1. Introduction and General Terms
- what personal information we may collect from you;
- how we keep your personal information safe;
- what we may use your personal information for;
- who we may share your personal information with; and
- your rights regarding your personal information.
Trustees of the 2nd Duke of Westminster’s Will Trust and Grosvenor (Mayfair) Estate are data controllers in respect of your personal information for the purposes of applicable data protection legislation.
2. Legal ground for processing personal information
We will process personal information relating to you because such processing is necessary to: (i) further our legitimate interest in the effective administration and management of the Management Schemes (ii) comply with our legal obligations under the Management Schemes
3. Personal information we may process about you
How do we collect personal information about you?
We collect personal information that you provide to us or which is provided to us on your behalf by your advisors on the application form. You do not have to provide any personal information that we request from you, but it may not be possible for us to effectively progress your application if that personal information is not provided.
What types of personal information may we process about you?
We may process any or all of the following personal information that relates to you:
- your name,
- your email address, postal address, telephone and mobile number;
- your bank account details.
4. Keeping your personal information safe
Where the personal information is held
- We store your personal information on our property management software system, Yardi Voyager, which is provided and hosted by a third party, Yardi.
- The Yardi Voyager system is secure and complies with industry standards to protect your personal information from unauthorised access. Access to Yardi Voyager systems is limited to representatives of Grosvenor as well as certain of our service providers (see section 6).
- Personal information is held in MS Windows shared drives, our email software, MS Outlook and our email archive provider, Mimecast. Access is restricted to representatives of Grosvenor as well as certain of our service providers (see section 6).
Retention of your personal information
For audit and financial reasons, we will hold your personal information on our systems for 3 years following the date when any refund due to you has been repaid or 3 years after your application has been rejected. We may continue to hold your personal information for a longer period if required to do so by applicable law.
5. What we may process your personal information for
We process your personal information to enforce the terms of the ‘Belgravia Estate Management Scheme’ and ‘Grosvenor Mayfair Estate Management Scheme’, which provide a framework of management for the continued conservation of the Belgravia and Mayfair areas of London;
. Who we may share your personal information with
We may share your personal information with any of the following recipients as may be necessary or desirable for the purposes described in section 5:
- other members of our company groups and their respective employees;
- our service providers, including legal and financial advisors, managing agents, management surveyors, insurance brokers, debt recovery agents, hosting service providers and communications and marketing providers;
- local and foreign regulators, governments and law enforcement authorities;
- local and foreign courts, tribunals and arbitrators, other judicial committees and enactments of laws; and
- persons connected with any sale, merger, acquisition, disposal, reorganisation or similar change to our business (including any potential or actual purchaser or that business and that purchaser’s advisors).
All third parties to whom we transfer personal information relating to you will be under an obligation to protect the confidentiality and security of that personal information.
7. Your rights regarding the personal information you provide to us
The accuracy of the personal information we hold about you is important to us. Under applicable data protection legislation you have rights concerning your personal information.
You have a right to correct any inaccurate or incomplete personal information we hold on you. You have a right to receive a copy of the personal information we hold on you, which we must provide to you in a structured, commonly-used and machine-readable format. You have a right to require us to stop or to restrict our processing of your personal information. You have a right to require the erasure of personal information we hold on you once it is no longer necessary in relation to the purposes for which the personal information was collected or is being processed.
Please contact us if you wish to exercise any of these rights using the details in section 10.
If you have a complaint about how we manage your personal information please contact us. Our contact details are in section 10. If you are still not satisfied after going through our internal complaints procedure you can complain to The Information Commissioner’s Office by telephone on 0303 123 1113 or through the following link: https://ico.org.uk/global/contact-us/email/
Issued Jan 2019 V1