No matter the type of property business you have, it is a legal requirement to be clear with your clients about what you plan to do with their personal information. The most effective way to do this is through a privacy notice, which you can display on your website and send to clients. Below, we take you through exactly what your privacy notice needs to include step-by-step to keep your property management business safe and your clients aware.DISCLAIMER: This ebook is intended for information only and does not constitute legal advice. If you have any questions related to issues in this ebook, we strongly advise contacting a legal professional.
Start with basic details
Begin with the name of your company, your postal address, telephone number and email address as well as website details if you have them. You should also make a note of the date you created the privacy notice, in case of any later amendments required.
Let people know what you're collecting
Personal data isn’t limited to things like phone numbers and addresses. As a basic definition, personal data means information by which a person is identifiable so it could include things like IP addresses and medical information. If creating a template, display all the types of personal data you have collected in list form.
Explain how you collect the data
Tell clients why you need to collect or hold their data and the legal basis for your right to do so. If you intend to share personal information with a third party, explain how and why you intend to do this.
You also need to include information about how a person can withdraw their consent for you to retain or pass on their personal information.
Describe how you will store it
Include a section confirming the information is securely stored and provide details on how long you intend to keep it for, then how you will safely and securely dispose of it.
Reference your clients' data protection rights
Your privacy notice needs to reference your clients’ rights under data protection law. It should detail:
- The right to access – the right to ask for copies of the personal information you hold.
- The right to rectification – the right to ask for information deemed inaccurate to be corrected and incomplete information to be completed.
- The right to deletion – the right to request the erasure of personal information under certain circumstances.
- The right to restriction of processing – the right to request restriction of the processing of personal information under certain circumstances.
- The right to object – the right to object to personal information being processed.
- The right to portability – the right to request data be transferred to another organisation or the client themselves in certain circumstances.
None of these services are chargeable.
Clarify your complaints process
You need to provide details of how clients can complain, both directly to your company, and also to the ICO (Information Commissioner's Office). Be sure to include the ICO’s address and telephone number.
For further information or detail on how to create an effective privacy notice, you can always refer directly to the ICO, which has a pre-prepared template. It is also worth regularly referring to their website to stay informed about amendments existing data protection requirements.