1LET Privacy Notice (reviewed Dec 2022)
Being transparent and providing accessible information to individuals about how we will use their personal data is important for our organisation. Our Privacy Notice covers what information we collect, who is collecting it, how it is collected, why it is being collected, how it will be used, who it will be shared with, details of transfers to any third country and retention period.
The GDPR legislation replaces the Data Protection Act (1998) and gives more rights to you as an individual and more obligations to organisations holding your personal data.
One of the rights is a right to be informed, which means we have to give you even more information than we do now about the way in which we use, share and store your personal information.
How we use your information
This privacy notice tells you what to expect when 1LET collects personal information. It applies to information we collect about:
- visitors to our website
- information collected via our website forms: tenants, landlords, guarantors
- newsletter subscribers
- repairs and maintenance issues reported through our website
- job applicants, current employees, former employees
- complainants
Visitors to our website
When someone visits https://www.1let.co.uk we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. Lawful basis for processing: Consent. This means you have given clear consent for us to process any personal data to monitor website data. Our website is hosted on Hostgator’s servers in their CyrusOne datacentre based in the U.S.A and operates under the EU-US Privacy Shield. Our website is also https secure https://www.1let.co.uk
Information collected via website forms
When someone completes a form on www.1let.co.uk we use a third-party service, Formstack, to collect information in order to provide the services we offer. Formstack is based in the U.S.A and operates under the EU-US Privacy Shield. For more information please see below.
Link to Privacy Policy: https://www.formstack.com/privacy
Tenants
Personal Data Collected for tenants: Name, contact details (email and telephone), age, national insurance number, marital status, address, residential status, previous addresses, employment status, financial status, income details, financial references, proof of ID, credit checks, names and ages of any children to occupy the property, bank details. This personal data is collected via our Tenant Application Form. Lawful basis for processing: Contract. This means the processing is necessary for a contract you have with 1LET (in the form of a Tenancy Agreement).
Personal data of any tenant(s) renting a property through 1LET may be shared with the following third-party data processors:
1. Amiqus ID
Data provided: Name, DOB, Present home address, email address.
Purpose: to run basic credit checks on prospective tenants in line with our application process requirements.
Lawful basis for processing: Legitimate Interest. This means the processing is necessary for 1LET’s legitimate interests by way of reference checking any prospective tenants on behalf of the landlord before a tenancy is offered.
Link to privacy policy: https://amiqus.co/policies/privacy
2. SME Professional
Data provided: Name, contact details (email and telephone), age, address, residential status, bank details.
Purpose: property management software used for all tenant, landlord, contractor and guarantor communication. Facilitates the day-to-day running of our property/tenancy management services.
Lawful basis for processing: Legitimate Interest. This means the processing is necessary for 1LET’s legitimate interests. We use SME to hold all data relating to our property management services including tenants, guarantors, landlords and contractors.
Link to privacy policy: https://www.smeprofessional.co.uk/privacy-statement/
3. Pinstripe
Data provided: Name, contact details (email and telephone), address.
Purpose: To carry out checkin, inventories and risk assessments.
Lawful basis for processing: Legitimate Interest.
Link to privacy policy: https://www.pinstripe.services/privacy-policy
4. Signable
Data provided: Name, email address, telephone number, address of tenants and address of guarantors.
Purpose: to send electronic tenancy agreements for signature. Lawful basis for processing: Legitimate Interest. This means the processing is necessary for 1LET’s legitimate interests. We use Signable for all tenancy agreements requiring tenants and guarantors (where applicable) to sign.
Link to privacy policy: https://www.signable.co.uk/privacy-policy/
5. Deposit Provider
Data provided: Name, contact details (email and telephone), address rent and deposit amount, tenancy start date.
Purpose: Transferring of tenant’s deposit for duration of tenancy. 1LET currently use Safe Deposit Scotland.
Link to Privacy Policy: http://www.safedepositsscotland.com/privacy-policy
6. Just Move In
Purpose 1: Home Setup Services: Administration of transferring council tax, utilities, and media services to and from tenant(s) and landlord(s).
Data provided: Name, contact details (email and telephone), address. In the course of provision of the services we may also process move-to and move-from addresses, moving dates, tenancy details, council tax status, and other data required for the provision of those services (including data relating to other occupants or household members).'
Lawful basis for processing: Legitimate Interest. This means the processing is necessary for 1LET’s legitimate interests by way of transferring utilities, council tax, media services into the tenant’s name on behalf of the landlord.
Where a Tenant receives Home Setup Services provided by Just Move In for the purpose of fulfilling the contract for those services, we will need to also provide relevant personal data to Just Move In. Just Move In will store and be a controller of such personal data.
Just Move In (full company name Ethical introductions Ltd) provides a privacy notice describing their use of data, available here: Link to Privacy Policy: https://justmovein.com/privacy-policy
7. Approved Tradesmen
Purpose: to arrange repairs and maintenance.
Data provided: Name, contact details (email and telephone), address ofTenants rental property In situations where a tenant reports an issue and wants to be contacted by one of our tradesmen we will pass on contact details so they can be contacted.
Lawful basis for processing: Legitimate Interest. 1LET only instruct pre-approved tradesmen. We require all tradesmen to provide: relevant professional qualifications, relevant professional memberships, public liability insurance certificate, professional liability insurance certificate, signed service standards agreement and agreement with our Data Protection Policy.
8. Insurance Provider
Purpose: to provide a quotation for tenant contents insurance.
Data provided: Name, contact details (email and telephone), address of rental property
In situations where a tenant requests a quotation for insurance we will pass your details for Bruce Stevenson. Lawful basis for processing: Legitimate Interest.
Link to Privacy Policy: http://www.brucestevenson.co.uk/policies/privacy-policy/
Personal data of tenants will be held by 1LET for the length of the tenancy plus up to 7 years in line withHMRC requirements.
Landlords
Data collected: Name, contact details (email and telephone), address, rental property address, age, proof of ID, proof of address, proof of ownership, national insurance. This personal data is collected via our Landlord Form.
Lawful basis for processing: Contract. This means the processing is necessary for a contract you have with 1LET in order to provide you with the services you have requested 1LET. Personal data of Landlords will be shared with the following third-party data processors:
1. Amiqus ID
Purpose: to run basic identity and proof of ownership checks on prospective and current landlords.
Lawful basis for processing: Legitimate Interest. This means the processing is necessary for 1LET’s legitimate interests by way of identity and ownership checking. Data provided: Name, contact details
Link to privacy policy: https://amiqus.co/policies/privacy
2. SME Professional
Lawful basis for processing: Legitimate Interest. This means the processing is necessary for 1LET’s legitimate interests. We use SME to hold all data relating to our property management services including tenants, guarantors, landlords and contractors.
Data provided: Name, contact details (email and telephone), address, bank details.
3. Signable
Data provided: Name.
Purpose: to send electronic tenancy agreements for signature.
Lawful basis for processing: Legitimate Interest. This means the processing is necessary for 1LET’s legitimate interests. We use Signable for all tenancy agreements requiring tenants and guarantors (where
applicable) to sign.
Link to privacy policy: https://www.signable.co.uk/privacy-policy/
4. Justmovein
Purpose 1: Transferring of council tax and utilities into any tenant(s) name(s).
Data provided: Name, contact details (email and telephone), address
Lawful basis for processing: Legitimate Interest. This means the processing is necessary for 1LET’s legitimate interests by way of transferring utilities and council tax into the tenant’s name on behalf of the landlord.
5. RBS Bankline
Purpose: payroll; to pay employees/shareholder/directors; to receive payments from and make payments to tenants; to receive payments from and make payments to landlords; to pay invoices for third-party contractor services.
Personal data provided: Name, bank details
Lawful basis for processing: legitimate interest
Link to privacy policy: https://www.rbs.co.uk/global/cookieprivacy.ashx?channel=personal
6. Approved Tradesmen
Purpose: to arrange repairs and maintenance.
Data provided: Name, contact details (email and telephone), address of rental property
In situations where a landlord may want to be contacted by one of our tradesmen we will pass on contact details so they can be contacted.
Lawful basis for processing: Legitimate Interest.
1LET only instruct pre-approved tradesmen. We require all tradesmen to provide: relevant professional qualifications, relevant professional memberships, public liability insurance certificate, professional liability insurance certificate, signed service standards agreement and agreement with our Data Protection Policy.
8. Insurance Provider
Purpose: to provide a quotation for landlord contents and/or buildings insurance.
Data provided: Name, contact details (email and telephone), address of rental property
In situations where a landlord requests a quotation for insurance we will pass your details for Bruce Stevenson.
Lawful basis for processing: Legitimate Interest.
Link to Privacy Policy: http://www.brucestevenson.co.uk/policies/privacy-policy/
9. HMRC
Lawful basis for processing: Legal Obligation. This means the processing is legally required. We are required to provide necessary tax and income information to HMRC.
Data provided: Name, contact details (email and telephone), address, bank details, rental income
Personal data of landlords will be held by 1LET while in contract to provide services to the landlord plus up to 7 years in line with HMRC requirements.
Guarantors
Personal data collected via our Guarantor Form.
Lawful basis for processing: Contract This means the processing is necessary for a contract you have with 1LET (in the form of a Tenancy Agreement).
1. Amiqus ID
Purpose: to run basic credit checks on prospective tenants in line with our application process requirements.
Data provided: Name, DOB, Marital Status, Frequency paid, Income (salary), Residential Status, Present home address
Lawful basis for processing: Legitimate Interest. This means the processing is necessary for 1LET’s legitimate interests by way of reference checking any prospective tenants on behalf of the landlord before a tenancy is offered.
2. SME Professional
Purpose: property management software used for all tenant, landlord, contractor and guarantor communication. Facilitates the day-to-day running of our property management services.
Data provided: Name, contact details (email and telephone), address.
Lawful basis for processing: Legitimate Interest. This means the processing is necessary for 1LET’s legitimate interests. We use SME to hold all data relating to our property management services including tenants, guarantors, landlords and contractors.
3. Signable
Purpose: to send electronic tenancy agreements for signature
Lawful basis for processing: Legitimate Interest. This means the processing is necessary for 1LET’s legitimate interests. We use Formstack for all tenancy agreements requiring tenants and guarantors (where applicable) to sign. Data provided: Name, email address, telephone number, address of tenants and address of guarantors.
Link to privacy policy: https://www.signable.co.uk/privacy-policy/
Personal data of guarantors will be held by 1LET while in contract to provide services to the landlord plus up to 7 years in line with HMRC requirements.
Neighbours
Data collected: Name, contact details (email and telephone), address, address. This personal data may be collected via correspondence with neighbours regarding any issues related to properties we manage.
Personal data of neighbours will be held securely in Outlook365 where correspondence is via email or may be held in our property management software named below where notes are required to be kept
Other forms
Personal Data collected via other forms including Landlord Pack Download, Viewing Request, Rental Valuation Requests and other contact requests.
Lawful basis for processing: Legitimate Interest. This means the processing is necessary for 1LET’s legitimate interests by way of providing information as requested or enabling us to provide services before a contractual relationship has been established.
Data provided: Name, contact details (email and telephone), address.
Repairs and maintenance issues reported through our website
When a tenant reports a maintenance and repair issues using via http://www.1let.co.uk/repairs/ we use a third-party service called Fixflo. This company is a data processor for 1LET and only processes personal information in line with our instructions.
Lawful basis for processing: Legitimate Interest. This means the processing is necessary for 1LET’s legitimate interests by way of managing repairs and maintenance.
Data collected: Name, contact details (email and telephone), address.
Newsletter subscribers
We use a third-party provider, Mailchimp, to deliver our monthly e-newsletters and property alerts. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter. For more information, please see Mailchimp’s Privacy Notice.
Lawful basis for processing: Consent. This means you have given clear consent to us in order to receive our e-newsletter. If you choose to unsubscribe your information will be removed from the system.
Link to privacy policy: https://mailchimp.com/legal/privacy/
People who call our office
When you call 1LET we may collect your name, email and telephone contact solely for the purposes of your call. We only keep this information for as long as necessary and will store this information on our calendar and/or email provided by third-party email provider Outlook365.
Lawful basis for processing: Legitimate Interest. This means the processing is necessary in order to provide information as requested by you or enabling 1LET to provide services requested by you before a contractual relationship has been established.
People who email us
Any emails received containing personal data will be held within Outlook365. These emails will only be held for as long as is required – for example if you are an existing tenant we will hold this until at least the end of your tenancy and potentially longer - where required by law. If you are a prospective tenant and do not proceed with a tenancy your personal information will be deleted and removed from our system. We check for and remove such information on a monthly basis. We monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.
Lawful basis for processing: Legitimate Interest. The processing is necessary for 1LET’s legitimate interests by way of providing information to you as requested by you or enabling us to provide services before a contractual relationship has been established.
Job applicants
Data collected: Name, contact details (email and telephone), address, CV.
Lawful basis for processing: Legitimate interest. Personal data of prospective employees will be held for no longer than one month of being informed of an unsuccessful application or within one month of related vacancy being filled. We do not hold speculative CV’s or enquiries on our system.
Current employees
All employees are asked to read and sign our employee privacy notice detailing how we process employee personal data and to read and sign our Data Protection Policy detailing how we process customer data safely and securely.
All personal data of employees will be held securely on our server and HR cloud-based software for as long as they are employed and for at least seven years thereafter, for legal, regulatory and accounting purposes.
Former employees
We use a third-party provider, to hold all employee information. Information may also be held securely on our office server and in emails held on Outlook365.
Personal data held: Name, contact details (email and telephone), age, national insurance number, marital status, address, salary details, proof of ID and bank details.
Sensitive Personal data held: physical or mental health condition, All personal data of employees will be held securely on our server and HR cloud-based software for as long as they are employed and for at least seven years thereafter, for legal, regulatory and accounting purposes.
Complainants
When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle. Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
Retention Period
Personal data of landlords and tenants will be held for the length of the tenancy and for at least seven years thereafter, for legal, regulatory and accounting purposes.
Personal data of prospective tenants who do not proceed with a tenancy will be removed and deleted from our system within 1 month of any tenancy starting at the related property and any hard copy information shredded.
All personal data of employees will be held on PeopleHR or securely on our server for as long as they are employed and for at least seven years thereafter, for legal, regulatory and accounting purposes.
Personal data of prospective employees will be held for no longer than one month of being informed of an unsuccessful application or within one month of related vacancy being filled. We do not hold speculative CV’s or enquiries on our system.
Personal data for previous and tenants, guarantors and landlords will be held during use our services (or whilst we providing services connected) and for at least seven years thereafter, for legal, regulatory and accounting purposes.
If we need to hold on to your personal data for longer, we take into consideration the potential risks in continuing to store your data against why we might need to keep it.
Subject’s Rights
1LET shall take appropriate measures to provide any information relating to processing to the data subject in a concise, transparent, intelligible and easily accessible form, using clear and plain language.
If you have any questions please contact Ken Bell, ken@1let.com