This version of our Privacy Statement is live from Monday 21 January 2018. The content of this statement may change from time to time, so you may wish to check this page occasionally to ensure you are still happy to share your information with us.
Gen² Property Ltd, a wholly owned subsidiary of Kent County Council, are committed to protecting and respecting any personal information that you share with us. This statement describes what types of information we collect from you as a data controller, and/or a data processor on behalf of our clients. It describes how this information is used by us, how we may share it with others, how you can manage the information we hold, and how you can contact us regarding your information.
We do not use personal information from general enquiries for marketing purposes. We will never send you unsolicited ‘junk’ email or communications, nor share your details with other organisations that might. We will not sell your information to third parties; however, we do work closely with Kent County Council and its subsidiary companies (hereafter collectively referred to as the KCC Group for the purposes of this document) who help to provide you with the information, products and services that you request from us.
Further information regarding Kent County Council’s privacy statements can be found on its website. please visit: https://www.kent.gov.uk/about-the-council/about-the-website/privacy-statement
Our full contact details can be found at the end of this notice.
What information do we collect?
We collect information about you and your property and/or location when you contact us via our website, email addresses and telephones. We only collect information which is necessary, relevant and adequate to deal with the enquiry or task it is provided for.
The information we may collect includes some, or all, of the following:
Name (including title);
Date of birth;
The date and time you used our services, or contacted us regarding our services;
The pages you visited on our website and how long you visited us for;
Your IP address;
The internet browser and devices you are using;
The website address from which you accessed our website;
Details of any transactions between you and us or any other part of the KCC group
Where you engage with us in a business context, we may collect your job title, company contact details (including email addresses), and company details (some of which we may obtain from an online or public business directories);
Any information within correspondence you send to us.
- Where you act on behalf of a business, any information we collect as part of business marketing activity.
How do we use this information?
Gen² Property Ltd will only process information that is necessary for the purpose for which it has been collected. We do not collect information from publicly accessible sources, or purchase information from third parties. We will never send you unsolicited ‘junk’ email or communications, nor share your personal information with anyone else who might.
Gen² do not use automated methods to analyse, combine and evaluate information that you have provided to us, or use automated decision-making processes based on personal data.
There are various ways in which we may use or process your personal information. We list these below:
Where you have provided your consent, we may use and process your information to undertake your enquiry or task that you have requested of us, either directly or on behalf of Kent County Council and/or other clients.
You can withdraw your consent at any time by contacting us on the details towards the end of this page. This may impact our ability to deal with any open enquiries/tasks you have with us where we rely on your consent as the legal bases for holding your details. In this circumstance, we will advise you of this.
We may use and process your personal information where this is necessary to perform a contract with you – which includes any lease and tenancies – and to fulfil and complete your orders, purchases and other transactions entered into with us, either directly or on behalf of Kent County Council and/or other clients.
We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.
Processing necessary for us to respond to understanding customers’ needs and requirements
To respond to any correspondence you send to us and fulfil the requests you make to us (for example: ownership enquiries, lease and rent enquiries, consultations);
To provide property support and services (for example maintenance and facilities services);
To analyse, evaluate and improve our products and services so that your visit and use of our website, email and telephone correspondence are more useful and enjoyable.
For product development purposes (for example to improve quality, performance and safety);
Processing necessary for us to promote our business, brands and products
To contact you if the company opens, closes or moves premises.
Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
To verify the accuracy of information that we hold about you and create a better understanding of you as a customer;
For network and information security purposes i.e. in order for us or our IT Provider to take steps to protect your information against loss, damage, theft or unauthorised access;
To comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- To inform you of updates to our terms and conditions and policies.
We may process your personal information to comply with our legal requirements (for example to register sales with HM Land Registry).
Sometimes we will need to process your personal information to contact you if there is an urgent safety concern relating to a property under our control and we need to tell you about it.
How do we share this information?
We do not sell your information to third parties, However, we may from time to time disclose your information to the following categories of companies or organisations to which we pass the responsibility to handle services on our behalf: Other companies/organisations within the KCC Group, Facilities Management Companies or Estate Agencies providing services to buildings under our control, our legal and other professional advisors.
We take steps to ensure that any third-party partners who handle your information comply with data protection legislation and protect your information just as we do. We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf. We will aim to anonymise your information or use aggregated non-specific data sets where ever possible.
We do not process or store data and information outside of the European Union.
There are circumstances where we share your information with our parent (or other companies within the KCC Group) in order to fulfil orders, transactions, handle complaints or provide you with a service or information that you have requested. For example, we will share information within the KCC Group where you enquire about their services through us or where you make a complaint to us and later make the same or similar complaint to them.
How long do we keep your information for?
We will not hold your personal information in an identifiable format for any longer than is necessary. If you are a customer or otherwise have a relationship with us we will hold personal information about you for a longer period than if we have obtained your details in connection with a prospective relationship.
If you are a customer, we hold your personal information for 6 years from the date our relationship ends, or 18 months from the last date of correspondence (whichever is the latter). We hold your personal information for this period to establish, bring or defend legal claims.
Where we have obtained your personal information following a request for information, quotation or any other information on any of our products or services, we hold your personal information for 18 months from the date we collect that information, unless during that period we form a relationship with you e.g. you become a customer or tenant. We hold your personal information for this period to give us an opportunity to form a relationship with you.
The only exceptions to the periods mentioned above are where:
- the law requires us to hold your personal information for a longer period, or delete it sooner;
- Where you have raised a legal claim, complaint or concern regarding a product or service offered by us, in which case we will retain your information for a period of 6 years following the date of that complaint or query;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further How can I manage the information we hold about you);
How can you manage the information we hold about you?
You have the right as an individual to access your personal information we hold about you and make corrections if necessary. You also have the right to withdraw any consent you have previously given us and ask us to erase information we hold about you. You can also object to us using your personal information (where we rely on our business interests to process and use your personal information).
You have a number of rights in relation to your personal information under data protection law. In relation to most rights, we will ask you for information to confirm your identity and, where applicable, to help us search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received any request (including any identification documents requested).
Under GDPR you have rights which you can exercise free of charge which allow you to:
- know what we are doing with your information and why we are doing it
- ask to see what information we hold about you (subject access request)
- ask us to correct any mistakes in the information we hold about you
- object to direct marketing
- make a complaint to the Information Commissioner’s Office
Depending on our reason for using your information you may also be entitled to:
- ask us to delete information we hold about you, provided we do not have any continuing lawful reason to continue to use and process that information;
- have your information transferred electronically to yourself or to another organisation
- object to decisions being made that significantly affect you
- object to how we are using your information
- stop us using your information in certain ways
We will always seek to comply with your request however we may be required to hold or use your information to comply with legal duties. Please note, your request may delay or prevent us delivering a service to you.
Further Information & Contact
If you would like any further information from us, or you wish to exercise any of your rights and/or manage your information, you can do this by contacting us using the following details:
By Post: Data Protection Officer, Gen² Property Ltd, Sessions House, County Road, MAIDSTONE, ME14 1XQ
By Email: firstname.lastname@example.org (please indicate that this is a data protection enquiry)
Phone: 03000 416888
For further information about your rights, including the circumstances in which they apply or if you are unhappy with Gen²’s treatment of your personal information, you may contact the Information Commissioners Office:
Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Phone: 0303 123 1113