This document describes how and why I collect, store, protect, process and share the data given to me.
- Jim Culverwell is the Data Controller. This means I am ultimately responsible for the personal data I hold.
- Contact Address: The Garden House, Teak Cottage Alresford Hampshire SO24 0HB
The personal data I will collect
- The contact details of my clients
- Contact details of my clients’ agents, associates or clients (as provided by my clients or from other public or investigative sources)
- Details of services required or provided
The reason I will process personal data
- I collect personal data to allow me to provide the commercial property consultancy services outlined in my terms of business.
My legal basis for processing personal data
- The processing of any personal data is carried out as part of the contract the client has with me to provide the Agreed Services (GDPR Article 6(1)(b)).
- The processing of the personal data of my clients is carried out as a legitimate interest of Jim Culverwell the Premises Mentor and of my clients (GDPR Article 6(1)(f)).
Who I may share personal data with
- Business associates and other professional advisers (eg solicitors)
- Associates of the person whose personal data I am processing
- Suppliers and service providers
- Ombudsmen and regulatory authorities
- Central government
The rights of the people whose data I process
The people whose personal data I process have the following rights that are applicable to my business:
- To be informed – they have a right to be told that I am processing their data. This right however does not apply if they already have the information I am processing or being informed would ‘render impossible or seriously impair’ my purposes for processing it
- Access – they have a right to confirmation that I am processing their data, a copy of their personal data and other supplementary information
- Rectification – they have a right to have inaccurate personal data corrected
- Erasure – they have a right to have their personal data erased, providing there are no reasons for this right not to apply (eg for the establishment, exercise or defence of legal claims)
- Portability – they have a right to obtain and reuse their personal data for their own purposes across different services
- To object – they have the right to object to the processing of their personal data in certain circumstances
If you want exercise any of your rights, please contact me at firstname.lastname@example.org
How long I keep personal data
- After I have finished the use for which it was being processed (e.g. as a live case or current client) I destroy most personal data after 2 years. Some personal data may however be retained for up to 7 years (current financial year plus 6) in line with the Limitation Act 1980.
How data is stored and processed?
- Personal data are stored in electronic and hard copy formats. Electronic records are protected by encryption, anti-hacking and anti-virus technologies. Hard copy documents are stored in appropriate containers and in locations to which access is restricted.
If you’ve already told me I need to do something, but I haven’t responded in a way that you’re satisfied with, you can complain to the Information Commissioner’s Office (the ICO).
It’s easiest to do this online via the ICO website https://ico.org.uk/concerns/handling/ , but you can also do so in writing to:
The Information Commissioner’s Office
Cheshire SK9 5AF