Privacy Statement

1 Introduction

Welcome to the Core Media Services UK Ltd (Core) Privacy policy.

Core Media Services UK Ltd (Core) which includes repairs and maintenance, voids and inventory, and marketing services are dedicated to ensuring that the privacy of our clients and customers is respected and protected and we are committed to ensure our use of your personal information is governed by this Privacy Notice. Clients include Councils, Developers, Housing Associations, or wider business requiring property repairs and maintenance, void works, inventories, cleaning services, creative marketing services who have appointed us to undertake work on their behalf.

Core is the controller of personal information it collects and uses. Core respects your privacy and is committed to protecting your personal data. We will treat your personal information as strictly confidential and in accordance with applicable data protection legislation. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or by other means of engagement with us regarding the services you use from us. It also tells you about your privacy rights and how the law protects you.

Why are we asking you to read this document?

While dealing with us we will ask you to provide us with some personal information to allow us to do the job instructed. (Your Information). We would like to explain to you what we do with Your Information, and the various rights you have in relation to Your Information.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

By using this website and/or continuing to receive services from us, you signify your acceptance of this policy. If you do not agree to this policy, please notify us and do not use our website(s). Your continued acceptance of services from us or use of this website following the posting of changes to this policy will be deemed as your acceptance of those changes.

2 Important information and who we are.

Purpose of this privacy policy

This privacy policy aims to give you information on how Core collects and processes your personal data through:

• your use of this website, including any data you may provide through this website when you complete the contact form on our website.
• the provision of our services to you as a landlord customer or a tenant of a property that we are instructed to carry out works on.

This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Core is the controller and responsible for your personal data for this website (collectively referred to as “we“, “us” or “our” in this privacy policy).

3 Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

• Email address: info@coreservices.uk
• Telephone number: 01375 531483

4 Complaints

If you have any complaints about the way we use your personal information, please contact us at info@coreservices.uk Once we receive this email, we will resolve the issue as best we can. If we cannot find a resolution, 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.

Information Commissioner

Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Telephone: 0303 123 1113

Website: https://ico.org.uk

You may request details of any personal information which we hold about you under the Data Protection Act 1998 as well as the General Data Protection Regulations 2018 (GDPR). If you would like a copy of this information, please email info@coreservices.uk or call us on 01375 531483.

If you believe that any information, we are holding about you is incorrect or incomplete, please contact us as soon as possible so we can update it.

Changes to the privacy policy and your duty to inform us of changes.

We keep our privacy policy under regular review. This version was last updated in November 2021.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

5 Third-party links

Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

6 The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• In the ordinary course of our business with landlord customers and their tenants:
  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• While operating our online customer portal application/ Inventory Base / Repairs System:
  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, your interests, preferences, feedback, and survey responses.
  • Usage Data includes information about how you use our website, products, and services; and

We also collect, use, and share Aggregated Data such as statistical or demographic data. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

What is personal information?

Personal information includes information such as name, contact details, date of birth, bank account details or any information about your needs or circumstances which would allow us to identify you.

Special personal information includes racial or ethnic origin, health and religious beliefs, political opinions, and sexual orientation. This information is more sensitive and therefore further justifications are needed for collecting, storing, and using this type of data. There are also additional restrictions on the circumstances in which we are permitted to collect and use for criminal conviction data.

Any references to personal information within this notice will include personal data, and less frequently- special personal data.

7 How is your personal data collected?

From any form of engagement – by telephone, email or on our website registration form, we will collect your full name and contact details (such as phone number, email address and postal address).

We use different methods to collect data from and about you including through:

• Direct interactions.You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • Apply for our products and services.
  • Create an account on our website.
  • Subscribe to our service or publications.
  • Request marketing to be sent to you.
  • Enter a survey, or
  • Give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our cookie policy https://coremediaservice.me.uk/cookie-policy/ for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Identity Data and Contact Data in respect of tenants whose properties we are working on from the relevant landlord (local authority, housing association, developer, etc) as part of our works assessment and planning process.
  • Technical Data from the following parties:
    • analytics providers.
    • advertising networks; and
    • search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers or aggregators and publicly available sources such as Companies House and the Electoral Register.

8 How we use your personal data.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• where we need to perform the contract, we are about to enter or have entered into with you.
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
• where we need to comply with a legal obligation.

Please go to the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data. We may send marketing communications through email or other such methods to the contact details that you have provided to us whilst enquiring, this is to keep our customers and clients up to date with our latest products and services.

You may choose to restrict the collection or use of your personal information in the following ways. Whenever you are asked to fill in a form on the website, identify the tick boxes to indicate which method of communication you would prefer to receive marketing by identifying the relevant tick boxes.

If you have previously agreed to us using your personal information for direct marketing purposes, and since decided that you no longer wish to receive promotional information from us you may change your mind at any time by emailing us at info@coremedia.me.uk or calling us on 01375 531483 to amend your preferences.

Purposes for which we will use your personal data.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data under more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

How we keep your information secure

The security of information is very important to us and we have measures in place which are designed to prevent unauthorised access to your personal information including but not limited to:

Files being stored on our secure client management systems. Access is restricted on our client systems to those within the business who are required to have access to that information for legitimate business purposes.

Hard copy documentation is stored in locked cabinets.

All data is hosted in data centres which have systems and protections in place to protect against both unauthorised access and other external factors that could cause damage to your personal data. Strict access requirements need to be adhered to for these.

9 Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established following personal data control mechanisms:

• Promotional offers from us
  We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
  You will receive marketing communications from us if you have requested information from us from us and you have not opted out of receiving that marketing.
• Third-party marketing
  We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
• Opting out
  You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
  Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
• Cookies
  A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic, or lets you know when you visit a site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.We use traffic log cookies to identify which pages are being used on our website. This helps us analyse data about our webpage traffic and improve our website to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie does not give us access to your computer or any information about you, other than the data you choose to share with us.You can choose to accept or decline cookies. Most web browsers automatically accept cookies; however, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, this may prevent you from taking full advantage of the website and our services as some parts of our website may become inaccessible or not function properly.

Cookies used on the website

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

10 Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above:

• Internal Third Parties as set out in the Glossary;
• External Third Parties as set out in the Glossary;
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

11 International transfers

We do not transfer your personal data outside the UK.

In the event that we, or some of our External Third Parties, transfer or store personal data on servers outside of the UK we take additional steps to ensure that your information is protected to at least an equivalent level, as required by applicable data protection laws.

12 Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

13 Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

14 Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• request access to your personal data;
• request correction of your personal data;
• request erasure of your personal data;
• object to processing of your personal data;
• request restriction of processing your personal data;
• request transfer of your personal data; and
• right to withdraw consent.

These are set out in more detail in the Glossary section below.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

15 Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Core operates under Core Media Services UK Ltd with three distinctly different business specialisms:

• Repairs and maintenance
• Voids and inventories
• Marketing & Exhibitions

External Third Parties

• Service providers acting as processors based in United Kingdom who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Subcontractors acting as processors or joint controllers who we instruct in order to carry out works or services on our behalf.

YOUR LEGAL RIGHTS

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.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• if you want us to establish the data’s accuracy.
• where our use of the data is unlawful, but you do not want us to erase it;
• where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; and
• you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.