The Company’s business is property development and estate management which provides commercial premises to let to its clients and businesses. The Company must process personal data so that it can provide these services – in doing so, the Company acts as a data controller.
You may give your personal details to the Company directly, such as on an application to rent, a formal lease or job application or we may collect them from other sources. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work or premises to rent we will only use your personal data in accordance with the terms of the following statement.
1. Collection and use of personal data
a. Purpose of processing and legal basis
The Company will collect your personal data and will process your personal data for the purposes of providing you with work (if you are an employee or contractor) or for entering into lease arrangements for the properties owned by the Company. The legal bases we rely upon to offer these services to are:
· Consent
· Legitimate interest
· Legal obligation
· Contractual obligation
b. Legitimate interest
Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
· Offering employment or engaging contractor services or renting properties or space
c. Recipient/s of data
The Company will process your personal data with the following recipients:
· Property professionals engaged including lawyers, property agents, banks or accountants
d. Statutory/contractual requirement
Your personal data is required by law and/or a contractual requirement and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are:
An inability to offer you work or engaging in any contractual arrangement with you.
1. Overseas Transfers
The Company may transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) where back-up data is held on cloud-based systems, or when using proprietary on-line accountancy software or when using Microsoft 365 based software. Specifically –
data backups are held on Microsoft One Drive Cloud storage;
the on-line accountancy software used is Quick Books Online;
Microsoft 365 Office products are used
In all cases where such cloud based or on-line software is used, transfers will only be made where the Commission has decided that a third country, a territory or one or more specific sectors in the third country, or an international organisation ensures an adequate level of protection, or where the organisation receiving the personal data has provided adequate safeguards. Individuals’ rights must be enforceable and effective legal remedies for individuals must be available following the transfer
.
2. Data retention
The Company will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time details of which are found in our GDPR Policy.
3. Your rights
Please be aware that you have the following data protection rights:
· The right to be informed about the personal data the Company processes on you;
· The right of access to the personal data the Company processes on you;
· The right to rectification of your personal data;
· The right to erasure of your personal data in certain circumstances;
· The right to restrict processing of your personal data;
· The right to data portability in certain circumstances;
· The right to object to the processing of your personal data that was based on a public or legitimate interest;
· The right not to be subjected to automated decision making and profiling; and
· The right to withdraw consent at any time.
Where you have consented to the Company processing your personal data you have the right to withdraw that consent at any time by contacting the company.
4. Automated decision-making
The company does not use automated decision-making, including profiling.
5. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: the data officer.
You also have the right to raise concerns with Information Commissioner’s Office or at https://www.inforights.im, or any other relevant supervisory authority should your personal data be processed outside of the IOM, if you believe that your data protection rights have not been adhered to.