- Policy prepared by: Gillian Cooke
- Approved by Board on 26th April 2018
- Next review date: 26th April 2020
In order to operate, Corporate Occupier Real Estate Consulting Limited (CORE Consult) needs to gather, store and use certain forms of information about individuals.
These can include contractors, suppliers, business contacts and other people the company has a relationship with or regularly needs to contact.
This policy explains how this data should be collected, stored and used in order to meet CORE Consult data protection standards and comply with the General Data Protection Regulations (GDPR).
This policy ensures that CORE Consult
- Protects the rights of employees and third parties
- Complies with data protection law and follows good practice
- Protect the company from the risks of a data breach
Data Protection Officer and their responsibility
The Data Protection Officer for Corporate Occupier Real Estate Consulting Ltd is Gillian Cooke. She is responsible for the secure, fair and transparent collection and use of data by CORE Consult. However, everyone who has access to data as part of CORE Consult has a responsibility to ensure that they adhere to this policy.
A regular review of all data will take place to establish CORE Consult still has good reason to keep and use the data held at the time of the review.
As a general rule a data review will be held approximately every 2 years. The next review will take place in April 2020.
It applies to all data that CORE Consult holds relating to individuals, including:
- Email addresses
- Postal addresses
- Phone numbers
In addition, data stored by CORE Consult may be retained if based on statutory requirements for storing data. This may include, but is not limited to:
- Details of payments made and received (e.g. in bank statements and accounting records)
- Contracts and agreements with suppliers/customers
- Insurance details
- Tax and employment records
DATA PROTECTION PRINCIPLES
a) We fairly and lawfully process personal data in a transparent way
CORE Consult will only collect data where lawful and where it is necessary for the legitimate purposes of the company.
b) We only collect and use personal data for specific, explicit and legitimate purposes and will only use the data for those specified purposes.
When collecting data CORE Consult will always provide a clear and specific privacy statement explaining to the subject why the data is required and what it will be used for.
c) We ensure any data collected is relevant and not excessive
CORE Consult will not collect or store more data than the minimum information required for its intended purpose.
d) We ensure data is accurate and up-to-date
CORE Consult will check and update their data on a regular basis.
e) We ensure data is not kept longer than necessary
CORE Consult will keep records for no longer than is necessary in order to meet the intended use for which it was gathered (unless there is a legal requirement to keep records) and will delete data within a reasonable period once it is no longer applicable.
f) We keep personal data secure
CORE Consult will ensure that data held by us is kept secure.
- Electronically-held data will be held within a password-protected and secure environment
- Physically-held data will be stored in a locked facility
When CORE Consult collects, holds and uses an individual’s personal data that individual has the following rights over that data. CORE Consult will ensure its data processes comply with those rights and will make all reasonable efforts to fulfil requests from an individual in relation to those rights.
- Right to be informed: whenever CORE Consult collects data it will provide a clear and specific privacy statement explaining why it is being collected and how it will be used.
- Right of access: individuals can request to see the data CORE Consult holds on them and confirmation of how it is being used. Requests should be made in writing to the Data Protection Officer and will be complied with free of charge and within one month. Where requests are complex or numerous this may be extended to two months
- Right to rectification: individuals can request that their data be updated where it is inaccurate or incomplete. CORE Consult will request that staff check and update their data on an annual basis. Any requests for data to be updated will be processed within one month.
- Right to object: individuals can object to their data being used for a particular purpose. CORE Consult will always provide a way for an individual to withdraw consent in all marketing communications. Where we receive a request to stop using data we will comply unless we have a lawful reason to use the data for legitimate interests or contractual obligation.
- Right to erasure: individuals can request for all data held on them to be deleted. CORE Consult data retention policy will ensure data is not held for longer than is reasonably necessary in relation to the purpose it was originally collected. If a request for deletion is made we will comply with the request unless:
- There is a lawful reason to keep and use the data for legitimate interests or contractual obligation.
- There is a legal requirement to keep the data.
- Right to restrict processing: individuals can request that their personal data be ‘restricted’ – that is, retained and stored but not processed further (e.g. if they have contested the accuracy of any of their data, CORE Consult will restrict the data while it is verified).
- Though unlikely to apply to the data processed by CORE Consult we will also ensure that rights related to portability and automated decision making (including profiling) are complied with where appropriate.
How we obtain consent
CORE Consult may collect data from consenting parties for marketing purposes from time to time. This can include contacting them to update them about company news and other activities.
Any time data is collected for this purpose, we will provide:
- A method for users to show their positive and active consent to receive these communications ( a ‘tick box’)
- A clear and specific explanation of what the data will be used for (e.g. ‘Tick this box if you would like CORE Consult to send you email updates with details about our forthcoming events ‘)
Data collected will only ever be used in the way described and consented to (e.g. we will not use email data in order to market third party products).
Every marketing communication will contain a method through which a recipient can withdraw their consent (e.g. an ‘unsubscribe’ link in an email).