1. Purpose of our privacy statement
1.1 Under the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR), we are required to explain to you why we are asking for this information about you, how we intend to use the information you provide and whether we will share this with anyone else.
2. Who are we?
2.1 Avenue Services (NW) Limited is a company limited by guarantee and is a joint venture between Sanctuary Group (one of the UK’s leading providers of housing, care and commercial services) and Cheshire West and Chester Council (CWaC). Our address is Parade Enterprise Centre, 14 The Parade, Blacon, Chester, CH1 5HN.
3. Our data protection officer
3.1. Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
3.2. If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing dataprotection@sanctuary.co.uk.
4. Why are we collecting your information?
Most of the personal information we process is provided to us directly by you to enable us to enter and administer a commercial tenancy for office space at our Parade Enterprise Centre or Hatton Road sites.
5. What information are we collecting?
5.1. We currently collect and process the following information:
- Name
- Address
- Contact details such as email and telephone number
- Financial and payment details
5.2. If you do not provide this information, we will not be able to enter into a contract with you for office accommodation.
6. What is our lawful basis for using your information?
6.1. Under Article 6 of the UK GDPR, the lawful bases we rely on for processing this information is:
(b) Performance of a contract.
7. Sharing your information
Members of Sanctuary Group
7.1. Sanctuary Group is made up of a number of related companies. We will share your information with other members of Sanctuary Group where necessary to best provide the services to you.
7.2. For more information on which companies make up Sanctuary Group, please go to www.sanctuary-group.co.uk/about-us.
Regulators and other legal obligations
7.3. We may also be required to share your information with other organisations where we have a legal obligation to share the information with them.
Data processors and Transfers
7.4. To facilitate the delivery of services to you, it may be necessary to share information about you with our contractors and sub-contractors in order to provide the services outlined in your commercial tenancy with us.
7.5. We will only share your information about you with contractors and sub-contractors where it is relevant and necessary. Our contractors and sub-contractors shall be contractually required to ensure that they adhere to the security requirements imposed by the Data Protection Act 2018 and the UK GDPR.
7.6. Our contractors and sub-contractors will not share your information with any other parties and will only be able to use the information when completing work on our behalf.
7.7. We also use a third-party processor, for technical IT support with our internal systems, who may transfer your data outside the UK to India.
7.8. This transfer is made in accordance Article 46 of the UK GDPR as we have ensured a similar degree of protection is afforded to it through our processor implementing an International Data Transfer Agreement.
7.9. For further information on the safeguards implemented, or to access a copy please email dataprotection@sanctuary.co.uk.
8. Can we use your information for any other purpose?
8.1. In limited circumstances, we may use your information for a purpose other than those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it for the new purpose.
9. Security of your information
9.1. The information that you provide will be stored securely. Our technological and organisational security measures and procedures reflect the seriousness with which we attach to the confidentiality, integrity and availability of your information.
9.2. Only relevant members of staff will access the information you provide to us.
10. Storing your information and deleting it
10.1 We will not keep your personal data for longer than we need it or are required to by law.
10.2. We keep the information relating to your commercial tenancy for six years following its end date.
11. Your rights
11.1. In relation to the information which we hold about you, you are entitled to:
11.1.1. Ask us for access to the information;
11.1.2. Ask us to rectify the information where it is inaccurate or is incomplete;
11.1.3. Ask us to limit and restrict what we do with your information;
11.1.4. Ask us to provide the data you have provided us in a structured, commonly used, and machine-readable format (for example, a CSV file) in order transmit the data to another data controller.
11.2. Our obligations to comply with the above rights are subject to certain exemptions.
11.3. To exercise any of the rights referred to above, you should contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing dataprotection@sanctuary.co.uk.
12. How to complain
12.1. If you have any concerns about our use of your personal information, you can contact our Data Protection Team on dataprotection@sanctuary.co.uk.
12.2. You also have the right to complain to the Information Commissioner’s Office (the ‘ICO’) if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.