letting and setting up tenancies, property management including repair work, arranging payment of utility supplies, rent collection, possible reference and immigration checks, maintaining our records and dealing with the deposit and termination of the tenancy. 

This will be referred to as “data” and “your information”

Any reference to guarantors, tenants or applicants can also include any former guarantors, tenants or applicants. Not all of this policy may seem relevant and therefore please disregard any information that is not relevant. References to a tenant can also include a guarantor, as a guarantor underwrites a tenant’s obligations and therefore references to the tenancy include the guarantee. 

Please read through this to be informed of how we use your information and inform us if any of the information supplied by you changes. 

Data Controller:
Digs Swansea Lettings LLP
Heritage House, 10A Park Place, Clifton, Bristol, BS8 1JW
lettings@digsswansea.biz
01792 514 516
ICO registration number: ZA558764

Why are we giving you this notice?
We are giving you this notice as we are required by data protection law to inform you why information is collected about you and then what is done with it. We must act fairly in relation to this information. You have various legal rights relating to this information which are spelt out in more detail in this notice.    

For us to collect or use your information there must be a legal basis or gateway for doing so. This notice identifies the relevant gateways for the various types of information we collect and hold. 

Under the data protection legislation, we can only process your data as necessary and to the extent that it is needed. However, in certain instances, as required, we can share your data, such as with utility suppliers, our own professional advisers, police/law enforcement agencies or regulatory authorities.

What type of data do we collect and hold about you?
We collect your information in different ways, including the information you supply to us during the application process. If you fail to provide the required information, we may not be able to proceed with the tenancy. The personal data we may process consists of:

• Identity and contact details including name, date of birth, student number, and where necessary car registration
• Personal/background information including occupation/status
• Bank details
• Verification and credit status
• Deposit (if any) including the amount, who it is paid by and bank details for return on tenancy termination
• Tenancy details including renewals, joint tenants, other residents and guarantors
• Immigration/right to rent checks 
• Rent and other payments 
• Recovery of arrears, claims or possession proceedings
• Repairs/health and safety/housing conditions
• Breach of tenancy terms/nuisance/anti social behaviour
• Council Tax liability
• Water charges payable
• Utilities and services provided
• Welfare Benefits
• Termination of tenancy 
• Audio and CCTV recordings (if any)
• Complaints
• Insurance
• Health or disability
• Emails texts and other communications and via our website where we operate one.
• Website and online portal information.
We also generate and use data internally, e.g. our rent records. 

Your data may also be collected and received third parties. This may be information from other tenants or neighbours and can include information from your guarantor or a guarantor of a joint tenant. Public bodies such as local authorities or the police, or other law enforcement agencies may give us information about you. This can include the Department for Work and Pensions or the local authority where you are receiving Universal Credit or housing benefit. Information may be given to us relevant to Council Tax by the local authority. Utility companies or service providers may also give us personal information about you. We obtain information about you when we carry out credit checks or take up references. We may also receive information from you via websites or from online rental portals such as StuRents, Gumtree, Zoopla, Rightmove or through our website. Any information which we receive in this way is set out in the Table to this privacy notice which gives you more details about information which we can receive from third parties. 

Why do we use the information about you?
The various purposes for which it may be necessary for us to process different categories of your information include: –
• In our legitimate interests for ensuring you are allowed to rent out the property
• In our legitimate interests for deciding on the suitability of a proposed tenant/resident
• In our legitimate interests for verifying the credit worthiness/suitability of tenants/residents
• Our legal obligation to check immigration status/right to rent. This is also to verify identities.
• To perform our tenancy contract to deal with joint tenants and residents who are linked to the tenancy
• To perform our contract to complete the tenancy agreement
• In our legitimate interests to secure rental payments/performance of tenant obligations, e.g. deposits and guarantors
• For contractual performance for rent collection and collection of other payments including banking details
• For contractual performance for managing the tenancy and the property
• For contractual performance and/or in our legitimate interests for record keeping
• For contractual performance for arranging repairs and maintaining the condition of the property and keeping it in a safe condition.
• For contractual performance for monitoring and enforcement of tenant responsibilities
• For contractual performance or in our legitimate interests for recovering debts and other payments due, including any possession proceedings
• In our legitimate interests for administering liability for Council Tax
• In our legitimate interests and those of the provider relating to arranging and paying for utilities and services
• In our legitimate interests for dealing with welfare benefits (including Universal Credit and housing benefit) where payable in respect of the rent
• In our legitimate interests in relation to tenancy termination including the return of any deposit and for dealing with any deposit disputes.
• In our legitimate interests for processing complaints
• For contractual performance or in our legitimate interests for dealing with health and disability issues relating to tenants/residents
• In our legitimate interests for obtaining and holding audio and cctv recordings
• To perform our legal obligations to provide information to public or local authorities who are legally entitled to require this information
• In your vital interests for contacting next of kin etc., in an emergency
• In our legitimate interests for the storage of emails, records of calls and other communications
• In accordance with our legal obligations if you exercise your rights under data protection law
• To perform our legal obligations for compliance with legal and regulatory requirements
• In our legitimate interests for the establishment and defence of legal rights
• In our legitimate interests for prevention, detection and investigation of crime and anti social behaviour and the security of any website or other means of electronic communication
We may change the purposes where this is compatible for the purpose for which we obtained the data originally. If we need to use your data for a non-compatible purpose we will notify you and explain the legal gateway that allows us to do so. We may process your information without your knowledge where this is required or permitted by law.
Do we share your data?
Where it is necessary, we will share data that we hold with others. We must comply with data protection legislation when doing this. Information can be shared with contractors and suppliers; utilities and service providers; trades people; financial organisations including banks and insurance companies; debt collection and tracing agents; public and government bodies (including those who administer benefits); courts; police and law enforcement agencies; taxation authorities; local authorities in relation to Council Tax and regulatory functions; any future owner of the property if we are selling and other landlords including where you apply to another landlord for a tenancy. We may need to share information with your next of kin etc., e.g. in an emergency. We also may share information with professional advisers such as lawyers and accountants or an advice agency which involves sharing information about you with them. If you live in a flat we may give information to the freeholder. We also send notifications to and have correspondence with any tenancy deposit scheme protecting any tenancy deposit which has been paid and may be required to share information with them at the end of the tenancy if a deposit dispute should occur. Where you are in a joint tenancy or there are guarantors for your tenancy, as necessary, we will share information either with joint tenants or guarantors or both. This may relate to your performance of your responsibilities under the tenancy agreement including rent arrears or other breaches of the tenancy terms. In some cases, we may be under a legal obligation to provide information either because of the law or because of a contractual obligating binding on us. What we share will depend on what is necessary in the circumstances and more details are given in the Table in respect of different kinds of information which we hold about you.  

Immigration/right to rent checks
By law, we are required to check your immigration status before we rent a property to you. This means that you are legally obliged to produce certain documentation (e.g. a passport or driving licence) to us. This applies whether or not you are a UK or EU citizen. We are required to see original documentation and also to take and keep copies of it. We check this documentation as part of our process to verify your identity at the outset of the tenancy. Prospective tenants and all adult residents who will live at the property must be checked.  

Search engines and websites
As necessary, we obtain information about you which is publically available via search engines such as Google or Facebook and websites. This will include information about you which you yourself made public. Further details are set out in the Table. However, when doing so we make sure that we comply with applicable guidelines under data protection legislation. 

Special categories of data/sensitive personal data
In limited situations we will process information about your health or any disability. This data is given special protection under data protection law. Normally we would expect to ask you for your explicit consent before we collect or use this kind of data.  

Obligation to process data
Property Letting is highly regulated so we are under various legal obligations. These include an obligation to carry out gas safety checks under gas safety legislation. We may need to handle data for this purpose such as to give the contracted gas safety engineer access to the property. We are also legally obligated to pass over details of your occupancy of the property to Welsh Water to enable them to collect water charges.  

Legally we must also hold and process information relating to any tenancy deposit which you pay to us including sharing your information with a deposit scheme by which any deposit is protected.  

Under any statutory licensing schemes applicable to the property we may be required to give information to the local housing authority relating to your occupation of the property. Similarly, there are various regulatory requirements which may mean that we need to give information about you to public or local authorities or other regulatory authorities.  

Utilities
In line with advice from the Information Commissioner we consider that it is in the legitimate interests of utility companies to receive information about occupants of the property to enable them to bill you for utilities (unless these are included within your rent or are paid by us and then invoiced to you). 

Council Tax
We notify the council of your occupancy relevant to the collection of Council Tax, including sharing your student status to ensure relevant exemptions are applied.
In any event they are entitled to serve notice upon us requiring this information if they choose to do so.

Retaining Communications
We monitor, record and retain your calls, emails, text messages, social media messages and any other communications. This is in our legitimate interests to maintain an accurate record which is necessary ot manage your tenancy and the property as well as to deal with tenancy applications and prospective tenants and guarantors. We need these records for our ongoing dealings with you, including our data protection obligations. 

Telephone calls
To protect our legitimate interests telephone conversations may be recorded electronically for monitoring and to ensure that we have a record of what is said. You or others may leave messages when calling.

CCTV
When CCTV is installed, this is for security purposes in cases where we consider that it is in our legitimate interests to carry out such monitoring which must be done in accordance with legal requirements. We may also use CCTV to detect breaches of the tenancy terms, e.g. in the common parts or outside the building. Recordings will be kept for these purposes. 

Length of storage of data
Data can only be stored on a time limited basis and not excessively. We will hold personal data about you for the duration of your tenancy and for seven years after your tenancy has ended. This is the statutory limitation period of six years plus a further year to allow for service of proceedings should proceedings commence later. We are also required to retain information for up to six years for tax purposes. If your tenancy application does not go ahead then we retain data for one year.  

Storage and security of data
We have put in place appropriate 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, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. All our information is stored securely electronically on servers or devices. Certain information is also retained on a secure basis in hard copy format.  

Information legally required under your tenancy agreement
Your tenancy agreement provides that in certain situations you must give us information when asked. This is a legal obligation because it is a contractual requirement. You should refer to the relevant clauses in your tenancy agreement which tell you the situations in which such information must be given. 

Holding data outside the European Union
Our email account is web based and is provided by Microsoft Exchange. Providers store related data internationally and not necessarily within the European Union. Microsoft meet the adequacy standard required by data protection laws. The recipient of this data is the provider concerned. Data is also held in Arthur Property Management Software. For further information on this you can view their own data protection policy here: https://www.arthuronline.co.uk/gdpr/.

Your rights
As the data subject, due to us holding personal data about you, you have a number of rights under data protection legislation. To exercise any of these rights you should contact us. You can do so by using the contact details provided above. 

In particular you have a right to object to the processing of your information where we are processing this in our own legitimate interests or those of a third party. This applies if you feel that this impacts on your own interests or your fundamental rights or freedoms.  

These rights are as follows – 
• Access – you have the right to make a request to be told what personal data we hold about you including what data has been processed and to have access to your personal data. 
• Correction/Rectification – if you consider any data we hold about you is inaccurate you can tell us so that where appropriate this can be corrected. Where a mistake is made in data processing then you can ask to have it rectified. Any third parties who have received the data from us should then be told of the rectification and you should be informed by us of any such third parties.   
• Erasure – you have a right to ask us in certain circumstances to erase any data we hold about you (the so called right to be forgotten). Individuals can request the right to have personal data erased to prevent processing in specific circumstances, i.e. it is no longer necessary, consent has been withdrawn, there is an objection and where applicable your rights etc., override the legitimate interests to continue our processing, or data has been unlawfully processed.
• You can object to our processing of data – this allows you to object to our processing of data about you. We must then stop processing data unless we can establish legitimate reason for continuing. In particular this applies where we are relying on our own legitimate interests or those of a third party to process data but it can also apply in other situations. 
• Restricting processing – you can ask us to suspend processing of your personal data and we must then restrict processing of data. This includes where you are contesting the accuracy of a statement or the lawfulness of the processing. 
• Data portability – this allows individuals to reuse their personal data for their own purposes across different services allowing them to move, copy or transfer personal data more easily. 

Withdrawal of consent
Where your consent provides us with the legal gateway to process data about you you can withdraw this at any time by telling us by email or post using the details above.

Website specific data protection:
What information do we collect?

We collect two types of data and information from Users. 

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information about your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

The second type of information is Personal Information which is individually identifiable information, namely information that identifies an individual or may, with reasonable effort, identify an individual. Such information includes:
  • Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site:
  • name and job title
  • contact information including email address
  • demographic information such as postcode, preferences and interests
  • other information relevant to customer enquiries

How do we receive information about you?

We receive your Personal Information from various sources:
  • When you voluntarily provide us with your personal details in order to register on our Site;
  • When you use or access our Site in connection with your use of our services;
  • From third-party providers, services and public registers (for example, traffic analytics vendors).

How we use the information we collect

We do not rent, sell or share Users’ information with third parties, except as described in this Privacy Policy.

We may use the information for the following:
Communicating with you – sending you notices regarding our services, providing you with technical information and responding to any customer service issue you may have;
  • To communicate with you and to keep you informed about our latest updates and services;
  • We may use the information to improve our products and services
  • For statistical and analytical purposes, intended to improve the Site
  • Internal record keeping
  • To contact you in response to a specific enquiry
  • We may contact you by email, phone, fax or mail for market research reasons
In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third-party providers, who may be located in different jurisdictions across the world, for any of the following purposes: 
  • Hosting and operating our Site;
  • Providing you with our services, including providing a personalised display of our Site;
  • Storing and processing such information on our behalf; 
  • Serving you with advertisements and to assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;
  • Performing research, technical diagnostics or analytics;
Cookies
We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 

A "cookie" is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies ' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third-party cookies' which are set by other online services who run content on the page you are viewing, for example by third-party analytics companies who monitor and analyse our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, which pages they visit, when they do so, etc. We use the information we obtain from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Third-party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 

This Privacy Policy does not apply to the practices of companies that we do not own or control, nor to individuals whom we do not employ or manage, including any of the third parties which we may disclose information to as set out in this Privacy Policy. 

How do we safeguard your information?

We take great care in implementing and maintaining the security of the Site and your information. We employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorised use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorised access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Advertisements

We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser). 

You may opt out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org and http://optout.aboutads.info.

Complaints
We operate our own internal complaints policy and if you have any concerns about the way in which we collect or handle data please contact us. 

Additionally, you have the right to lodge a complaint with the Supervisory Authority who is –
Information Commissioner
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
www.ico.org.uk 

Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

How to contact us

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at lettings@digsswansea.biz or write to Digs Swansea Lettings LLP, Heritage House, 10a Park Place, Clifton, Bristol, BS8 1JW.

Last Modified 30th October 2019.
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