Martin’s Management Services Limited GDPR Data Protection Policy
In this notice, Martin’s Properties includes Martin’s Management Services Limited and all entities within the control of the Martin Family, including its parent companies, fellow subsidiaries, limited liability partnerships and trusts. “We”, “us” or “our” refers to Martin’s Management Services Limited and entities within the control of the Martin Family.
Martin’s Management Services Limited is committed to being transparent about how it collects and uses the personal data of its stakeholders, and to meeting its data protection obligations. This policy sets out the organisation’s commitment to data protection, and individual rights and obligations in relation to personal data. This policy applies to the personal data of, employees, former employees, contractors, suppliers, customers, tenants, former tenants & job applicants.
We have appointed a compliance officer as the person with responsibility for data protection compliance within the organisation. The compliance officer can be contacted at email@example.com if you have any questions about this policy, or requests for further information.
“Personal data” is any information that relates to a living individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.
“Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.
“Criminal records data” means information about an individual’s criminal convictions and offences, and information relating to criminal allegations and proceedings.
Data protection principles
We process personal data in accordance with the following data protection principles:
- We process personal data lawfully, fairly and in a transparent manner.
- We collect personal data only for specified, explicit and legitimate purposes.
- We process personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
- We keep accurate personal data and take all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
- We keep personal data only for the period necessary for processing.
- We adopt appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.
We tell individuals the reasons for processing their personal data, how we use such data and the legal basis for processing. We will not process personal data of individuals for other reasons. Where we rely on our legitimate interests as the basis for processing data, we will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals.
We will update personal data promptly if an individual advises that his/her information has changed or is inaccurate.
As a data subject, individuals have a number of rights in relation to their personal data.
Subject access requests
Individuals have the right to make a subject access request. If an individual makes a subject access request, we will tell him/her:
- whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
- to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
- for how long his/her personal data is stored (or how that period is decided);
- his/her rights to rectification or erasure of data, or to restrict or object to processing;
- his/her right to complain to the Information Commissioner if he/she thinks we have failed to comply with his/her data protection rights; and
- whether or not we carry out automated decision-making and the logic involved in any such decision-making.
We will also provide the individual with a copy of the personal data undergoing processing if requested to do so by the individual. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.
To make a subject access request, the individual should send the request to firstname.lastname@example.org. There is a standard form of request available and individuals should contact the compliance officer for this. In some cases, we may need to ask for proof of identification before the request can be processed. We will inform the individual if we need to verify his/her identity and the documents we require.
We will normally respond to a request within a period of one month from the date it is received.
If a subject access request is manifestly unfounded or excessive, we are not obliged to comply with it. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which we have already responded. If an individual submits a request that is unfounded or excessive, we will notify him/her that this is the case and whether or not we will respond to it.
Individuals have a number of other rights in relation to their personal data. They can require the organisation to:
- rectify inaccurate data;
- stop processing or erase data that is no longer necessary for the purposes of processing;
- stop processing or erase data if the individual’s interests override our legitimate grounds for processing data (where the organisation relies on our legitimate interests as a reason for processing data);
- stop processing or erase data if processing is unlawful; and
- stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual’s interests override our legitimate grounds for processing data.
To ask us to take any of these steps, the individual should send the request to email@example.com.
We take the security of personal data seriously. We have internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties.
Where we engage third parties to process personal data on our behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
If we discover that there has been a breach of personal data that poses a risk to the rights and freedoms of individuals, we will report it to the Information Commissioner within 72 hours of discovery. We will record all data breaches regardless of their effect.
If the breach is likely to result in a high risk to the rights and freedoms of individuals, we will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures we have taken.
International data transfers
We will not transfer personal data to countries outside the European Economic Area.
Individuals are responsible for helping us keep their personal data up to date. Individuals should let us know if data provided to us changes, for example if an individual moves house or changes his/her bank details.
If an individual believes that we have not complied with his/her data protection rights, he/she should raise the issue firstly with our Compliance Officer. If this does not resolve their concern they may complain to the Information Commissioner (https://ico.org.uk/).