Privacy notice for tenants

‘Rothesay’ is the trading name for Rothesay Life Plc, an insurance company established in the UK with company registration number 06127279 and ICO registration Z1003678. We are authorised in the UK by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Our registered office address is The Post Building, 100 Museum Street, London WC1A 1PB.

This privacy notice applies to all situations where we process personal data about any individual that is a tenant in a residential property that we directly or indirectly own. We assign a property manager to each residential property that we own and that property manager is responsible for the day-to-day management of the property, including assisting you with any issues that may arise from time to time.

We are a controller under data protection laws. This means that we are trusted to look after and deal with your personal information in accordance with this notice. We determine the ways and means of processing your data and must therefore, be accountable for it. We take this responsibility very seriously.

This privacy notice contains information about:

• The personal data that we process as a controller
• Where the personal data has been obtained
• The reasons why we process your personal data and the lawful basis we use to do so
• The security measures that we have in place to keep your personal data secure
• The length of time we store your personal data for
• The organisations, or categories of organisation, with whom we might share your personal data
• International transfers of your personal data
• The rights you have under data protection laws in relation to our processing of your personal data

Please note that we may change this privacy notice from time to time.

To request a printed copy of this privacy notice please contact us using the contact details contained in the part of this privacy notice headed Contact details.

The categories of personal data we process include the following:

1. Tenant personal information: Data relating to each tenant in residential property that we directly or indirectly own. Data includes:

• Name
• Date of birth
• Marital status
• Address of property
• Contact details (including phone number and email address)
• Financial information such as salary or assets

2. Tenancy information: Data relating to the tenant's tenancy agreement and properties. Data includes:

• Amount of rent due to be paid under the tenancy agreement
• Property value and rental value
• Tenancy start date and end date
• Additional information – if you are in breach of the terms of your tenancy agreement, we may obtain more information about the breach (including any reason for such breach) from the property manager in order to determine what action to take.

3. Sensitive personal data: Where necessary and permitted under data protection laws. For example, if you breach the terms of your tenancy agreement, then we might process your personal data in order to review your circumstances in the context of determining what action should be taken. This may involve processing your sensitive personal data, such as health information.

Personal data will usually be collected from you by the property manager who manages the property in which you are a tenant.

The table below provides details of the purpose and the lawful bases upon which we process personal data.

You can object to our processing of your personal data on the grounds of legitimate interests. See the section headed Your rights to find out how.

We may also process personal data including sensitive personal data where permitted by data protection laws. For example, in the event that you breach the terms of your tenancy, we might need to process sensitive personal data such as health information as part of reviewing your circumstances and determining what action the property manager should take. We will generally only process such personal data where necessary for the establishment, exercise or defence of legal claims, where necessary for the prevention or detection of unlawful acts, or where otherwise permitted by data protection laws.

Our commitment to corporate security is demonstrated through the implementation of policies, controls and procedures, which are externally certified and audited to the international information security standard, ISO 27001:2013.

Our security policies, controls and procedures are regularly reviewed and updated so that we maintain good practices across our business to keep your information safe.

We have contractual arrangements in place with all of our service providers who process personal data which are compliant with data protection laws. We regularly check that our service providers are complying with their contractual commitments. This includes assessing and reporting on our service providers’ information security controls to check their compliance using questionnaires and/or on-site audits.

We will only keep your personal data in an identifiable format for so long as we reasonably require it for the purposes for which we process your personal data (as described above), unless a longer period is required by law and, In any event, we will only keep your personal data for as long as our internal rules and polices allow us to fulfil our business or legal and regulatory obligations. This will usually be six years after the date of termination of the tenancy agreement.

We share personal data with a variety of other companies to operate our business. However, we only share the personal data where necessary to help us satisfy one or more of the reasons for processing set out above.

We have detailed the types of companies with whom we currently share personal data below. The companies fall into two categories.

Processors with whom we share personal data

For these companies, we determine the purposes for which the personal data we pass to them is processed and they should not process that personal data other than in accordance with our written instructions. Processors with whom we share personal data:

1. IT service providers

Our main IT infrastructure and core software is provided by Goldman Sachs Group, Inc.. This means that personal data we process is stored on Goldman Sachs’ IT systems.

2. Other service providers to our business

Other companies who process personal data on our behalf include those who provide day-to-day operational business services such as emails, archiving, document scanning and copying, document destruction and printing.

Controllers with whom we share personal data

For these companies, we do not determine the purposes for which the personal data we pass to them is processed once it is shared. To understand how the other controllers process your personal data , you should refer to their privacy notices. Controllers with whom we share personal data:

1.  Property related service providers

We engage a number of companies to provide services relevant to our investments in properties, including property managers, investment managers, asset managers, property valuation companies, auditors and due diligence providers.

2.  Group entities

We will sometimes need to share personal data with entities within our corporate group for administrative purposes and as part of our internal financing arrangements.

3.  Other property investors

If we decide to sell our interests in a property to another investor, we may share basic information about the properties, tenants and tenancies to enable the new investor to evaluate the property it is looking to acquire.

4.  Professional advisers

We sometimes have to share personal data with our professional advisers (including accountants and lawyers) where it is required for the purposes of their advice.

5.  Regulators, law enforcement and auditors

We will share personal data when requested or required by Regulators, Law enforcement agencies or other third parties, including to comply with obligations imposed on us by laws and regulations

Where personal data is transferred to and processed in a country outside of the UK or the EEA (as applicable), we take steps to provide appropriate safeguards to protect your personal data, including by entering into approved standard contractual clauses obliging recipients to protect your personal data and only transferring personal data to the extent that an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data is ensured in compliance with data protection laws.

If you want further information on the specific mechanisms used by us when transferring your personal data outside of the UK or EEA, please contact us using the details contained in the part of this privacy notice headed Contact details.

Under certain circumstances, you have the following rights under data protection law:

• The right of access to personal data relating to you (known as Subject Access Requests)
• The right to correct any mistakes in your personal data
• The right to require us to delete your personal data
• The right to restrict our processing of your personal data
• The right to object to us processing your personal data, including for marketing purposes
• The right to have your personal data provided to another controller

How to exercise your rights

If you wish to exercise any of your rights, please contact us using the details contained in the part of this privacy notice headed Contact details.

Any queries regarding your tenancy should in the first instance be directed to the property manager. The contact details for your property manager can be found on the contract documentation that you received from them.

How to contact us regarding this privacy notice

You may want to contact us to:

• Ask any questions you have in relation to the information contained in this privacy notice
• Exercise any of your rights under the data protection laws
• Request a printed copy of this privacy notice printed in large print or braille
• Request an audio version of this privacy notice
• Make a complaint (see below)

To contact us you can email our Data Protection Officer (DPO) at dpo@rothesay.com or write to:

Data Protection Team, Rothesay Life Plc, The Post Building, 100 Museum Street, London WC1A 1PB

How to make a complaint

If you have a problem or concern relating to the ways we process your personal data or the contents of this privacy notice, please contact us in the first instance.

We hope that we will be able to address the problem or concern to your satisfaction. However, you also have the right to make a complaint to the Information Commissioner’s Office. The process for making a complaint to the Information Commissioner’s Office is available here: 

www.ico.org.uk/make-a-complaint

Their contact details are as follows:

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

Or phone: 0303 123 1113

ico.org.uk