Information about Downing
Downing is made up of different legal entities as follows, Downing Property Services Ltd, George Downing Construction Ltd, Downing Property Management Ltd, Downing Students, Downing Living Ltd and Downing Construction Ltd. This privacy notice is issued on behalf of Downing group so when we mention ‘Downing’, “our”, ‘we’, ‘us’ in this privacy notice, we are referring to the relevant Downing group company responsible for processing your data.
Downing takes its data protection and privacy responsibility seriously. This privacy notice explains how we collect, use and share personal information in the course of our business activities and your access to, and use, of our websites, including:
- Who we are and what we do
- How you can contact us for more support
- What personal information we collect and when and why we use it
- How we share personal information within Downing and with our service providers, regulators and other third parties
- Explaining more about Direct Marketing, profiling and automated decision making
- Transferring personal information globally
- How we protect and store personal information
- Legal rights available to help manage your privacy
The Downing entity who is the controller of, and responsible for, your personal information will be the member of the Downing group that collects information from or about you. Downing Property Services Ltd is responsible for this website.
Please note that this privacy notice only applies to the use of personal data collected by Downing. It does not apply to personal data collected by third parties or other organisations. You might find external links to third party websites, plug-ins and applications on our website. We do not control such third party websites, plug-ins and applications and this privacy notice does not apply to your use of such third party sites, plug-ins or applications.
We keep this privacy notice under regular review and may amend this notice from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this notice. Please keep us informed if your personal data changes during your relationship with us.
Who we are and what we do:
Downing is a leading property company working in construction, development, property management and in the provision of commercial, residential, and high-quality purpose-built student and co-living accommodation across the UK. You may find out more about Downing at ww.downing.com or by contacting us through the web page link ‘Get in touch’ section of our website at www.downing.com.
From time to time Downing will use information provided by you in order to carry out our business, and to contact you when necessary to respond to your enquiry and throughout the duration of your contract and manage your account, if applicable. We will manage the performance of any agreed third-party partners as required by law for the provision of services to you and in communication with relevant colleges and universities of our student tenants and to enable us to conduct our business in the context of your enquiry.
How to contact us:
If you have any questions about this privacy notice or would like to find out more about the legal basis for which we process and use personal information please contact us by:
- email to firstname.lastname@example.org;
- telephone on 01517072666; or
- post to Downing, 5 Myrtle Street, Liverpool L7 7DN.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues at www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO.
What personal information we collect and when and why we use it
We may collect information about you, directly from or through a third party, if you:
- Register or use one of our websites or online services
- Rent one of our properties
- Work in partnership with us
- Contact us by post, telephone, fax, email or SMS, where applicable
- Enter into a contract with us
- Purchase one of our services
Depending on the purpose for which we use your data, we may collect, store and use certain personal information that is disclosed to us including your name, status, date of birth, age, employer, telephone number, mobile number and email address. As and where required, such information may also include photographic identification and proof of address.
Personal information we collect from/about you as described above, may be used in the following ways:
- For sharing information with Downing staff and third parties in relation to business needs, including employee training purposes.
- To create and manage an account, to include the processing of bank/card details for the raising and settlement of invoices if applicable.
- To enable and facilitate the creation and management of a tenancy agreement, lease, licence or contract if applicable.
- For recruitment purposes if appropriate.
- To provide details to landlords, agents or sub-contractors to enable the provision of services.
- To enforce our agreements with you.
- Investigate or settle inquiries or disputes.
- Comply with any applicable law, court order, other judicial process, or the requirements of a regulator.
- Use as otherwise required or permitted by law.
- To enable us to monitor and improve the performance of the websites.
- To facilitate third party contracts for the provision of services to you (E.g. security provision /Wi-Fi / insurance) as agreed.
- To facilitate the collection of bad debt.
- For audit and statistical analysis, including for our business and accounting records.
- For fraud prevention, including passing information to credit reference agencies.
- To opt-in to our mailing list for marketing purposes.
- To verify your identity.
- For identification purposes to support the security infrastructure throughout the business/buildings e.g. a photograph on an entry system or a biometric access and management system.
The legal basis for using your personal information
We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. We have set out below a description of the lawful justification we may rely upon when using your personal data, depending on the way in which the personal data is used:
- You have provided your consent to us using the personal information (for example, the performance of a contract or the creation of a tenancy agreement).
- Our use of your personal information is necessary in order to take steps at your request prior to entering into a contract with you and to perform a contract or take steps to enter into a contract with you. (For example: to create a tenancy agreement etc.).
- Our use of your personal data is necessary to comply with relevant legal or regulatory obligations that we have (For example: confirmation of student status or to verify your right to rent).
Sharing personal information within Downing, with our service providers and regulators
We will share your information in the manner and for the purposes described below:
- Within Downing group where such disclosure is necessary to provide you with our services or to manage our business.
- With third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use of any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These include IT service providers who help manage our IT and back office systems.
- With credit reference agencies and organisations working to prevent fraud in financial services.
- With our regulators and law enforcement organisations, to comply with all applicable laws, regulations and rules, and request of law enforcement, regulatory and other governmental agencies.
- in aggregate, statistical form, non-personal information, regarding the visitors to our website, traffic patterns and web page usage with our partners, affiliates and advertisers.
- To local councils, statutory bodies, education establishments such as colleges and universities, where applicable.
- Utility provides set out in the tenancy agreement, where applicable.
- For provision of insurance.
- To debt collection agents, solicitors or a Guarantor for the collection of outstanding debts.
- Our professional advisors such as lawyers and accountants.
- With the persons nominated by you as your emergency contact where, Downing believe you are at risk.
- If in the future we were to sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third party purchaser or our business or assets.
Please note the above list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide our services and manage our business as effectively as we can.
Explaining more about direct marketing
How we use personal information to keep you up to date with our products and services
We may use personal information to let you know about Downing products and services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.
How you can manage your marketing preferences
How you can manage your marketing preferences to protect privacy rights and to ensure you have control over how we manage our marketing with you:
- We will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you.
- You can request us to stop marketing at any time by following the ‘unsubscribe’ link you will find in our email marketing messages we send you. Alternatively, you can contact us using the information at the start of this privacy notice and inform us if you wish us to stop all forms of marketing or a particular type (For example: email).
We recommend you routinely review the privacy notices and preference settings that are available within your Downing account.
Transferring personal information globally
Downing operates on a global basis. Accordingly, your personal information may be transferred and stored in countries outside the UK that are subject to different standards of data protection. Downing will take appropriate steps to ensure that any transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognised as providing adequate legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights.
You have the right to contact us for more information about the safeguards we have in place to ensure adequate protection of your personal information when this is transferred as mentioned above.
How we protect and store your information
We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature or the information concerned. Measures we take include placing confidentiality requirements on our staff members and service providers, destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected. As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user ID`s and passwords, please take appropriate measures to protect this information.
Storing personal information
We will store your personal information for as long as is reasonably necessary for the purpose for which it was collected, as explained in this notice. In some circumstances, we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements.
In specific circumstances, we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
Legal rights available to help manage your privacy
Subject to certain exemptions, and in some cases dependent upon the processing activities we are undertaking, you have certain rights in relation to your personal information.
Your personal information:
As an individual, you have the following rights which relates to all data we collect and store for customers and contractors.
- The right of access to your personal information. You have the right to 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.
- The right to rectification and update your personal information. You have the right to 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.
- The right to erasure. You can request to delete personal information we hold. You have the right to 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. We are not required to comply with your request to erase personal information if the processing of your personal information is necessary: (i) for compliance with a legal obligation; or (ii) for the establishment, exercise or defence of legal claims.
- The right to restrict the processing of your personal information. You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- The right to data portability or to request the transfer of your personal information. You have the right to 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.
- The right to object to the processing of your personal information. You have the right to object to the 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.
- The right to withdraw consent. You have the right to 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.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you.
You can exercise your rights by contacting us using the information at the start of this privacy notice. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
We may not be able to fully address your request, for example, if it were to impact on the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.