Spofforth Park Management Company, making Spofforth Park a delightful place to live

PRIVACY NOTICE

  1. Introduction
    This Privacy Notice explains how personal data relating to leaseholders, freeholders, and residents is handled in connection with the management of the property or development in which you hold an interest. It is issued in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
    We take your privacy seriously. This notice sets out what data is held about you, why it is held, who holds it, and what your rights are.
  2. Who is the Data Controller?
    The freeholder or residents’ management company (as applicable) acts as the Data Controller for the purposes of UK GDPR. As Data Controller, we determine the purposes for which personal data is processed.
    We do not directly hold, store, or process your personal data ourselves. All personal data is held and processed exclusively by our appointed Data Processor on our behalf.
  3. Our Data Processor
    Personal data relating to residents, leaseholders, and freeholders is held and processed by our appointed managing agent:
    Data Processor Pure Block Management
    Role Appointed Managing Agent / Data Processor
    Contact Please contact Pure Block Management directly for all data-related queries.
  4. Transfer of Data from Previous Managing Agent
    Personal data was previously held by Residential Management Group Ltd, who acted as managing agent prior to the appointment of Pure Block Management. Upon the change of managing agent, all relevant personal data held by Residential Management Group Ltd was transferred to Pure Block Management in accordance with applicable data protection law.
    This transfer was necessary to ensure continuity of management services and to enable Pure Block Management to fulfil its obligations as managing agent. The transfer was carried out on a lawful basis and subject to appropriate data processing safeguards.
  5. What Personal Data is Held?
    The personal data held by Pure Block Management on our behalf is strictly limited to that which is necessary for the following two purposes:
    5.1 Service Charge Administration
    Data held for the purpose of administering service charges may include:
    • Name and contact details of leaseholders and freeholders
    • Correspondence address and, where provided, email address
    • Leasehold title information and lease dates
    • Service charge account details, demands issued, and payment records
    • Arrears information and any associated correspondence
    5.2 Compliance with Covenants in the TP1
    Data held for the purpose of monitoring and enforcing compliance with covenants contained within the TP1 (the standard Land Registry transfer form setting out the terms, restrictions, and obligations on the transfer of the freehold or leasehold) may include:
    • Name and contact details of the property owner or occupier
    • Property address and title number
    • Records of covenant compliance correspondence and notices
    • Details of any reported or observed breaches and actions taken
    • Communications relating to enforcement or remediation of covenant obligations
    No other categories of personal data are held or processed in connection with the management of this development.
  6. Lawful Basis for Processing
    The processing of personal data is carried out on the following lawful bases under UK GDPR Article 6:
    Lawful Basis Purpose
    Contract (Article 6(1)(b)) Processing necessary for the performance of the lease agreement and to fulfil obligations relating to service charges.
    Legal Obligation (Article 6(1)(c)) Processing required to comply with legal obligations under the Landlord and Tenant Act 1985 and associated legislation.
    Legitimate Interests (Article 6(1)(f)) Processing necessary for the enforcement of covenants in the TP1, to protect the amenity and value of the development and the interests of all residents.
  7. How Long is Data Retained?
    Personal data will be retained by Pure Block Management only for as long as is necessary to fulfil the purposes for which it was collected, or as required by law. In practice:
    • Service charge records and related correspondence are typically retained for a minimum of six years from the end of the relevant accounting period, in line with the Limitation Act 1980.
    • Covenant compliance records are retained for as long as the relevant property interest exists and for a reasonable period thereafter.
    • Data transferred from Residential Management Group Ltd will be subject to the same retention standards.
  8. Who May Data Be Shared With?
    Personal data will not be sold or shared for commercial purposes. Data may be disclosed to third parties only where strictly necessary, including:
    • Solicitors, surveyors, or other professional advisers engaged in connection with service charge disputes or covenant enforcement
    • Insurers, where required in connection with the buildings insurance policy
    • The Upper Tribunal (Lands Chamber) or other courts and tribunals, where legal proceedings are necessary
    • Regulatory bodies or law enforcement agencies, where required by law
    • Successor managing agents, in the event of a further change of managing agent
    All third parties with whom data is shared are required to handle it in compliance with UK GDPR.
  9. Your Rights Under UK GDPR
    You have the following rights in relation to your personal data:
    Right of Access You may request a copy of the personal data held about you (a Subject Access Request).
    Right to Rectification You may request that inaccurate or incomplete data be corrected.
    Right to Erasure You may request deletion of your data, subject to legal retention obligations.
    Right to Restrict Processing You may request that processing of your data be restricted in certain circumstances.
    Right to Object You may object to processing based on legitimate interests.
    Right to Data Portability You may request your data in a structured, machine-readable format where technically feasible.
    Right to Complain You have the right to lodge a complaint with the Information Commissioner’s Office (ICO).
  10. How to Exercise Your Rights
    As personal data is held exclusively by Pure Block Management, all requests to exercise your data protection rights, including Subject Access Requests, should be directed to Pure Block Management in writing.
    Pure Block Management is required to respond to requests within one calendar month of receipt, in accordance with UK GDPR. No charge will be made for reasonable requests.
  11. The Information Commissioner’s Office (ICO)
    If you believe your data protection rights have not been respected, you have the right to make a complaint to the UK’s supervisory authority:
    Information Commissioner’s Office
    Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
    Helpline: 0303 123 1113
    Website: www.ico.org.uk
  12. Updates to This Notice
    This Privacy Notice may be updated from time to time to reflect changes in the law, the management arrangements, or our processing activities. The current version will always be made available to residents and leaseholders upon request. The date at the top of this notice indicates when it was last reviewed.
    This notice is issued in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.