Welcome to Placefirst’s privacy notice.
Placefirst Limited and its group companies respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website at https://placefirst.co.uk (the “Website”) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy notice
The Website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity: Placefirst Limited
Name or title of data privacy manager: Sarah Hughes
Email address: [email protected]
Postal address: 6th Floor, Imperial Court, 2 Exchange Quay, Salford, M5 3EB
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of 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.
The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes name, date of birth and gender.
- Contact Data includes address, email address and telephone number.
- Financial Data includes bank account.
- Transaction Data includes details about payments to and from you, tenancy details and other details of properties you have rented from us.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.
- Profile Data includes your employment status, reference, salary, dependants and credit check record.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
- CCTV Data includes images and other data recorded on CCTV systems in place around our buildings.
We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We collect information about criminal convictions and offences as part of the application process for a tenancy.
If you fail to provide personal data
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.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an application for a tenancy on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies..
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers ;
- advertising networks; and
- search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as credit reference agencies that we may choose to use from time to time to assess an application for a tenancy.
- Identity and Contact Data from data brokers or aggregators such as property advertising websites.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
- CCTV Data from use of our fixed CCTV cameras outside our buildings.
4. 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.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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 where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To ensure that residents, staff and visitors to outside our buildings are safe||(a) CCTV||Necessary for our legitimate interests (for the prevention of crime and the safety of our residents, staff and visitors)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We include an opt-out on all marketing emails sent to you.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or entered into a tenancy through us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by emailing us or clicking an opt-out link in any marketing communication from us.
Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of the provision of our services including without limitation when you enter into a tenancy with us.
Change of purpose
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.
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.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
External Third Parties who are Touchsoft, Worldpay, Acquaint CRM, Van Mildert, Diamond Properties, PT_X Bottomline Technologies and Adiuvo.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We may disclose personal data to law enforcement authorities, insurers and in the course of litigation.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
7. Data security
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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
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:
(a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.
No fee usually required
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 may refuse to comply with your request in these circumstances.
What we may need from you
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may 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.
PLACEFIRST CCTV POLICY
1. Policy Statement
1.1 We believe that CCTV and other surveillance systems have a legitimate role to play in helping to maintain a safe and secure environment for all our staff, residents and visitors. However, we recognise that this may raise concerns about the effect on individuals and their privacy. This policy is intended to address such concerns.
1.2 Images recorded by surveillance systems are Personal Information which must be processed in accordance with data protection laws. We are committed to complying with our legal obligations and ensuring that the legal rights of staff, relating to their Personal Information, are recognised and respected.
1.3 This policy is intended to assist staff in complying with their own legal obligations when working with Personal Information and to help residents and visitors understand how we use CCTV.
- For the purposes of this policy, the following terms have the following meanings:
CCTV: means fixed and domed cameras designed to capture and record images of individuals and property.
Data: means information which is stored electronically, or in certain paper-based filing systems. In respect of CCTV, this generally means video images. It may also include static pictures such as printed screen shots.
Data Subjects: means all living individuals about whom we hold personal information as a result of the operation of our CCTV (or other surveillance systems).
Data Controllers: are the people who, or organisations which, determine the manner in which any Personal Information is processed. They are responsible for establishing practices and policies to ensure compliance with the law. Placefirst are the Data Controller of all Personal Information used in our business for our own commercial purposes.
Data Processors: are any person or organisation that is not a Data User that processes data on our behalf and in accordance with our instructions.
Personal Information: means data relating to a living individual who can be identified from that data (or other data in our possession). This will include video images of identifiable individuals.
Placefirst: means Placefirst Limited, a limited company incorporated in England and Wales with registered number 07071980 and registered address at 6th Floor, Imperial Court, 2 Exchange Quay, M5 3EB.
Processing: is any activity which involves the use of data. It includes obtaining, recording or holding data, or carrying out any operation on the data including organising, amending, retrieving, using, disclosing or destroying it. Processing also includes transferring Personal Information to third parties.
Surveillance Systems: means any devices or systems designed to monitor or record images of individuals or information relating to individuals. The term includes CCTV systems as well as any technology that may be introduced in the future such as automatic number plate recognition (ANPR), body worn cameras, unmanned aerial systems and any other systems that capture information of identifiable individuals or information relating to identifiable individuals.
3. About this policy
3.1 We currently use CCTV cameras to view and record individuals in and around our buildings. This policy outlines why we use CCTV, how we will use CCTV and how we will process data recorded by CCTV cameras to ensure we are compliant with data protection law and best practice. This policy also explains how to make a subject access request in respect of Personal Information created by CCTV.
3.2 We recognise that information that we hold about individuals is subject to data protection legislation. The images of individuals recorded by CCTV cameras in and around our buildings are Personal Information and therefore subject to the legislation. We are committed to complying with all our legal obligations and seek to comply with best practice suggestions from the Information Commissioner’s Office (ICO).
3.3 This policy covers all residents, our employees and contractors, and visiting members of the public.
3.4 This policy is non-contractual and does not form part of the terms and conditions (i) on which any resident occupies a property or (ii) of any employment or other contract between Placefirst and any of our employees or contractors. We may amend this policy at any time. The policy will be regularly reviewed to ensure that it meets legal requirements, relevant guidance published by the ICO and industry standards.
4. Personnel responsible
4.1 The board of directors of Placefirst has overall responsibility for ensuring compliance with relevant legislation and the effective operation of this policy. Day-to-day management responsibility for deciding what information is recorded, how it will be used and to whom it may be disclosed has been delegated to the Head of Resident Services. Day-to-day operational responsibility for CCTV cameras and the storage of data recorded is the responsibility of the Head of Resident Services.
4.2 Responsibility for keeping this policy up to date has been delegated to the Head of Resident Services.
5. Reasons for the use of CCTV
5.1 We currently use CCTV around our buildings as outlined below. We believe that such use is necessary for legitimate business purposes, including:
(a) to prevent crime and protect buildings and assets from damage, disruption, vandalism and other crime;
(b) for the personal safety of residents, staff, visitors and other members of the public and to act as a deterrent against crime;
(c) to support law enforcement bodies in the prevention, detection and prosecution of crime;
(d) to assist in day-to-day management, including ensuring the health and safety of staff and others;
(e) to assist in the effective resolution of disputes; and
(f) to assist in the defence of any civil litigation.
This list is not exhaustive and other purposes may be or become relevant.
6.1 CCTV monitors the exterior of the building and both the main entrance and secondary exits 24 hours a day and this data is continuously recorded.
6.2 Camera locations are chosen to minimise viewing of spaces not relevant to the legitimate purpose of the monitoring. As far as practically possible, CCTV cameras will not focus on private homes, gardens or other areas of private property.
6.3 Surveillance Systems will not be used to record sound.
6.4 Images are not actively monitored and recordings will generally only be viewed when an issue has been raised. Users of a building should always call 999 in the event of danger and should not assume that any person is monitoring the Surveillance Systems.
7. How we will operate any CCTV
7.2 We will ensure that live feeds from cameras and recorded images are only viewed by approved members of staff whose role requires them to have access to such data. Recorded images will only be viewed in designated, secure offices.
8. Use of data gathered by CCTV
8.1 In order to ensure that the rights of individuals recorded by the CCTV system are protected, we will ensure that data gathered from CCTV cameras is stored in a way that maintains its integrity and security. This may include encrypting the data, where it is possible to do so.
8.2 Video footage will be stored on site on a fixed server and will be protected by a private VPN. We will not store large quantities of video footage on the cloud. From time to time, certain video footage (for example footage relating to an incident) may be copied to another server and/or the cloud.
8.3 We may engage Data Processors to process data on our behalf. We will ensure reasonable contractual safeguards are in place to protect the security and integrity of the data.
9. Retention and erasure of data gathered by CCTV
9.1 Data recorded by the CCTV system will be stored digitally. Data from CCTV cameras will not be retained indefinitely but will be permanently deleted once there is no reason to retain the recorded information. Exactly how long images will be retained for will vary according to the purpose for which they are being recorded. For example, where images are being recorded for crime prevention purposes, data will be retained in respect of incidents that have come to light until the end of any investigation and/or prosecution. In all other cases, recorded images will be kept for no longer than 31 days. We will maintain a comprehensive log of when data is deleted.
9.2 At the end of their useful life, all images stored in whatever format will be erased permanently and securely. Any still photographs and hard copy prints will be disposed of as confidential waste.
10. Covert monitoring
10.1 We will never engage in covert monitoring or surveillance (that is, where individuals are unaware that the monitoring or surveillance is taking place) unless, in highly exceptional circumstances, there are reasonable grounds to suspect that criminal activity or extremely serious malpractice is taking place and, after suitable consideration, we reasonably believe there is no less intrusive way to tackle the issue.
11. Ongoing review of CCTV use
11.1 We will ensure that the ongoing use of existing CCTV cameras in the building is reviewed at least every 12 months to ensure that their use remains necessary and appropriate, and that any surveillance system is continuing to address the needs that justified its introduction.
12. Requests for disclosure
12.1 We may share data with other group companies and other associated companies or organisations, for example shared services partners where we consider that this is reasonably necessary for any of the legitimate purposes set out above in paragraph 1.
12.2 No images from our CCTV cameras will be disclosed to any other third party, without express permission being given by the Head of Resident Services. Data will not normally be released unless satisfactory evidence that it is required for legal proceedings or under a court order has been produced.
12.3 In other appropriate circumstances, we may allow law enforcement agencies to view or remove CCTV footage where this is required in the detection or prosecution of crime.
12.4 We will maintain a record of all disclosures of CCTV footage.
12.5 No images from CCTV will ever be posted online or disclosed to the media.
13. Subject access requests
13.1 Data Subjects may make a request for disclosure of their Personal Information and this may include CCTV images (a “Subject Access Request”). A Subject Access Request is subject to the statutory conditions from time to time in place and should be made in writing, in accordance with our subject access policy which can be requested from the Head of Resident Services.
13.2 In order for us to locate relevant footage, any requests for copies of recorded CCTV images must include the date and time of the recording, the location where the footage was captured and, if necessary, information identifying the individual.
13.3 We reserve the right to obscure images of third parties when disclosing CCTV data as part of a Subject Access Request, where we consider it necessary to do so.
14.1 If any resident or member of staff has questions about this policy or any concerns about our use of CCTV, then they should speak to the Head of Resident Services in the first instance.
15. Requests to prevent processing
15.1 If any resident or member of staff has questions about this policy or any concerns about our use of CCTV, then they should speak to the Head of Resident Services in the first instance.