“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be directly using the data itself or by combining it with other information which helps to identify a living individual (e.g. a list of residents may contain car registration numbers rather than names but if you use a separate list of the registration numbers which give the corresponding names to identify the residents in the first list then the first list will also be treated as personal data).
The processing of personal data is governed by legislation relating to personal data which applies in the United Kingdom including the General Data Protection Regulation (the “GDPR) and other legislation relating to personal data and rights such as the Human Rights Act.
A description of what personal data Prince of Wales Mansions (Harrogate) Ltd (POWM) processes and for what purposes is set out in this Privacy Policy.
Names, titles and aliases, photographs.
Contact details such as telephone numbers, addresses, car registrations, and email addresses.
Where they are relevant to the services provided by POWM, or where you provide them to us, we may process information such as gender, age, marital status, nationality, education/work history, academic/professional qualifications.
Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept and destroyed securely including ensuring that appropriate technical and security measures are in place to protect your personal data to protect personal data from loss, misuse, unauthorised access and disclosure.
To deliver services for the benefit of POWM residents.
To provide services that you request and to understand what we can do for you and inform you of other relevant services.
To confirm your identity to provide some services.
To contact you by post, email, telephone or using social media (e.g., Facebook, Twitter, WhatsApp).
To help us to build up a picture of how we are performing.
To prevent and detect fraud and where necessary for the law enforcement functions.
To enable us to meet all legal and statutory obligations and powers including any delegated functions.
To carry out comprehensive safeguarding procedures (including due diligence and complaints handling) in accordance with best safeguarding practice from time to time with the aim of ensuring that all children and adults-at-risk are provided with safe environments and generally as necessary to protect individuals from harm or injury.
To promote the interests of POWM.
To maintain our own accounts and records.
To seek your views, opinions or comments.
To notify you of changes to our facilities, services, events and staff, director and other role holders.
To send you communications which you have requested and that may be of interest to you. These may include information about refurbishments, new projects or initiatives.
To process relevant financial transactions including payments for goods and services supplied to POWM.
To allow the statistical analysis of data so we can plan the provision of services.
Our processing may also include the use of CCTV systems for the prevention and prosecution of crime.
POWM is a limited company and has certain powers and obligations. Most of your personal data is processed for compliance with a legal obligation which includes the discharge of POWM’s statutory functions and powers. Sometimes when exercising these powers or duties it is necessary to process personal data of residents or people using POWM’s services. We will always take into account your interests and rights. This Privacy Policy sets out your rights and POWM’s obligations to you.
Sometimes the use of your personal data requires your consent. We will first obtain your consent to that use.
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is currently best practice to keep financial records for a minimum period of 8 years to support HMRC audits or provide tax information. We may have legal obligations to retain some data in connection with our statutory obligations as a limited company. POWM is permitted to retain data in order to defend or pursue claims. In some cases, the law imposes a time limit for such claims (for example 3 years for personal injury claims or 6 years for contract claims). We will retain some personal data for this purpose as long as we believe it is necessary to be able to defend or pursue a claim. In general, we will endeavour to keep data only for as long as we need it. This means that we will delete it when it is no longer needed.
You have the following rights with respect to your personal data:
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
· The right to access personal data we hold on you
At any point you can contact us to request the personal data we hold on you as well as why we have that personal data, who has access to the personal data and where we obtained the personal data from. Once we have received your request we will respond within one month.
There are no fees or charges for the first request but additional requests for the same personal data or requests which are manifestly unfounded or excessive or may be subject to an administrative fee.
· The right to correct and update the personal data we hold on you.
If the data we hold on you is out of date, incomplete or incorrect, you can inform us as your data will be updated.
· The right to have your personal data erased
If you feel that we should no longer be using your personal data or that we are unlawfully using your personal data, you can request that we erase the personal data we hold.
When we receive your request, we will confirm whether the personal data has been deleted or the reason why it cannot be deleted (for example because we need it for to comply with a legal obligation).
· The right to object to processing of your personal data or to restrict it to certain purposes only
You have the right to request that we stop processing your personal data or ask us to restrict processing. Upon receiving the request, we will contact you and let you know if we are able to comply or if we have a legal obligation to continue to process your data.
· The right to data portability
You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
· The right to withdraw your consent to the processing at any time for any processing of data to which consent was obtained
You can withdraw your consent easily by telephone, email, or by post (see Contact Details below).
· The right to lodge a complaint with the Information Commissioner’s Office.
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Any personal data transferred to countries or territories outside the European Economic Area (“EEA”) will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union. Our website is also accessible from overseas so on occasion some personal data (for example in a newsletter) may be accessed from overseas.
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
We keep this Privacy Policy under regular review and we will place any updates on this web page: http//www.powm.co.uk/dataprotection. This Notice was last updated in June 2018.
Please contact us if you have any questions about this Privacy Policy or the personal data we hold about you or to exercise all relevant rights, queries or complaints at:
Prince of Wales Mansions (Harrogate) Ltd
1 York Place
Harrogate
North Yorkshire
HG1 1JB
United Kingdom
Further information on GDPR can be found at the UK Government site: https://www.gov.uk/government/collections/data-protection-act-2018
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