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Privacy Notice Guardians

Privacy Notice Guardians

How your information will be used

1. Introduction 
Ad Hoc Property Management Limited is a part of Ad Hoc International BV which includes Ad Hoc Licensee Ltd and Ad Hoc Property Owners Ltd. This Privacy notice explains how we use any personal information we collect about you when you register as a Property Guardian (also known as a Licensee) via our website or on any of our property portals.

2. What information do we collect about you?

  • As your trusted provider for temporary accommodation under our Guardianship Scheme, Ad Hoc Property Management Ltd process and retain information about you for processing your license. In order for us to manage your account efficiently, lawfully and appropriately during your induction, whilst you reside in any our properties or when your license agreement terminates.
  • We collect information about you when you register with us or via our website. We also collect information when you voluntarily complete customer surveys, provide feedback and participate in competitions.
  • This includes using information to enable us to comply with any legal requirements, pursue the legitimate interests of the Company and protect our legal position in the event of legal proceedings. If you do not provide this data, we may be unable in some circumstances to comply with our obligations and we will tell you about the implications of that decision.

3. How will we use the information about you? 
Personal information which you supply to us during the application may be used in a number of ways, for example:

  • The Provision of a Licence agreement
  • For Fraud Prevention
  • For audit and debt collection
  • For statistical analysis
  • For health and safety reasons
  • Property Owners
  • Law enforcement agencies such as the UKBA or police
  • Public Authorities

The legitimate interests given here are not exhaustive and only includes some of the most common uses. The Company will notify you in writing should any new legitimate interest not already covered by the given example arises. We will never process your data where these interests are overridden by your own interests.

We may pass your personal information to our group of companies, which includes our Dutch parent company, so that they may offer you their products and services, subject to your agreement. Ad Hoc will not share your information for marketing purposes with companies outside the Ad Hoc Group, unless we have your explicit consent or for legitimate business purposes.

In processing your application, we may send your information with and obtain information about you from, credit reference agencies, DBS, UKBA or fraud prevention agencies.

The sort of information we hold includes your application form and references, your License Agreement and any amendments to it such as License Fee Increases; correspondence with or about you, for example letters to you about your deposit contact and emergency contact details; records of any warnings for breaches issued, information collected for monitoring Guardian demographics, email addresses for surveys and marketing purposes for example. 

You will, of course, inevitably be referred to in many company documents and records that are produced by our staff in the course of carrying out their duties and the business of the company. You should refer to the Data Protection Policy which is available on our website.

Where necessary, we may keep information relating to your health, which could include medical assessments after an accident in one of our buildings. This information will be used in order to comply with our health and safety and occupational health obligations – to consider how your health affects your suitability to be a Guardian and whether any adjustments to your Unit might be appropriate. We will also need this data to administer and manage statutory Health and Safety Executive (HSE) reporting.

Where we process special categories of information relating to your racial or ethnic origin, political opinions, religious and philosophical beliefs, , biometric data or sexual orientation, we will always obtain your explicit consent to those activities unless this is not required by law or the information is required to protect your health in an emergency. Where we are processing data based on your consent, you have the right to withdraw that consent at any time.

Other than as mentioned below, we will only disclose information about you to third parties if we are legally obliged to do so or where we need to comply with our contractual duties to you, for instance we may need to pass on certain information to our insurers, contractors or the police.

We may transfer information about you to other group companies for purposes connected with your agreement or the management of the company’s business.

In limited and necessary circumstances, your information may be transferred outside of the EEA or to an international organisation to comply with our legal or contractual requirements. Where necessary, we would only transfer data outside of the EEA to an organisation of entity that provides the following safeguards;

  • a legally binding and enforceable instrument between public authorities or bodies;
  • Binding Corporate Rules;
  • standard contractual clauses adopted by the European Commission;
  • standard contractual clauses adopted by the supervisory authority and approved by the European Commission;
  • approved codes of conduct; and
  • approved certification mechanisms.

We do use automated decision making (including profiling) in limited circumstances including shortlisting during our recruitment process. The logic behind this would to be to only identify and shortlist candidates who meet the minimum requirements to become a Guardian such as only accepting applicants who are over the age of 18 at the time of applying into the scheme. The consequences of this logic is that a candidate who may be 18 could be excluded from the shortlist of Guardians to contact if the selection tools or system fails to pick up the age entered correctly or a potential Guardian has made an error on the online application.

Your personal data will be stored for a period required by law for current and former Guardians for tax purposes or the criteria used for determining how long your data will be based on current legislation.

If in the future we intend to process your personal data for a purpose other than that which it was collected we will provide you with information on that purpose and any other relevant information.

4. Marketing 
We would like to send you information about products and services of ours and other companies in our group which may be of interest to you. If you have consented to receive marketing, you may opt out at a later date. You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the Ad Hoc group. If you no longer wish to be contacted for marketing purposes, please contact your local Ad Hoc branch.

5. Access to your information and correction
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to our Data Protection officer (see final page for details). We may make a small charge for this service. We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.

6. Other websites
Our website contains links to other websites. This privacy notice only applies to this website so when you link to other websites you should read their own privacy policies.

7. Changes to our privacy policy
We keep our privacy policy under regular review and we will place any updates on this web page.

Your rights

1. Under the General Data Protection Regulation (GDPR) and The Data Protection Act 2018 (DPA) you have a number of rights with regard to your personal data. You have the right to:

  • request from us access to and rectification or erasure of your personal data;
  • the right to restrict processing, object to processing as well as in certain circumstances the right to data portability.

2. If you have provided consent for the processing of your data you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn. 

3. You have the right to lodge a complaint to the Information Commissioners’ Office if you believe that we have not complied with the requirements of the GDPR or DPA 18 with regard to your personal data. 

4. How to contact us

AD HOC PROPERTY MANAGEMENT LITD is the controller and processor of data for the purposes of the DPA 18 and GDPR.
If you have any concerns as to how your data is processed you can contact our Data Privacy Manager as follows: 

Data Privacy Manager:
Sharan Sidhu
HR Department
Ad Hoc Property Management Ltd.
Unit 20 & 21 Angel Gate City Road London EC1V 2PT

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