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Privacy Policy


                        This notification is made by Abraham Adam and Co Ltd for itself and for its clients 

Data Controller:

The data controller responsible for your information is Abraham Adam and Co Limited. You can contact us online at [email protected] or by post at 173 Upper Tooting Road London SW17 7TJ, if you have any questions or complaints regarding our use of your information. As a data controller we are registered with the Information Commissioner's Office, and our registration number is Z2869414.

What this Notice is about

This Privacy Notice tells you what information we obtain and hold about you whether you are initially applying to us for a tenancy or if you become a tenant, resident or guarantor,it explains what information we collect, why we collect it, and what we do with it, as well as who we share it with. We collect and handle personal information about our tenants and residents and prospective tenants and residents along with any guarantors to enable us to provide residential accommodation. This includes dealing with applications for tenancies, checking the suitability of tenants, residents along with any guarantors (including credit, immigration andsimilar referencing checks), arranging lettings, property management (including dealing with repairs), rent collection, dealing with any complaints, maintaining our accounts and records, tenancy terminations and administering tenancy deposits.


We call this information"your information”. It is also referred to as "data”.


Where this notice is given to more than one person it is given to each of you separately.


If there is no guarantor, please disregard any reference in this notice to guarantor or guarantee.


You should read this notice when you give us information so you are aware of how and why we are using this. Please update us if any information supplied by you changes.


Why we are giving you this notice


We are required by data protection law to give you this notice.We must be open with you about why information is collected about you and then what is done with it. We must act fairly in relation to this information.You have various legal rights relating to this information which are spelt out in more detail in this notice.


If you are already a tenant, resident or guarantor some of the items in this notice may not be relevant toyou. Different information will be involved depending on whether you are a tenant, resident or guarantor.


In order that we can collector use information about you there must be a legal basis or gateway for doing so. This notice identifies the relevant gateway for the various types of information we collect and hold about you. A detailed explanation of these gateways is given in this notice.


Under data protection legislation we can only process data "as necessary” and only to the extent that it is needed. For example, we can use your bank details regarding payments and other limited purposes only. However, in certain instances, as necessary,we can share any of your data, e.g. with our own professional advisers or letting and managing agents. We may also share any of your data, as necessary, with the police/law enforcement agencies or regulatory authorities.


References to a tenant in this notice also include a guarantor if there is one. This is because a guarantor underwrites a tenant’s obligations so references to your tenancy are to include your guarantee.



The data we collect/hold about you


We use different ways to collect data about you including the information you supply to us when applying for a tenancy/residency. If you fail to provide this information we may not be able to proceed.


As necessary personal data is processed by us relating to tenants/ prospective tenants/ residents/prospective residents/ guarantors consisting of the following as applicable: -

·Identity and contact details

·Personal/background information including occupation/status

·Bank details

·Verification and credit status

·Deposit(if any) including return on tenancy termination

·Tenancy details including renewals, joint tenants, other residents and guarantors

·Immigration/right to rent checks (England only)

·Rent and other payments

·Recovery of arrears, claims or possession proceedings

·Repairs/health and safety/housing conditions

·Breach of tenancy terms/nuisance/anti social behaviour

·Council Tax liability

·Water charges payable

·Utilities and services provided

·Welfare Benefits

·Termination of tenancy

·Audio and CCTV recordings (if any)



·Emails texts and other communications and via our website where we operate one.

·Website and online portal information.

We also generate and use data internally, e.g. our rent records.


We also collect and receive data about you from third parties. This may be information given to us by other tenants or residents or neighbours. It can include information from a guarantor where there is a guarantor for your tenancy or from a joint tenant or other residents. Public bodies such as local authorities or the police, or other law enforcement agencies may give us information about you. This can include the Department for Work and Pensions or the local authority where you are receiving Universal Credit or housing benefit. Information may be given to us relevant to Council Tax by the local authority. Utility companies or service providers may also give us personal information about you. Where the property is let or managed on our behalf by an agent the agent will supply us with information about you. We obtain information about you when we carry out credit checks or take up references. We may also receive information from you via websites or from online rental portals such as Openrent, Gumtree or Rightmove. Any information which we receive in this way is set out in the Table to this privacy notice which gives you more details about information which we can receive from third parties.


Sharing data with others


We will share information we hold with others, where this is necessary.When we do this, we must comply with data protection legislation. Information can be shared with other landlords including where you apply to another landlord for a tenancy; contractors/suppliers; utilities and service providers; trades people; financial organisations (including banks and insurance companies); debt collection and tracing agents; public and government bodies (including those who administer benefits, such as the Department for Work and Pensions or the local authority);courts; police and law enforcement agencies; taxation authorities; local authorities in relation to Council Tax and regulatory functions; letting and managing agents; and any future owner of the property. We may need to share information with your next of kin etc., e.g. in an emergency. It may be necessary for us to share information with a future owner of the property if we are selling. We also may share information with professional advisers such as lawyers and accountants or an advice agency which involves sharing information about you with them. If you live in a flat we give information to the freeholder, managing agent etc., for the block of flats. We also send notifications to and have correspondence with any tenancy deposit scheme protecting any tenancy deposit which has been paid. In some cases, we may be under a legal obligation to provide information either because of the law or because of a contractual obligation binding on us. What we share will depend on what is necessary in the circumstances and more details are given in the Table in respect of different kinds of information which we hold about you.


Joint tenants and guarantors


Where you have a tenancy jointly with someone else or there is a guarantor for your tenancy, as necessary, we will share information either with the joint tenant or the guarantor (or both). This relates to your performance of your responsibilities under the tenancy agreement including information about any rent arrears or other breach of the tenancy terms. It can also relate to issues around the termination of the tenancy and any claims we may have as a result.

Immigration/right to rent checks


By law, in England, we are required to check your immigration status before we rent a property to you. This means that you are legally obliged to produce certain documentation (e.g. a passport or driving licence)to us. This applies whether or not you are a UK or EU citizen. Not only are we required to see original documentation but we must take and keep copies of it. We also check this documentation as part of our process to verify your identity at the outset of the tenancy. Prospective tenants and all adult residents who will live at the property must be checked.

Search engines, websites, etc


As necessary, we obtain information about you which is publically available via search engines such as Google or Facebook and websites. This will include information about you which you yourself made public. Further details are set out in theTable. However, when doing so we make sure that we comply with applicable guidelines under data protection legislation.




In cases where you rent aproperty where a child resides, information will be given to us about resident children; usually by an adult such as a parent on their behalf. Data protection law requires us to give such information additional protection where we collect or use it. In particular, where the rented property is located in England, we need to check on the age of any residents to see whether or not an immigration/right to rent check must be carried out.


Obligation to process data


Private renting is highly regulated so we are under various legal obligations. These include an obligation to carry out gas safety checks under gas safety legislation. We may need to handle data for this purpose,e.g. to give the contracted gas safety engineer access to the property. In line with Information Commissioner advice, we will pass over details of your occupancy to the relevant Water Company to enable them to collect water charges as it is in their legitimate interests to receive this information.


Legally we must also hold and process information relating to any tenancy deposit which you pay to us including sharing your information with a deposit scheme by which any deposit is protected.


Under any statutory licensing schemes applicable to the property we may be required to give information to the local housing authority relating to your occupation of the property. Similarly, there are various regulatory requirements which may mean that we need to give information aboutyou to public or local authorities or other regulatory authorities.





Again, in line with advice from the Information Commissioner we consider that it is in the legitimate interests of utility companies to receive information about occupants of the property to enable them to bill you for utilities (unless these are included within your rent).


Council Tax


Likewise, we notify local authorities of your occupancy relevant to the collection of Council Tax. In any event they are entitled to serve notice upon us requiring this information if they choose to do so.


Why we collect data and the legal basis for processing your personal data


We must tell you why we collect and hold information about you.


We must also have a legal basis before we are allowed to collect or process your personal data. Processing personal data includes recording,storing, altering, using, sharing or deleting data. We only need one of these "gateways” and for our purposes they are –


·You consent. Consent may be requested in certain cases, e.g. to obtain a reference but generally wedo not rely on your consent to process your personal data.

·To perform our contract so that we can carry out our responsibilities under the tenancy agreement with you, including anything you request us to do with a view to you becoming a tenant (or resident).

·Compliance by us with a statutory or other legal obligation.

·Where this is in your vital interests, e.g. if there is a life-threatening situation.

·Where we are pursuing our own legitimate interests or those of a third party. This will not apply if our interests are overridden by your interests or your fundamental rights and freedoms. We must carry out a balancing exercise therefore to decide whether we can rely on this gateway to ensure that it applies. In each case we have done this and we do not consider your interests, rights or freedoms outweigh our own or those of the third party concerned.


This notice identifies the relevant gateway applicable in each case. In some cases, we will rely on more than one gateway depending on the particular purpose for which we are using your data.


Additionally, any data must be processed by us fairly and openly.

Why we process your data


The various purposes for which it may be necessary for us to process various categories of your information include: -


·In our legitimate interests for deciding on the suitability of a proposed tenant/resident

·In our legitimate interests for verifying the credit worthiness/suitabilityof tenants/residents

·Our legal obligation to check immigration status/right torent. This is also to verify identities.;

·To perform our tenancy contract to deal with joint tenants and residents who are linked to the tenancy

·To perform our contract to complete the tenancy agreement

·In our legitimate interests to secure rental payments/performance of tenant obligations, e.g. deposits and guarantors

·For contractual performance for rent collection and collection of other payments including banking details

·For contractual performance for managing the tenancy and the property

·For contractual performance and/or in our legitimate interests for record keeping

·For contractual performance for arranging repairs and maintaining the condition of the property and keeping it in a safe condition.

·For contractual performance for monitoring and enforcement of tenant responsibilities

·For contractual performance or in our legitimate interests for recovering debts and other payments due, including any possession proceedings

·In our legitimate interests for administering liability for Council Tax

·Our legal obligation (in the Welsh Water area) or otherwise in our legitimate interests and those of the Water company for the payment of water charges

·In our legitimate interests and those of the provider relating to arranging and paying for utilities and services

·In our legitimate interests for dealing with welfare benefits (including Universal Credit and housing benefit) where payable in respect of the rent

·In our legitimate interests in relation to tenancy termination including the return of any deposit

·In our legitimate interests for processing complaints

·For contractual performance or in our legitimate interests for dealing with health and disability issues relating to tenants/residents

·In our legitimate interests for obtaining and holding audio and cctv recordings

·To perform our legal obligations to provide information to public or local authorities who are legally entitled to require thisinformation

·In our legitimate interests for the storage of emails, records of calls and other communications

·In accordance with our legal obligations if you exercise your rights under data protection law

·To perform our legal obligations for compliance with legal and regulatory requirements

·In our legitimate interests for the establishment and defence of legal rights

·In our legitimate interests for prevention, detection and investigation of crime and anti social behaviour and the security of anywebsite or other means of electronic communication


We may change the purposes where this is compatible for the purpose for which we obtained the data originally. If we need to use your data for a non-compatible purpose we will notify you and explain the legal gateway that allows us to do so. We may process your information without your knowledge where this is required or permitted by law.


More information about what we do with data and why,along with the relevant legal gateway is given in the Table. This also tells you who we share data with and receive it from.


Retaining Communications


We may monitor, record and retain your calls, emails,text messages, and other communications.This is in our legitimate interests to maintain an accurate record of these. This may be necessary to manage your tenancy or the property or to deal with your application for a tenancy or to deal with tenants/residents or prospective tenants/residents/guarantors. We need these records for our ongoing dealings with you, including our data protection obligations.


Length of storage of data


Data can only be stored on a time limited basis and not indefinitely.We will hold personal data about you for the duration of your tenancy and for seven years after your tenancy has ended.This is the statutory limitation period six years plus a further year to allow for service of proceedings should proceedings commence later. We are also required to retain information for up to six years for tax purposes. If your tenancy application does not go ahead then we retain data for one year.


Storage and security of data


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 ordisclosed. In addition, we limit accessto 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.


All our information is stored securely electronically on servers or devices. Certain information is also retained on a secure basis in hard copy format.


Telephone calls


To protect our legitimate interests telephone conversations may be recorded electronically for monitoring and to ensure that we have a record of what is said. You or others may leave messages when calling.




When we install CCTV, this is for security purposes in cases where we consider that it is in our legitimate interests to carry out such monitoring which must be done in accordance with legal requirements. We may also use CCTV to detect breaches of the tenancy terms, e.g. in the common parts or outside the building. Recordings will be kept for these purposes.


Information legally required under your tenancy agreement


Your tenancy agreement provides that in certain situations you must give us information when asked. This is a legal obligation because it is a contractual requirement.You should refer to the relevant clauses in your tenancy agreement which tell you the situations in which such information must be given.


Holding data outside the European Union


Our email account and webprovider is Webcreation Ltd. Our email account is web based. Providers store related data internationally and not necessarily within the EuropeanUnion. The recipient of this data is the provider concerned. You need to refer to the provider concerned to determine if they have the required clearance (adequacy decision) from the EU authorities or whether or not, instead, there is an agreement containing appropriate and suitable safeguards and to obtain a copy of this agreement.


Your rights


Where we hold personal data about you, you are the data subject. Data protection legislation gives you a number of rights.To exercise any of these rights you should contact us. You can do so by email at the address given above or you can telephone us on the number given above. You can also write to us at our address given at the top of this notice. Normally nofee is payable.


In particular you have a right to object to the processing of your information where we are processing this in our own legitimate interests or those of someone else.This applies if you feel that this impacts on your own interests or your fundamental rights or freedoms.


These rights are as follows –


·Access – you have the right to make a request to be told what personal data we hold about you. This is a right to obtain confirmation that data has been processed and to have access to your personal data and the right to information details which should be provided with the privacy notice.

·Correction/Rectification – if you consider any data we hold about you is inaccurate you can tell us so that where appropriate this can be corrected. Where a mistake is made in data processing then you can ask to have it rectified. Any third parties who have received the data from us should then be told of the rectification and you should be informed by us of any such third parties.

·Erasure – you have a right to ask us in certain circumstancesto erase any data we hold about you (the so called right to be forgotten). Individuals can request the right to have personal data erased to prevent processing in specific circumstances, i.e. it is no longer necessary, consent has been withdrawn, there is an objection and where applicable your rights etc.,override the legitimate interests to continue our processing, or data has been unlawfully processed.

·You can object to our processing of data – this allows you toobject to our processing of data about you.We must then stop processing data unless we can establish legitimate reason for continuing. In particularthis applies where we are relying on our own legitimate interests or those of a third party to process data but it can also apply in other situations.

·Restricting processing – you can ask us to suspend processing of your personal data and we must then restrict processing of data. This includes where you are contesting the accuracy of a statement or the lawfulness of the processing.

·Data portability – this allows individuals to reuse their personal data for their own purposes across different services allowing them to move, copy or transfer personal data more easily.


Withdrawal of consent


Where your consent provides us with the legal gatewayto process data about you you can withdraw this at any time by telling us byemail or post using the telephone/addresses given above.




We operate our own internal complaints policy and ifyou have any concerns about the way in which we collect or handle data pleasecontact us.


Additionally, you have the right to lodge a complaintwith the Supervisory Authority who is –


InformationCommissioner's Office
Wycliffe House
Water Lane




About this Table

As necessary, we collect,use and otherwise process different categories of information (data) about yourelying on the various legal gateways available to us. This relates to your application for atenancy/residency and, if this goes ahead, so that we can manage the tenancy andthe property along with associated matters.This part of this notice gives you a general description of theseprocessing activities for the different categories of information and thepurposes for which we process your information.If you consider that we have not given sufficient details of what we dothen you can make an access request for more information.




Renting out residentialaccommodation and managing tenancies and rental properties is a multifaceted. As tenants and residents are atthe centre of this service, we must process your data for a large number ofdifferent purposes. Data protection lawrequires us to give you information about these processing activities asconcisely as possible. To do so we havesplit information about you into different categories, which is in line withrequirements in the legislation. We alsohave to tell you the extent for which your information can be used andshared. Due to the nature of ourbusiness information falling into one category will be combined withinformation in other categories to be handled by us as permitted for the statedpurposes under the relevant legal gateway which we have to identify. For example, information about youridentity/contact details will be combined with other categories of informationto correctly identify you, e.g. when we compile our accounts or passinformation about a repair over to a contractor so that they can deal with theproblem at the property you rent.However, we only do this to the extent that it is necessary in thecircumstances.


Expressions used


To make this Table asconcise as possible we employ a number of expressions –


Handle information – collecting, compiling, using or storing information(data).


Use information – when we use information this means we consult it, compileit, refer to it to make a decision, or act on it, or combine it with otherdata. When using it in this way we mayhave to alter it.


Share data – this includes transferring data to someone else where thisis necessary, or receive it from a third party.


Collect data – this is where we receive information either from you, e.g.when you sign a tenancy application form or from a third party, e.g. areference about you.


Compile data – this is where we use information about you which we have collectedto generate information about you, e.g. our rent payment records or repairrecords.


Next of kin etc. – this includes close relatives.


Altering Data


We are required by dataprotection legislation to keep your information up to date and it is of coursein our own legitimate interests to do so for us to ensure that we have accuraterecords. For example, we keep our recordof your rent payments up to date as they are received.


Storing Data


We keep information bothelectronically and in a manual filing system to maintain our records. We do this because we need to use it fromtime to time. Normally the legal gatewaypermitting us to do so which will apply will be the same as applies when we usethe data. Additionally, however, thereare legal obligations to retain data under data protection law, taxationlegislation and housing law. We alsoneed to do so to fulfil our contract with you.In our own legitimate interests, we also need to retain information todeal with enquiries or disputes and for audit purposes.


Destruction of Data

We delete/destroy data onceit is no longer needed. This is arequirement of data protection law. Thisnotice tells you the period for which we normally store data.

What this Table tells you


Information is handled as necessaryfrom time to time. As already stated,information falling under one category can be amalgamated with or added toinformation in another category in order to carry out the stated purposes.

Part 1 of this Table tellsyou, depending on the relevant category of your information, what ourprocessing activities are and what is the legal gateway permitting processing aswell as the purpose for which we carry out these processing activities.


Where the legal gateway inquestion is our own legitimate interests (or those of a third party) weidentify the relevant legitimate interests.


Details about sharing dataare set out in Part 2, whether we transfer it to someone else or receive from athird party.


Part 1 – Collecting, compiling, using and storing yourinformation


In this Part we list out thedifferent categories of your information, briefly explain them where needed,explain what we do with the information and why, as well as specifying therelevant legal gateway we rely on to do so.


We use the word "handle” tocover collecting, compiling, using or storing this information.

Identity and contact details


1.This includes name, contact details, date of birth andnational insurance number

2.We handle this information in order to enter into the tenancyagreement and subsequently to manage the tenancy and the property. This is done to perform the contract.


Personal and background information


1.This includes details of the tenant’s present residence andtheir current landlord (if any), current occupation and status, employed,student etc., employer or educational institution, state benefits received,details of other residents, any bankruptcy or county court judgments, next ofkin etc., pets and any photographs of yourself.

2.This information is handled to evaluate your suitability as atenant. This is done for our ownlegitimate interests. These are toensure that any let is to reliable tenants and residents with suitableguarantors where applicable.

3.We also handle this information which relates to next of kinetc., to contact them in the event of an emergency. This is to protect your vital interests.

4.This information will also be handled if we need to trace youto contact you in connection with the tenancy or the property or to pursue aclaim against you, e.g. for rent arrears.This is in our own legitimate interests.These are to enforce your obligations, deal with property left behind atthe property or to recover property.

Bank details


1.This includes details of your bank, building society or otherpaying organisation, including those operating digitally/online.

2.We handle this information in order to receive payments fromyou or on occasion to make payments to you.This is done to perform our contract.

3.We also handle this information if we seek to make recoveryfrom you of unpaid debt. This is in ourown legitimate interests. These are torecover what is due to us.

4.We also handle this information as part of our verificationof your suitability as a tenant, including to protect against moneylaundering. This is in our own legitimateinterests to ensure that we let to suitable tenants/residents and do notreceive proceeds of crime.


Tenancy details


1.This includes renewals of the tenancy. Information within this category includes theaddress of the property, start date for the tenancy, period of occupancy, rentand other payments.

2.We handle this information to prepare and complete thetenancy agreement and then to manage the tenancy and the property. This is done to perform our contract.

3.Tenancies are renewed by agreement. This will involve a request from you. We handle information about the renewal oftenancies. This is done for contractualperformance.

4.Where you are a joint tenant or there are residents livingwith you details of any other joint tenant or resident are linked with thetenancy/property.

5.We handle this information to prepare and complete thetenancy agreement and thereafter to manage the tenancy and the property. This is done so that we can form a contract.

6. Wherethere is a guarantee, e.g. from a parent, we collect information about theidentity and contact details of the guarantor, background information about theguarantor and details of property owned.This is then linked to your tenancy and the property.

7. Wehandle this information to protect our own legitimate interests. This is to provide security for the paymentof the rent and to ensure compliance with tenancy obligations.

Deposits (if any)


1.This includes the amount of a deposit, who pays it and in whatshares and the steps taken to protect the deposit.

2.We handle this information to deal with the deposit receivedand to administer the deposit. This includeshandling information about persons who contribute towards the deposit who arenot a tenant. This is done both forcontractual performance and to ensure compliance with legal obligationsrelating to handling deposits under the Deposit Protection Legislation. This is to secure payment of the rent andcompliance with tenancy obligations.

3.We also handle deposits at tenancy termination and this isdealt with under that section.


Immigration/right to rent checks(England only)/verifying tenant’s identity


1. Underimmigration legislation we check that each tenant and adult resident in theproperty has the right to rent. Thisincludes retaining copies of passports, driving licences and other specifieddocumentation. We must retain this forinspection if required by the Home Office.

2. Wehandle this information in accordance with the requirements of immigrationlegislation in order to carry out our legal obligations.

3. Wealso handle this information in order to verify the identity of tenants andresidents along with guarantors in order to protect our legitimateinterests. These are to ensure that weare dealing with the correct person.This is done in Wales as well as in England for this purpose.


Rent and payment collection


1. Thisincludes records we compile to record receipt of rent and other payments fromyou and associated documentation relating to such payments. This also includes any documentation where weneed to issue reminders for payment, including levying charges for interest orfees for late payment.

2. Wekeep this information in order to compile correct and up to date records. This is done for contract performance.


Recovery of arrears, claims andpossession proceedings

1. Inthe event of non-payment of rent or other payments due, or if there is non-performanceof the contract (including allegations against ourselves) then we record thisand enter into relevant communications.This includes information and documentation related to any proceedingswhich may be commenced or brought against us in relation to these matters,including proceedings to recover possession of the property.

2. Wehandle this information in order to pursue recovery of what is owing to us andto enforce our rights, to defend claims, and to recover possession of theproperty. This is done in our ownlegitimate interests. These are toprotect our property interests, to enforce our rights and to ensure payment dueto us is made, as well as to defend any claims brought against us.

Repairs/housing standards/health andsafety

1. Thisincludes condition surveys, inspection reports, reports of repairs required andinformation about actions taken. Thisextends to conditions and standards generally at the property including healthand safety, e.g. gas safety.

2. Wehandle this information to ensure that the property and its contents areproperly maintained. This is done bothfor the purposes of contractual performance and, where applicable, to complywith our legal obligations.

Breach of tenancy agreement/nuisanceetc.

1. Thisincludes complaints which we receive or information which we hold relating toalleged breaches by a tenant or resident (which could include a child)including nuisance and anti social behaviour.This includes records and related communications. This includes complaints about these mattersmade by neighbours or other tenants or residents.

2. Wehandle this information so as to ensure that tenancy obligations are compliedwith and that tenants and residents live harmoniously with neighbours. Thisis to protect our own legitimate interests and the legitimate interests of affectedthird parties. These legitimate interestsare ensuring the tenancy obligations are complied with as well as theprevention and detection of crime and anti-social behaviour.

3. Wealso handle this information under a legal obligation where there is aselective licensing area in force or where the property is a licensed house inmultiple occupation (HMO) or under the licensing scheme operating in Wales.

Council Tax liability

1. Notificationis given to the local authority in relation to tenant/resident liability forCouncil Tax. This can includeinformation about the period of occupancy as well as former and subsequentaddresses.

2. Wehandle this information in order to ensure that the liability for Council Taxis dealt with correctly. This is done toprotect our own legitimate interests and those of the local authority. These are for the correct billing andcollection of Council Tax and to ensure that we do not have to meet Council Taxliability ourselves where this is not appropriate.

3. Inthe event of the local authority serving a statutory notice we then we must supplythis information to comply with our legal obligations.

4. Whereappropriate the tenant may be entitled to a reduction in Council Tax (formerlycalled Council Tax benefit). Informationis handled relevant to claims made by tenants.This is in the interests of the local authority administering the schemeto see that benefits are properly calculated and paid.


Water charge payments

1. Thisrelates to notification to a water company of the tenants/residents who areliving at the property their periods of occupancy and it can include previousand subsequent addresses. It alsorelates to communications between ourselves and the water company concerned.

2. Inthe area covered by Welsh Water this information is handled pursuant to a legalobligation.

3. Outsidethe Welsh Water area we handle this information to establish liability forwater charges in our own legitimate interests and those of the water companyconcerned. This is to ensure that legalliability for payment of water charges is correctly established and discharged.


Utilities and other service providers


1. Wearrange and establish liability for payment of gas and electricity consumed atthe property and any services which are provided, e.g. Broadband or cable tv. These services may be provided as arequirement under the tenancy agreement.It includes communications about changesof tenants, interruptions and disconnection of supply and work to be carriedout in connection with utilities and services such as the installation of smartmeters/replacement meters.

2. Wehandle this information in order to arrange provision of utilities and servicesand ensure that the correct liability for relevant charges is established andthat these are paid for. This is done inour own legitimate interests and those of the utility company/providerconcerned. These are to ensure utilitiesand services are provided and that liabilities are paid.

3. Wealso handle this information in order to deal with breakdowns, interruptionsand disconnections and to ensure that the appropriate quality of service isprovided. This is done in our ownlegitimate interests. These are toensure that requisite utilities and services are available and are provided atthe property.

Universal Credit/Housing Benefit/LocalHousing Allowances


1. Whereeligible a tenant will be entitled to the appropriate welfare benefits toassist them to pay rent. Information maybe required by the Department for Work and Pensions (DWP) or local authority toverify entitlement. Normally, payment ofbenefit is made direct to the tenant; however, if the tenant is vulnerable orthere are arrears, payment of benefit can be made direct to us. This extends to Council Tax reductions (theold Council Tax benefit).

2. Wehandle tenancy details and rent payment records, including information aboutarrears of rent, and the tenant’s personal circumstances, relevant to theprocessing of claims and the administration of benefits. This is done for contractual performance. It is also carried out in our own legitimateinterests to secure payment of rent due to us.

3. Wehandle information relevant to applications for benefit and in particularapplications for direct payment to ourselves including reasons for non-paymentof rent. This is for contractual performance.

4. Onoccasion where direct payment has been made to us there may be claims by thebenefit authority for recovery of overpayments.We handle information relevant to such claims. This is done for our own legitimateinterests. These are to ensure that wecan collect and retain rent due to us.


Tenancy termination


1. Atenancy may run out and the tenant leaves.Tenants can leave early while the tenancy is still running on. We may serve notice requiring the tenant tovacate and, if need be, enforce this by court possession proceedings.

2. Tenancyterminations of whatever kind also involve the return of any deposit paid,possible claims against guarantors, claims on rent insurance or propertyinsurance, arrangements for tenants/residents to vacate the property, tenants/resident’sproperty being left behind. They alsogive rise to issues around the state and condition in which the property hasbeen left, e.g. cleanliness.

3. Wehandle information relevant to these matters concerning tenancytermination. This is done in our ownlegitimate interests. These are toensure that the property is returned to us in a proper state with vacantpossession and that all appropriate financial claims by either party againstthe other are correctly dealt with.These include our obligations in relation to the refund of deposits, tocomply with our contractual obligations between us and the tenancy depositscheme with whom the deposit is protected.




1. Weoperate a complaints procedure which may be informal. Although we will do all we can unfortunatelysometimes things go wrong so complaints may arise.

2. Informationhandled concerns complaints which you may make or which may be made on yourbehalf. These will give rise to communicationsand records being compiled by us.

3. Wehandle complaints with a view to resolving these, although this might involveexternal intervention, e.g. by the courts.

4. Wehandle complaints for contract performance.This is also done in our own legitimate interests. These are to protect ourselves against claimsand to ensure that the complaints are properly resolved.




1. Importantly,this is sensitive personal information to which additional protectionsapply. We may be given information aboutyour health (whether mental or physical) or disabilities.

2. Healthinformation may be given to us to explain your absence from the property or asa reason why rent has not been paid. Youmay wish us to have information about your health so that we are aware of howyou may need assistance on occasion. This could also be information about healthor disabilities affecting someone else which impacts on you.

3. Wemay be given information about your disabilities so that we can make particulararrangements for you, including any adaptations which may be required to make underdisability discrimination legislation.

4. Wehandle information about your health or disability, and the health of others dependingupon the circumstances to assist us in the management of the tenancy and theproperty. This may be to protect yourvital interests. It may alternatively befor contractual performance where it affects your ability to perform yourcontractual obligations under the tenancy agreement. It will be in our own legitimate interests ifwe are told of any medical condition which affects you. This is so we are aware of possible impactson you.

5. Inregards to information concerning any disability, we handle this information toassist in the management of the tenancy and the property. This may also be under a legal obligationwhere we are obliged by law to make provision to deal with yourdisability.

6. Inaddition, as this is special category data, additional legal requirements areimposed upon us about your health and/or disability and we may request yourconsent to handle this information.


CCTV and Audio


1. Ifwe operate cctv you will be given information about this. We may operate cctv to cover common parts orthe exterior of the premises.

2. Wemay also hold audio recordings, e.g. messages from you on telephone answeringmachine or mobile phone.

3. Wherecctv is operated this is for the safety and security of the premises inquestion and for the prevention and detection of crime and anti socialbehaviour, as well as monitoring tenancy obligations. This is done in our own legitimateinterests. These include the protectionof our property and ensuring compliance with tenancy obligations as well as thesafety and security of tenants, residents and neighbours.

4. Wehandle audio recordings to assist with accurate record keeping. This is done for contract performance or inour own legitimate interests. These areto ensure that we have reliable records of communications.


Correspondence etc


1. Correspondenceincludes all ways in which we receive communications from whatever source. This includes emails, text messages, socialmessaging and messages, letters and documentation. This can include photographs and other visualrecordings.

2. Wehandle these communications initially relating to entering into the tenancyagreement and then for the management of the tenancy and the property, as wellas associated matters arising under the various categories of informationreferred to in this Table. This is donefor contractual performance where applicable, to carry out any applicable legalobligations imposed on us, to protect your vital interests, or in ourlegitimate interests. These legitimateinterests are to ensure that we have the necessary information relating tothese matters and for accurate record keeping.


Websites and online platforms


1. Informationabout you is available in the public domain, often put there by you. This can be accessed by appropriate searcheswhich allow for access to the websites which hold this information.

2. Informationabout you is also made available when you access online platforms, e.g. toenquire about properties which are available for renting.

3. Wehandle this information to assess your suitability for tenancies/residency andfor the management of the tenancy and the property. This is in our own legitimate interests toensure that tenants/residents are suitable and that the tenancy and theproperty are effectively managed. Thiscan include ensuring that tenancy obligations are performed. These legitimate interests are to ensure thatour property interests are protected and our rights are enforced.

4. Wehandle information received via our online platforms for contract performance,including arranging lettings and entering into tenancy agreements.




1. Weinsure the buildings and may insure contents belonging to us. We may also insure against public liability,including liability to yourself for injuries and rental insurance, in the eventof rent arrears or other tenancy default.

2. Wehandle information about you which may be relevant to our insurances to arrangecover, to administer insurance contracts, to renew insurances and to makeclaims. Contractually we are undercertain duties, e.g. to disclose information to the insurers. We handle this information to protect ourlegitimate interests. These are toensure that appropriate risks are adequately insured against and to recover anysums due to us under the policy as a result of claims.

3. Itis your responsibility to insure your own contents/belongings. You may seek information from us relevant toarranging such insurance or making claims.We handle this information and will do so with your consent which isprovided as part of your request for any assistance or information.


Flat management


1. Thisapplies in particular where the property is a flat. This flat will be held by us under a lease orsubject to other contractual arrangements which will set out variousresponsibilities for the upkeep, insurance etc., of the block including commonareas. The lease or other arrangements placecontractual obligations on us which in turn may be passed on to you under theterms of the tenancy.

2. Wehandle information about you in order to carry out our responsibilities underthese leases/arrangements. This is donein our own legitimate interests and in the interests of the freeholder etc., ofthe block so as to ensure that respective obligations are properly performed.




Part2 – Sharing Information


We share your information withvarious persons, organisations and public authorities as necessary. This involves us either transferring yourinformation to others or collecting it from them, depending upon thecircumstances. This Part of the Tablegives you details about this. It can bea two-way traffic between ourselves and others.In some instances, we may collect information about you from someoneelse following a request by us to them to provide this information.


Where we collect information fromothers (third parties) we have to tell you the source of this information,whether or not it is publically accessible, the nature of the source (i.e.whether it is publically or privately held) and the types of organisation fromwhom the information is obtained. Wherepossible we need to name the source as well but often this cannot be done. The required details appear in this Part ofthe Table.


Whereinformation is received from a private person/body or a public authority, thisinformation will not normally be publicly accessible, however in some instancesit will be. Information which will bepublically accessible will be information such as Council Tax bandings andinformation available in public registers, e.g. registers of births and otheravailable public registers.


We share identity and contactdetails with all persons, organisations/authorities referred to below. This category of information is linked withthe other information in every category for the purposes and under the legalgateway specified under each of the other categories of information. This is to ensure that you are correctlyidentified and, if need be, can be contacted.

A– Sharing of certain categories of your information


We sharecertain categories of your information (both transferring it to them andcollecting it from them as necessary) with private persons/organisations andpublic authorities as necessary.


In Section B we go onto explainthat, as necessary, certain private persons/organisations and publicauthorities can share any of your information (irrespective of its category).


Table 1 below identifies the differentcategories of your information and specifies the privatepersons/organisations/public authorities with whom these different categoriesof your information are shared as necessary.This Table should be read in conjunction with Table 2 (privatepersons/organisations) and Table 3 (public authorities). Tables 2 and 3 explainwhy we share your information with thesepersons/organisations/public authorities and the legal gateway whichallows this to happen.


Depending on the category of dataconcerned you should also refer to that category under Part 1 above because thepurposes set out for which we handle data and the legal gateway for doing soalso usually apply when we share data with others.


Table 1 – Data categories and who they areshared with

Data category

With whom we share the data

Personal/background information

Other landlords/employers; debt collectors/tracing agents; next of kin etc.; insurers; banks etc.

Bank details

Our bank, credit reference agency; debt collects/tracing agents

Tenancy details

Other landlords/employers, benefit authority, taxation authority

Deposits (if any)

Tenancy deposit body; debt collectors/tracing agents; taxation authority

Immigration/right to rent checks (England only) and verification of tenant’s identity

Home Office; credit reference agency (for verification of identity)

Rent and other payments

Bank, benefits authority, taxation authority, joint tenants/resident’s guarantor, insurers, other landlords

Recovery of arrears, claims and possession

Debt collectors/tracing agents, other landlords, taxation authority, joint tenants/residents, guarantors; insurers

Repairs/housing conditions/health and safety

Contractors, tradespeople, etc., deposit protection body, joint tenants/residents, freeholder flat management etc., guarantors

Breach of tenancy agreement/nuisance etc.

Contractors, tradespeople etc., deposit protection body, joint tenants/residents, guarantors, educational institution, neighbours, other residents etc., freeholder, flat management agents etc., insurers

Council Tax liability

Taxation authority (local authority)

Water charges

Thames Water and Castle Water Ltd and other water companies

Utilities and services

Utility suppliers and service providers, e.g. Gas

Universal Credit, housing benefit etc.

Benefit authority (Department for Work and Pensions or local authority), regulatory authority, joint tenants/residents/guarantors

Termination of tenancy

Other landlords, educational institutions, debt collectors/tracing agent, taxation authority, deposit protection body, bank joint tenant/resident/guarantors, freeholder managing agents etc.

CCTV/audio/ recording table

Deposit body, joint tenants/residents, guarantor, next of kin etc.

Correspondence etc.

Depending upon the applicable category of information relevant correspondence etc. is shared with any of the persons/organisations/authorities listed in Section A.

Online platforms

Joint tenants/residents; guarantors


Insurers, banks etc.

Flat management

Freeholders, flat managing agents etc.


Table 2 – Private persons/organisations

Categories of persons /organisations

Purpose and legal gateway

Other landlords/employers

To obtain references. This is to ensure suitability for a tenancy in our own legitimate interests. We also provide information to prospective landlords in their legitimate interest to assist them in evaluating suitability for a tenancy/residency. These interests are to ensure that properties are let to reliable tenants/residents. Where the property is subject to selective licensing there is a legal obligation for new landlords to obtain references before they let.


Contractors/tradespeople/service suppliers

Assisting in carrying out our responsibilities under the tenancy agreement and for the management of the tenancy and the property for contractual performance. In certain cases, this is also to comply with our legal obligations in relation to housing conditions and health and safety, e.g. gas, electrical and fire alarm maintenance and inspection. We will also provide your contact details to contractors etc., to facilitate access to the property for contract performance. On occasion we will arrange for inspections in our legitimate interests. This is so that we can deal with complaints and pursue/defend claims.

Utility companies and service providers, e.g. Broadband

Arranging for utilities/services and establishing liability for payment along with administering their supply in our own legitimate interests and those of the provider. This is to ensure utilities/services are provided and that liability is correctly established. Utility companies also have certain statutory obligations to perform, e.g. metering. In the case of utilities or other service providers if we agree to provide any relevant utility or services as part of the tenancy agreement then these arrangements are made for contractual performance. Otherwise, they are in the legitimate interests of the utilities/service providers to ensure that they can effectively carry out their various activities.

Credit reference agencies

We request and consider credit and other referencing relating to deciding on the suitability of tenants and residents for a tenancy. This is in our own legitimate interest to ensure that we let to reliable tenants/residents.

Debt collects/tracing agents

To trace you or make a claim in our legitimate interests. These are to enforce our legal rights.

Joint tenants/residents

Management of the tenancy and the property for contractual performance. Additionally, in our own legitimate interests and those of joint tenants/residents where there are arrears of rent or other payments due or breaches of the terms of the tenancy agreement as they are either jointly liable for performance or non- performance could adversely impact on their continued residence at the property. The legitimate interests are to protect our own property interests and to enforce our rights.


Management of the tenancy and the property for contractual performance. We also inform guarantors of claims and liabilities for contractual performance of the guarantee. It is in our own legitimate interests and those of the guarantor to give and receive information relating to non- performance of tenancy obligations including non- payment of rent and other payments. Our interests are to protect our property interests and to enforce our rights and the guarantor’s interests are so that the guarantor is aware of possible liability under the guarantee.

Next of kin etc.

To make contact with them in the event of an emergency to protect your vital interests.


To arrange public and other liability insurance and rent insurance and to make claims. This is in our legitimate interests and the insurers legitimate interests. These are making sure that appropriate insurance is arranged and the policies are correctly administered. Under the terms of policies, we are required contractually to provide information to insurers.

Banks and lenders

Where we have loans, information regarding tenancies must be provided to arrange and administer loans. This is in our own legitimate interests to finance our business. Contractually they are entitled to your information. In the case of banks information about you can be shared for the purposes of administering rental and other payments for contractual performance. Your information can also be shared for the purposes of preventing and detecting money laundering and fraud. This is in our own legitimate interests and those of the bank in order to detect crime. Contractually we may be required to provide information regarding insurance cover to banks etc. providing us with loans. This is in our legitimate interests to ensure compliance with the loan conditions and in the interests of the bank etc. to see that appropriate insurance cover is in place.

Neighbours, other tenants and residents

The management of the tenancy and the property. This includes information relating to complaints including alleged breaches of the tenancy agreement and anti social behaviour, as well as the abandonment of the property. It can include car registration information. This is in our own legitimate interests to protect our property rights and to enforce compliance with the terms of the tenancy. It is also in the legitimate interests of neighbours for their enjoyment of their own properties and to protect their property, interests and rights.

Flat freeholders, managing agents etc., where the property is a flat.

The management of the tenancy and the property. Under leases/other contractual arrangements they are entitled to certain information, e.g. who occupies the flat and the terms of such occupation. Further, consents/permissions may be required relating to the tenancy for the carrying out of alterations or works or your information may be relevant to repairs. This is done in our own legitimate interests. These are to ensure we comply with our own contractual obligations. Additionally, there may be complaints involving breach of the terms of these leases/other contractual provisions connected with nuisance, non-compliance with leases/other arrangements or anti social behaviour. Consequent upon this information may be shared in our own legitimate interests or those of the freeholder managing agent etc., concerned. This is to ensure compliance with our own contractual legal obligations and/or for the management of the block.

Web sites, portals etc.

Undertaking searches and obtaining publically available information relevant to your suitability for a tenancy/residency and relating to the management of the tenancy and the property. This is undertaken in accordance with applicable data protection law and guidance and subject to data protection principles. In connection with your application for a tenancy, we may receive information via any online portal involved for contractual performance.



Table3 – Public Authorities


Home Office

Immigration/right to rent checks for the performance of our legal obligations

Benefit authority

The administration of benefits such as Universal Credit (by the Department for Work and Pensions) and the housing benefit/local housing allowance by the local authority. This includes applications to them for direct payment of benefit to ourselves. It extends to claims by them for overpayment where we receive direct payments. This is for contractual performance and/or in our legitimate interests to ensure that we collect rent and that amounts properly due to us are received.

Deposit body

Under housing legislation we are required to protect any deposit which you pay in connection with the tenancy. We may pay this into a custodial scheme which holds the money or alternatively hold it ourselves in which case it is insured. We have to register the deposit with the deposit body concerned. This is to comply with our legal obligations. During the course of the tenancy it may be necessary to give details of any changes to the deposit body to comply with our legal obligations. On the termination of the tenancy for contractual performance we must arrange for the return of the deposit in whole or in part depending on whether there are any claims on it or not by us. In the event of disputes these can be submitted to adjudication in which case it is necessary for information to be provided to the deposit body concerned (and its adjudicator) in our legitimate interests to pursue or defend claims. This is also contractually required under the rules of the scheme.

Educational institutions

Information relating to non- payment of rent, breach of tenancy terms, nuisance or anti social behaviour may be shared with educational institutions where you are studying. Educational institutions can operate complaints schemes in conjunction with landlords of student properties. This can include information about tenancy terminations. This is in our own legitimate interests to protect our property interests and our rights and in the interests of the educational institution concerned to oversee the conduct of their students.

Taxation authorities

These are HM Revenue and Customs and (in the case of Council Tax and Council Tax reduction schemes) local authorities, as well as any other public authority having power to levy taxes or charges. We are required by law to make appropriate returns to comply with legislation imposing taxes etc. In the case of Council Tax this is required where statutory notice to that effect is served on us. Otherwise, we share information with the local authority relating to Council Tax in our own legitimate interests to ensure that Council Tax is correctly administered and in the legitimate interests of the local authority to collect information for the same reason.


B – Private persons/organisations/publicauthorities with whom any information is shared

Asnecessary, we share all of your information (irrespective of its category) withcertain private bodies/organisations/public authorities. This includes transferring your informationto them and receiving it from them.These are


Category of person/organisation/public authority

Purposes and legal gateway

Professional advisers

Assistance and advice regarding the management of the tenancy and the property for contractual performance. Where we handle your information under some other gateway and a professional adviser assists or advises this will for the same purpose and under the same legal gateway. If it is in the legitimate interests of ourselves or someone else then those interests will be the same. These are to ensure that we act appropriately and properly as well as according to the law.

Police/law enforcement agencies*

Prevention/detection of crime and anti social behaviour in our and their legitimate interests. This is to protect our property and enforce our rights and to enforce the law.

Regulatory authorities*

To carry out their functions in their legitimate interests. These are to enforce legal requirements. On occasion, we may be under a legal obligation to provide your information, particularly if a notice to that effect is served on us. This can include an ombudsman or accreditation or similar scheme of which we are a member. It also includes water companies, utility providers who are exercising their functions as statutory undertakers.

Letting and managing agents

To let or manage the property in our and their legitimate interests. These are so that the tenancy and the property are effectively let and managed. Contractually we are required to provide your information to any letting/managing agent we instruct.


The administration of Justice in our legitimate interests. These are to pursue and defend claims.

Prospective purchaser of the property

In the event of a proposed sale/sale of the property either subject to the tenancy or with vacant possession any prospective purchaser/purchaser will require information about the tenancy and the property. This is in our own legitimate interests and their legitimate interests. This is part of the conveyancing and sales process for both parties. The legitimate interests are to ensure that correct information is provided and received.

* Theseare public authorities