Privacy Notice

Introduction

This Privacy Notice has been written for anyone interested in how Dot Dot Dot uses personal data. This Notice is a summary of more detailed processes and procedures that govern how Dot Dot Dot collects, stores, processes and updates personal data and governs how this data is used in our business operations to achieve our mission. In this context, ‘processing’ also refers to Dot Dot Dot just keeping your information.

The Privacy Notice will also be of interest if you want to:

  • understand how to view data held by Dot Dot Dot about you
  • find out how to correct information we hold about you, if that is necessary
  • find out how to exercise your legal rights in relation to personal data about you.

This Privacy Notice was last updated on 09/05/2018.

Scope

This Privacy Notice covers any interactions where personal data is collected, processed and stored. These will most usually be through the following types of interaction:

  • Use of our website at www.dotdotdotproperty.com and information entered into this website
  • Information directly entered into a data collection site managed by us, these are hosted by a managed service provider and will include the URL tfaforms.com
  • Information provided to our employees, Directors, agents, service providers, contractors regardless of communication method (examples include as part of a phone call, by email, in a meeting or home/site visit)
  • Information recorded in our computer systems and databases including text and images
  • Information provided by you in paper form and stored by us including text and images
  • Photos, videos taken as part of an event (for which we will seek your consent on an event-by-event basis)
  • Still and moving image and audio captured by CCTV, where this exists at certain operational sites, and is controlled by Dot Dot Dot. Notices displayed locally will inform you if this is the case.

Data Controller and Responsible Persons

When we refer in this Privacy Notice to “Dot Dot Dot”, “we” or “us” we mean Dot Dot Dot Property Ltd, a company registered in England.

The Data Controller for the purposes of the General Data Protection Regulations (“GDPR”) is Dot Dot Dot Property Ltd of View Tube, Marshgate Lane, London E15 2PJ.

Dot Dot Dot has an employee responsible for implementing and overseeing data protection compliance who can be contacted at privacy@dotdotdotproperty.com

Dot Dot Dot’s Chief Executive has responsibility for data protection compliance.

Dot Dot Dot Property Ltd is registered with the Information Commissioner’s’ Office (ICO). Our registration number is Z313474X and our registration information can be viewed at the ICO website https://ico.org.uk/ESDWebPages/Entry/Z313474X .

Why does Dot Dot Dot collect, process and store personal information?

Dot Dot Dot needs to collect, store and process personal information in order to carry out its core functions of recruiting property guardians, marketing activity, guardian management, property management, business development and sales as well as human resources management.  In this context, ‘processing’ also refers to Dot Dot Dot just keeping your information.

We also have a range of ways that we would like to keep in touch with people with whom we have a relationship, and those interested in our work. We collect, store and process information to undertake these activities, to help improve our business and satisfaction levels and to operate more efficiently.

Legal basis of consent

Dot Dot Dot’s main legal basis for processing personal data is where it is necessary for the purpose of the legitimate interests pursued by us to process your information. We aim to do this as long as we do not interfere with your freedoms or rights.

The other reasons we can rely on to process your personal information are:

  • Where you have given consent (also known as ‘agreement’)
  • Where we are under a legal obligation to collect information or a contractual obligation to process/disclose the information
  • Where we need to protect the vital interests of another person or organisation

Use and retention of personal data

The use and retention of personal data is explained by Dot Dot Dot’s Data Inventory which also includes information about the time periods for which personal data is retained. Once the retention period has passed, data is erased or destroyed.

In detail: How Dot Dot Dot collects, handles and stores personal information

We have set out how we collect, handle and store personal information depending on your specific interaction with us. We hope this makes it easier to understand how your personal information will be used depending on your actual or proposed relationship to us. We have divided the individuals that we interact with into the following types:

  • Applicants for housing
  • A current guardian living in a building that we manage, including former guardians
  • A former guardian who has moved out of a building that we manage
  • An employee of Dot Dot Dot, including a former employee
  • Any other individual not included in one or more of the above categories

These lists are not intended to be exhaustive. Generally the information you provide to us will have been provided to us by you (at the point of application, or when we communicate with you).

Applicants for housing

We collect, process and store the following information:

  • Contact information
  • Background information, including sensitive classes of information
  • Volunteering, educational and occupational history
  • Financial details
  • Other information relevant to becoming a property guardian
  • Other information relevant to property management
  • Images of your identification documents and proof of address, in order to comply with legal duties of property managers
  • You will be invited to tell us information about sensitive categories of data, for example demographic information and protected characteristics. We want to collect this information to help us judge whether our services are accessible. We do not use individual information of this nature in any decision and there are extra safeguards in place for how this information is collected and used..

We collect this data for the following purposes:

  • Creating an electronic record of your application
  • Processing your application including verification of identify
  • Inviting you to viewings, meetings and other activities
  • Promoting and advertising our services
  • Your responses to customer satisfaction surveys and research which is designed to help us improve the quality of our services
  • Research
  • Investigations
  • Complaints and dispute handling

We analyse information to ensure that our service is accessible to as many people as possible

How we store this data:

  • Form Assembly
  • Salesforce
  • Mailchimp
  • Bookwhen
  • Dropbox
  • Paper records
  • G-suite

A current guardian living in a building that we manage, or a former guardian who has moved out

We collect, process and store the following information:

  • Contact information
  • Background information, including sensitive classes of information solely for the purposes of assisting with our decisions on whether we can offer housing
  • Volunteering, educational and occupational history
  • Financial details including actual or expected earnings, regular payments and liabilities including debt
  • Other information relevant to being a property guardian, including notes or our interactions and conversations
  • Other information relevant to property management
  • Images of your identification documents and proof of address, in order to comply with legal duties of property managers
  • Information about your volunteering
  • Information about your service requests to us (for example, repairs)
  • Information about your payments and fees account status
  • Information gathered from property inspections about your conduct
  • Information about actions we have taken to recover monies owed
  • Your responses to customer satisfaction surveys and research which is designed to help us improve the quality of our services

You will be invited to tell us information about sensitive categories of data, for example demographic information and protected characteristics. We want to collect this information to help us judge whether our services are accessible. We do not use individual information of this nature in any decision and there are extra safeguards in place for how this information is collected and used.

We collect this data for the following purposes:

  • Creating an electronic record of your housing
  • Communicating with you about your housing, your building and your relationship with Dot Dot Dot
  • Collecting your fees and any amounts due to us
  • To ensure efficient and effective property management and contract management
  • Promoting and advertising our services
  • Research
  • Investigations
  • Complaints and dispute handling
  • Any (tenancy/housing) references we are asked to provide

How we store this data:

  • Form Assembly
  • Salesforce
  • Mailchimp
  • Bookwhen
  • Dropbox
  • Paper records
  • G-suite

How we share this data:

From time to time we share selected information with third parties in order to achieve:

  • efficient and effective property management
  • contract management
  • to improve safety
  • reduce risks.

This will usually consist of contact information but may include other categories commensurate with our objective.

Examples include:

  • Sharing information about who lives in which property with our clients and building owners
  • Sharing information with our agents who are carrying out tasks on our behalf (for example a contractor undertaking a repair, or a market research organisation carrying out a survey on our behalf).

An employee of Dot Dot Dot, or a former employee

Note that this category does not include applicants for employment roles.

We collect, process and store the following information:

  • Contact information
  • Educational and occupational history
  • National Insurance number and tax code
  • Emergency contact details
  • Employment history with the organisation
  • Employment terms and conditions (eg pay, hours of work, holidays, benefits, absence)
  • Information about your health that you have provided to us, or which we have asked to be provided by our Occupational Health provider
  • Any performance-related information including warnings, conduct issues or disciplinary action
  • Other information relevant to employment
  • Images of your identification documents and proof of address, in order to comply with legal duties as an employer
  • You will be invited to tell us information about sensitive categories of data, for example demographic information and protected characteristics. We want to collect this information to help us judge whether we are fair and inclusive as an employer. We do not use individual information of this nature in any decision and there are extra safeguards in place for how this information is collected and used.

We collect this data for the following purposes:

  • We collect and store employee personal data to manage our functions as an employer.

We analyse information at the company and team level to ensure that our recruitment, human resources management and  employment practices are fairly delivered and that our employment opportunities are accessible to as many people as possible.

How we store this data:

  • BreatheHR
  • Dropbox
  • Salesforce
  • Paper records
  • G-Suite

Any other individual not included in one or more of the above categories

We collect, process and store the following information:

  • Contact details
  • Your communication preferences
  • Records of your contact with us and our contact with you

We collect this data for the following purposes:

  • We hold contact details for you so that we can communicate with you by your preferred methods about services and activities which you may find useful.
  • We may also use this information to progress transactional or professional activity (examples would be a licensing application, contact with you for a professional reason if you are an employee of a local authority or another organisation that regulates or controls our activities).
  • Your responses to customer satisfaction surveys and research which is designed to help us improve the quality of our services

How we store this data:

  • Form Assembly
  • Salesforce
  • Mailchimp
  • Dropbox
  • Paper records
  • G-suite

Processing methods, storage and security

Regardless of the type and extent of personal information we hold about you, you can expect the following safeguards:

Cloud Based Storage: The majority of information we process is stored on the cloud, and storage on hardware is limited. This  lessens the threat of this information being lost through not having any back-up or it being  physically stolen. The programmes we have chosen to use have renowned security systems which minimise  our risk of being hacked/ having any data stolen.

Password Protection: All of our information stored in the cloud is protected by password, and these passwords are changed regularly. Dot Dot Dot also uses LastPass, LastPass  is a password manager that locks all passwords in a secure vault. One master password is required to access all other passwords, making  it a secure system. Staff will not need to write down multiple passwords to all the different programmes that Dot Dot Dot uses, which therefore  increases security. LastPass was chosen as it is a safe and secure way of sharing and storing organisational passwords.

Physical Storage: All information that is not stored on the cloud will be stored on hardware that is both password protected and encrypted or securely locked on site. This reduces the risks to physical information being stolen or compromised.

Our Quality Management System, assessed to ISO9001, describes how security is delivered and kept up to date.

Sensitive categories of personal data

Dot Dot Dot has a separate document which outlines the personal data we collect which may be regarded as sensitive. You can read this here.

Your rights under the GDPR

You have a number of rights under the provisions of the GDPR. You can read more about these at https://ico.org.uk/for-the-public/

To exercise any of the following rights please complete the request form here, or contact us at privacy@dotdotdotproperty.com:

  • access and check your data
  • request a correction
  • withdraw consent
  • request a restriction on processing
  • raise an objection to processing
  • request erasure (exercise your “right to be forgotten”)
  • request a machine readable copy of your information (“right to data portability”)

Changes to this Privacy Notice

We aim to keep our Privacy Notice up to date, to reflect changes in our business operations, to reflect improvements and quality, to respond to feedback and any changes in legislation. You will always be able to find our up to date Privacy Notice on our website and major revisions will be promoted on the website.

Concerns, questions and complaints

Dot Dot Dot has an employee responsible for implementing and overseeing data protection compliance, please direct your questions or concerns to privacy@dotdotdotproperty.com.

We have a general complaints policy which can be used if you wish to make a complaint about issues relating to this Privacy Notice. Read more about the complaints policy. https://dotdotdotproperty.com/complaints/

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