Data Processing Notice

1. INTRODUCTION

This notice explains what information we collect, when we collect it and how we use this. During the course of our activities, we will process personal data (which may be held on paper, electronically, or otherwise) about you and we recognise the need to treat it in an appropriate and lawful manner. The purpose of this notice is to make you aware of how we will handle your information.

2. WHO ARE WE

ASN Capital group and associated companies (‘ASN Capital’) whose data is processed and held by ASN Capital Ltd, and listed below:

ASN Capital Ltd
ASN Capital Investments Ltd
ASN Capital Construction Ltd
ASN Capital Lettings Ltd
ASN Capital Group Ltd
ASN Capital Project Alpha Ltd
ASN Capital Project Beta Ltd
ASN Capital Project Gamma Ltd
ASN Capital Colehill Ltd

We take the issue of security and data protection very seriously and strictly adhere to guidelines published in the General Data Protection Regulation (EU) 2016/679 which is applicable from the 25th May 2018, together with any domestic laws subsequently enacted.

We are notified as a Data Controller with the Office of the Information Commissioner under registration number Z1774526 and we are the data controller of any personal data that you provide to us.

Any questions relating to this notice and our privacy practices should be sent to:

ASN Capital Ltd, 528 Wimborne Road, Bournemouth, BH9 2EX

Or office@asncapital.com

3. HOW WE COLLECT INFORMATION FROM YOU AND WHAT WE COLLECT

We collect information about you:

From any application forms you complete and submit to us
From any application or credit check forms you complete with our appointed subcontractors which are subsequently shared with us
From any applications for accommodation you make to a landlord other than ASN Capital that relate to a property we own and/or manage
From any correspondence or requests for information you submit to us in writing, by telephone, by email, in person, via our website, via social media, via apps or any other means
From recorded and monitored CCTV systems that are under our control
From recordings of telephone calls made to us or by us
From analytical data generated by tracking cookies and pixels on our websites and emails

4. WHAT INFORMATION WE COLLECT

The extent of information we collect about you will be determined by the nature of your application or enquiry with us, but may include the following:

Customer name, e-mail address, telephone number, date of birth, address (including any previous addresses), marital status, National Insurance number, nationality, next of kin, name of university or college where you are studying (if applicable), the name of friends that you are staying with (if applicable), relevant medical / disability information;
Guarantor or referee name, e-mail address, telephone number, date of birth, address (including any previous addresses), marital status, National Insurance number, nationality, next of kin (if applicable);
Employee / applicant name, e-mail address, telephone number, date of birth, address (including any previous addresses), marital status, National Insurance number, nationality, next of kin, relevant medical / disability information, photographs, uniform information, driving licence details, pension information, details of relevant criminal convictions and employment history;
Property address; term, rent, deposit, utility and service responsibilities;
The employment status of tenants and/or guarantors, address, contact details (including email, phone and fax numbers) of the employer/accountant, payroll numbers, length of employment, salary information (including any regular overtime or commission), and any other income received;
Bank account details of the customer / employee, including account number and sort code, and any hire purchase/loan agreements/credit cards or store cards that you have;
Any welfare benefits that you may be eligible for, or are currently on;
Images and video recordings of your activity and property that fall within range of a CCTV system under our control; and
Audio recordings of the content of telephone calls made to or from ASN Capital telephone numbers.
Statistics relating to website usage, referring websites, opening of emails and advertising conversions.

5. WHY WE NEED THIS INFORMATION ABOUT YOU AND HOW IT WILL BE USED

We need your information and will use your information:

to undertake and perform our obligations and duties to you in accordance with the terms of our contract with you;
to enable us to supply you with the services and information which you have requested;
to help you to manage your tenancy/property;
to carry out due diligence on any prospective tenant or employee, including as appropriate whether there is any money judgements against them, or any history of bankruptcy or insolvency;
to analyse the information we collect so that we can administer, support and improve and develop our business and the services we offer;
to contact you in order to send you details of any changes to our services which may affect you;
to comply with statutory requirements connected with the services applied for or provided to you;
to enable us to monitor the quality of services provided to you and communication made with you;
to assist with the training and performance monitoring of staff during their provision of services to you and communication made with you;
to assist with the prevention and detection of crime;
to assist in ensuring the safety of residents and visitors to properties under our control; and
for all other purposes consistent with the proper performance of our operations and business.

The information you provide to us will be treated by us as confidential and will be processed only by us and any third party, acting on our behalf. We may disclose your information to other third parties for the purposes set out in this notice or for purposes approved by you, including the following:

If we enter into a joint venture with or merged with a business entity, your information may be disclosed to our new business partners or owners;
If ownership of a property to which your contract relates your information may be disclosed to the new owners or their appointed agents;
To carry out due diligence on you as a prospective tenant / customer / guarantor, including but not limited to the carrying out of affordability checks, due diligence checks and the obtaining of references from relevant parties, whose data you have provided;
If you request so, your information shall be disclosed in order to determine if there are any money judgements against you, as the prospective tenant / customer / guarantor, or to determine if you have a history of bankruptcy or insolvency;
If you are unable to make payments that fall due under your agreements or contracts with us, your information may be disclosed to any relevant party assisting in the recovery of this debt or the tracing of you;
In the creation, renewal or termination of the tenancy / agreement / contract with us, your information will be disclosed to the relevant local authority, tenancy deposit scheme administrator, service/utility provider, freeholder, factor, facilities manager or any other relevant person or organisation in connection with this;
In the management of our business we may share your information with our bank, prospective bank or other finance provider; and
Where we consider doing so would assist in the prevention and detection of crime we may share your information with the police or any other statutory authority with a remit to investigate the crime concerned.
Where we consider doing so would assist in protecting the physical or mental health and welfare of you or another person for whom we have a duty of care.

Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.

7. TRANSFERS OUTSIDE EUROPE

We may transfer your information outside the EEA:

Where our third party service providers and/or subcontractors have data storage or processing facilities located outside the EEA.

Where information is transferred outside the EEA, we will ensure that there are adequate contractual and/or statutory safeguards in place to protect your information to an equivalent standard under this notice as if it were kept within the EEA.

8. SECURITY

When you give us information we take steps to make sure that your personal information is kept secure and safe.

We ensure physical records are kept in secure locations with access limited to personnel with an operational need to access the information.
We ensure electronic records are kept on systems which are up to date with relevant security precautions.
We ensure electronic records are stored in encrypted format where reasonably practicable.
We ensure access to electronic records is restricted to personnel with an operational need to access the information.
We ensure personnel are trained on data security practices.

9. HOW LONG WE WILL KEEP YOUR INFORMATION

We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you.

Information relating to applications and credit checks, that do not proceed to contract.	1 year after application is made.
Information relating to tenancy agreements, occupation of a property, contracts, deposits, transaction data.	7 years after the last financial transaction or relevant correspondence connected with the contract, or 15 years after the end of the contract (whichever is later).
Information relating to employment contracts	7 years after the end of employment or relevant correspondence connected with the contract, or 15 years after the end of the contract (whichever is later).
Information relating to contracts executed as deeds.	13 years after the last financial transaction or relevant correspondence connected with the contract, or 15 years after the end of the contract (whichever is later).
Information relating to unsubscribed marketing records	1 year after the unsubscribe request.
Video CCTV recordings	1 year after the recording is made.
Telephone recordings	1 year after the recording is made.

Where more than one classification applies to a piece of information the longest retention period will apply. In the case of an investigation or incident, the relevant information will be retained for an extended period as reasonably determined by ASN Capital.

Some data may be held for longer than these periods whilst it is pending review to ensure that data that is required for a longer period (i.e. relating to ongoing long term contracts, etc) is not inadvertently deleted automatically. In some cases retention periods will be shorter than those listed above due to limitations of the equipment and services used.

Data will normally be checked for retention at 6 monthly intervals, so each of the retention periods specified above may be extended by up to 6 months until the next scheduled deletion.

10. YOUR RIGHTS

You have the right at any time to:

ask for a copy of the information about you held by us in our records;
require us to correct any inaccuracies in your information;
make a request to us to delete what personal data of yours we hold; and
object to receiving any marketing communications from us.

If you would like to exercise any of your rights above please contact us at office@asncapital.com

Should you wish to complain about the use of your information, we would ask that you follow the complaints procedure published on our customer support website.

You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information. The Information Commissioner’s contact details are noted below:

Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113
Email: casework@ico.org.uk