Privacy Policy
RLMH Ltd (company number: 03872383) Commercial Property Developers and Hudsons Building Contractors & Joiners (“we” or “us” or “our”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
From 25th May 2018 there will be changes to data privacy law in the UK which will apply to all. This Privacy Notice explains why we collect personal data, what personal data we collect, how we use it and your rights.
The following definitions apply in this policy:
"Legitimate Interest" means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us on the details within this policy.
"Performance of Contract" means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
"Comply with a legal obligation" means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how we collect and process your personal data through your use of our website or by contracting with us in general, including any data you may provide through our website or otherwise during the contractual process with us.
This website and our goods./services are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
RLMH Ltd (company number: 03872383) is the controller and responsible for your personal data.
The information we collect about you and how we collect it:
Data Collected:
NameHome addressPhone numberEmail addressDate of birthTradeCompany registration number (CRN)Registered AddressNational Insurance numberUnique tax reference (UTR)Tax CodeBank sort code & account numberSub Contractors (Bona Fide)Self Employed workersTenants - existing and prospective
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How we collect data
For Sub-contractors - we obtain this information direct from you when you commence work for us a sub contractor. Occasionally information such as a national insurance number or UTR number will be obtained from HMRC.
For Self Employed workers - we obtain this information direct from you when you commence work.
For Tenants - we obtain this information prior to the commencement of your tenancy. If your tenancy is arranged through a Lettings Agent, we will have access to some or all of this information via their portal, or as part of our agreement with them.
We also collect data, where possible, from various publically available sources.
Why we collect and retain this information and how we use your personal data:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: where we need to perform the contract we are about to enter into or have entered into with you; where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or where we need to comply with a legal obligation. We can also use your personal data where it is necessary for our legitimate interests (including but not limited to: the running of our business and/or to recover debts due to us for example).
More specifically, we collect, retain and use your personal data as follows:
Sub contractors – the information held is kept to enable us to contact the sub contractor to offer work and to receive details of work completed from the sub contractor, and to pay for such works direct into the sub contractor’s bank account. The email address is necessary to communicate about any issues relating thereto, as is the telephone number. It is a requirement of HMRC that a monthly return for any payments made to sub contractors is made and for this we have to provide, names, UTR numbers and national insurance numbers.
Self Employed workers - this information is kept so we can pay you for the work you undertake and email your pay slip where requested, we can contact you in an emergency and so we can send communications by post.
Tenants - existing and prospective – information is sought and held on the basis of performance of a contract, and so to enable us to prepare Lease Agreements, invoices and invoice payments and other general day to day email, telephone and postal communications. We have a lawful basis for collecting and holding personal information for the following reasons: passing the names of new tenants to utility companies, seeing references which were provided to the letting/ managing agent, disclosing details of a tenant who has vacated leaving rent arrears to a tracing agent or debt collector to help us recover the debt, passing on forwarding addresses of former tenants to utility companies, providing tenants contact details to repairers if work needs to be carried out, notifying other joint tenants of any rent arrears owed by another tenant, informing the guarantor where the tenant has failed to pay rent.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
By providing us with your personal data, you agree us processing it in the manner described.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us on the details within this policy. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We do not transfer your personal data outside of the European Economic Area.
Security measures - storing your data:
We will take all necessary steps to ensure that your data is held securely. Anti virus software is installed on computers used by the Company, all online programs and documents are password protected. Paper records are stored in locked cabinets and/ or a locked office. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long we have had your information and how long it is likely to be kept:
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are set out in this section below:
For Sub contractors and Self employed workers - your personal data will have been provided to us at the commencement of your contract with us. We will keep your information indefinitely as, due to the nature of our work, it is possible that we may wish to use your services in the future at another of our building sites and if so, we will want to be able to readily contact you. Furthermore, HMRC require us to retain records for 6 years after the current financial year has ended.
For tenants – some or all of your personal data will have been provided to us at the commencement of your tenancy with us. We will keep your information for up to 1 year after a failed tenancy application, and for up to 7 years after the expiry of the tenancy agreement if accepted. Leases will be retained indefinitely as we may be required to refer to the original lease for legal reasons.
For both Sub contractors and Self employed workers – if you do not want us to keep your information after the 6 year period mentioned above, please let us know. Our contact details are in the ‘Contact Us’ section of this website.
Who will we share your information with:
Solicitors appointed by and acting of behalf of RLMH Ltd and HMRC. With the exception of HMRC, we will not share your information with anybody unless we have your express consent.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see ‘your rights’ below for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your rights:
You have the right to complain to the ICO (Information Commissioners Office), the UK supervisory authority for data protection issues (www.ico.org.uk) if you feel we have concerns about the way we are handling your data. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are as follows:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us on the details set out within this policy.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Changes to our privacy policy:
Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back to see any updates or changes. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Contacting us:
If you have any questions about this Privacy Policy or the way we handle your personal information, please contact us at the address/details in the ‘Contact Us’ section of this website.