PRIVACY NOTICE

The Data Protection Act 2018 (DPA 2018) sets out the data protection framework in the UK and incorporates the Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”) into the national law. Its purpose is to protect the “rights and freedoms” of natural persons (living individuals), and to ensure that personal data is not processed without their knowledge, and, wherever possible, that it is processed with their consent.

Under the DPA 2018 and the GDPR, Lettuce Property Management Ltd, is defined as the Data Controller and therefore has a legal duty to protect any information we collect from you. Lettuce Property Management Ltd (T/A Lettuce Student Accommodation) is a wholly-owned subsidiary of Topham Investments Ltd.

This notice explains what information we collect, when we collect it and how we use this. During the course of our activities, we will process personal data (which may be held on paper, electronically, or otherwise) about you and we recognise the need to treat it in an appropriate and lawful manner. The purpose of this notice is to make you aware of how we will handle your information.

What are the legal grounds for our processing of your personal information (including when we share it with others)?
We rely on the following legal bases to use your personal data:

Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations. For example, when preparing your tenancy agreement and guarantor documentation.

Legal compliance
If the law requires us to, we may need to collect and process your data. For example, our obligations under “Right to Rent” legislation.

Legitimate interest
Where it is in our legitimate interests to do so. For example:

• Providing security services at our properties
• Fraud prevention and detection
• Risk assessment
• Compliance
• Due diligence
• Network and Information Security
• Suppression lists and managing communication opt-out requests
• Training, communication and awareness
• Profiling
• Direct marketing of our own properties where you have actively expressed an interest in our properties
• Monitoring and web analytics
• Cloud storage
• Utility switches

What kinds of personal information about you do we process?
Personal data is information that relates to an identified or identifiable individual.

We collect information about you:

• When you contact us through our website, email, social media or by telephone
• During your application for accommodation
• Subscribing or unsubscribing to marketing material
• Participating in a promotion, offer or competition
• Entering or attempting to enter into a business or employment relationship with ourselves
• When you act as a Guarantor;
• Your image and voice may be recorded on CCTV if you live at or visit Willowbank Mews
• Your image and voice may be recorded on body worn video if you live at or visit Willowbank Mews

We collect the following information about you:

• Name
• Home Address
• Telephone number
• Current address/Landlord
• Email address
• Date of Birth
• Nationality
• Identification documents
• Course certificate
• Student ID number
• New student address
• Guarantor telephone number
• Guarantor email address
• Guarantor employer
• Identification documents
• Guarantor identification documents
• Guarantor utility bills
• Guarantor bank/mortgage statements
• Guarantor P60/payslip
• Trusted Contact details

Information may also be provided to us indirectly by, including but not limited, to:

• Next of kin / delegated authorities
• Employers
• ‘Trusted Sources’ eg:- Government agencies, University bodies, Police registers, Credit / Default Agencies, Financial Institutes (Banks, Building Societies, Loan Agencies, Credit Card companies), Law firms, Health providers, Third party service affiliates or suppliers who have sought your consent. This information may be provided via the use of forms and documentation, Online submission portals, Email, postal or telephone correspondence.

We, our service providers and partners collect certain information by using automated means, such as cookies, when you interact with our advertisements, mobile applications, or visit our websites, pages or other digital assets. The information we collect in this manner may include:

• IP address
• Browser type
• Operating system
• Referring URLs and information on actions taken or interaction with our digital assets.

Please see our Cookie Policy for more information.

How do we use your personal information?
This means your personal information, which you supply to us may be used in a number of ways, for example:

• To keep and maintain accurate records relating to your tenancy
• To collect tenant fees, deposit, rental and any other payments due
• To protect your deposit or register a guarantor as an interested party
• To recover debt
• Provide tenant services such as parking, out of hours telephone service, on-site security and emergency unlock
• To send you communications required by law or which are necessary to provide our services to you
• To monitor and to keep records of our communications with you and our staff
• To comply with legal and regulatory obligations, requirements and guidance
• Managing any aspect of the service
• To protect our tenants, premises and assets from crime, at Willowbank Mews we operate CCTV systems which record audio and images and Body Worn Video which record audio and images for security. We do this on the basis of our legitimate business interests.
• To inform you of properties which may be of interest to you where you have actively expressed an interest in our properties.
• In the interests of your health, safety and welfare.

Sharing your personal information
Furthermore, during the processing of your tenancy agreement, throughout the duration of your tenancy, after the tenancy end-date and in other circumstances where we are required to meet our legal and statutory obligations, provide our services to you, and protect our legitimate interests, information may be shared with third parties as is reasonably necessary, for example;

• The relevant Local Authority
• Our on-line payment services provider, currently Sagepay
• Our chosen Deposit Protection Scheme, currently My Deposits
• Our on-site security and key-holding services provider, currently G4S
• Our out of hours telephone service provider, currently Callcare
• The higher education institute you are attending, usually Coventry University
• The Police
• Your Guarantor
• The person authorised to pay your rent
• The Home Office
• Legal professional/Court
• Other tenants party to your joint tenancy agreement and their guarantors
• Fellow housemates
• The Landlord
• Cloud services provider
• IT support provider
• Utility companies
• Your Trusted Contact(s)

We will never knowingly share, pass or sell on your personal data to with a third party for marketing purposes without your consent.

For how long is your personal information retained by us?
Whenever we collect or process your personal data, we will only keep it for as long as is necessary for the purpose for which it was collected and in line with legal and regulatory requirements.

Your Rights

The UK GDPR provides the following rights for individuals:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability

The right to object
You have the right at any time to:

• ask for a copy of the information about you held by us in our records
• require us to correct any inaccuracies in your information
• make a request to us to delete what personal data of yours we hold
• object to receiving any marketing communications from us; you can exercise this right by emailing admin@lettucelettings.co.uk, or unsubscribing via the “unsubscribe link” within the marketing emails you receive from us.

If you would like to exercise any of your rights above, please contact us at admin@lettucelettings.co.uk.

Should you wish to complain about the use of your information, we would ask that you contact us to resolve this matter in the first instance. You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information. The Information Commissioner’s contact details are noted below:

England:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113
Email: casework@ico.org.uk

Scotland:
The Information Commissioner’s Office
Scotland 45
Melville Street
Edinburgh
EH3 7HL

Telephone: 0131 244 9001
Email: Scotland@ico.org.uk

Wales:
Information Commissioner’s Office
2nd floor
Churchill House Churchill way
Cardiff
CF10 2HH

Telephone: 029 2067 8400
Email: wales@ico.org.uk

Northern Ireland:
Information Commissioner’s Office
3rd Floor
14 Cromac Place
Belfast
BT7 2JB

Telephone: 028 9027 8757
Email: ni@ico.org.uk

Access to your information and how to contact us
The accuracy of your information is important to us – please help us keep our records updated by informing us of any changes to your email address and other contact details. For further information on how your information is used, how we maintain the security of your information and your rights to access information we hold on you, please contact admin@lettucelettings.co.uk or telephone 02477 717171.

Updating this Privacy Notice
Lettuce Property Management reserve the right to amend and update this Privacy Notice when required therefore it is advisable you review this notice at regular intervals.