Privacy Policy

This Policy was last updated in August 2024.

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

Collecting & Using your personal data

1. Introduction

LIBERTAS LETTINGS LIMITED is a “data controller”. This means that we are responsible for deciding how your personal information is held and used.

LIBERTAS LETTINGS LIMITED for the purposes of this Privacy Notice is known as “The Agent”.

The Agent collects, stores and processes personal data relating to contract-holders, residents and guarantors, and prospective contract-holders in order to provide rental accommodation. This privacy notice sets down how the Agent collects and uses personal data about you before, during and after an occupation contract.

This privacy notice sets down what personal data is to be collected, why it is collected, how it is held and what data is processed by the Agent and with whom it is shared.

The Agent is committed to protecting the privacy and security of your personal data.
The Agent is committed to being clear and transparent about how it collects and uses that data and to meeting its data protection obligations.

2. Data Protection Policies

The Agent will comply with data protection law. This means that the personal data held about you must be:

- used lawfully, fairly, and in a transparent way;
- collected only for valid purposes that have been explained to you clearly and not used in any way that is incompatible with these purposes;
- relevant to the purposes you have been about and limited to those purposes only;
- accurate and kept up to date;
- kept only for such time as is necessary for the purposes you have been told about; and
- kept securely.

3. What information is to be collected and processed?

The Agent will comply with data protection law. This means that the personal data held about you must be:

The Agent collects and processes a range of personal data about you. Personal data means any information about an individual from which the person can be identified. If you are already a contract-holder, resident, or guarantor, some of the points below may not be relevant to you. Different information may be collected, depending on whether you are a contract-holder, resident, or guarantor. This includes:

- Identity and personal contact details, such as your name, title, address, email address, telephone number, date of birth, national insurance number, car registration;
- Background information such as previous landlord details, employer details, accountant details, next of kin, dependants, and emergency contacts;
- Bank account details, bank references, and credit check results;
- Occupation contract details including renewals, joint contract-holders, other residents, and guarantors;Deposit information (if any) including return on termination;
- Rent and utilities payment records;
- Recovery of arrears, claims, or possession proceedings;
- Repair and health and safety records;
- Breach of occupation contract terms/complaints;
- Council Tax and utilities records;
- Universal credit/housing benefit records;
- Notices and correspondence regarding termination;
- CCTV and audio recordings (if any); General correspondence in all formats (letters, emails, text messages etc); and
- Data sent from web browser to the Agent’s server (including pages visited and time and date and duration on the Agent’s server). 

I/we may also collect, store and use the following special categories of more sensitive personal data (known as “special category personal data”): 

- Information about medical or health conditions, including whether or not you have a disability for which the Agent needs to make adaptations; and
- Equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

This information is collected in a variety of ways. For example, personal data is collected through the application process and through correspondence during the occupation contract. The Agent also generates its own records such as rent payment records.

In some cases, the Agent collects personal data about you from third parties, such as:

- references supplied by former landlords, employers, and personal referees;
- information from credit reference agencies;
- other contract-holders, residents, or neighbours;
- guarantors;local authorities;
- the police or other law enforcement agencies;
- Department for Work and Pensions utility companies or service providers;
- letting/managing agents; and
- websites or online rental portals for lettings.

Personal data is stored in a range of different places, including in paper files and on the Agent’s IT systems (including email systems).

5. Situations in which your personal information will be processed

The Agent will comply with data protection law. This means that the personal data held about you must be:

Your personal information will be processed in the situations below:
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- To verify the identity of a proposed contract-holder/resident;
- To decide on the suitability of a proposed contract-holder/resident;
- To arrange lettings;
- To assess the financial standing/suitability of a proposed contract-holder/resident;
- To deal with joint contract-holders and residents who are linked to the occupation contract;
- To enter into an occupation contract;
- To secure payment of rent and performance of contract-holder obligations;
- To collect rent and other payments;
- To manage the occupation contract and the property;
- To arrange an energy performance certificate;
- To arrange an inventory check or report on the condition of the property;
- To keep accurate records relating to the Agent’s rental business;
- To arrange repairs and maintenance of the property;
- To monitor and enforce performance of contract-holder’s obligations;
- To recover debts and/or obtain possession of a property;
- To ensure Council Tax and utilities charges are billed and paid appropriately;
- To ensure that welfare benefits (such as Universal Credit and housing benefit) are paid to the landlord or contract-holder where appropriate;
- To handle termination and the return of any deposit;
- To handle complaints;
- To address health and disability issues relating to contract-holders/residents;
- To create and keep audio and CCTV recordings;
- To provide information to public or local authorities who are legally entitled to require this information;
- To contact next of kin or close relatives in case of emergency;
- To store emails, records of calls, and other communications;
- To comply with legal and regulatory requirements;
- To bring and defend legal claims;
- To prevent, detect and investigate crime and anti-social behaviour;
- To perform our letting contract to deal with joint contract-holders and residents who are linked to the occupation contract;
- To take payment for the services provided by the Agent; and
- To provide you with general updates in relation to the property market and information relating to the Agent’s services in accordance with your express consent.

6. If you fail to provide personal information

If you do not provide certain information when requested, the Agent may not be able to proceed with the grant of a secured occupation contract.

7. Change of Purpose

Your personal data will only be used for the purposes for which it was collected unless it is reasonably considered that it is needed for an additional reason and that reason is compatible with the original purpose(s). If your personal data is needed for an unrelated purpose, you will be notified and an explanation of the legal basis which allows this to be done.

You should be aware that your personal data may be processed without your knowledge or consent where this is required or permitted by law.

8. Use of sensitive personal information

Some special categories of personal data, such as information about health or medical conditions, are processed to comply with legal obligations (for example, in relation to contract-holders/residents with disabilities and for health and safety purposes).

9. How long is the data kept?

Your personal data will only be retained for as long as is necessary to fulfil the purposes for which it is collected, including any legal, accounting or reporting requirements. The period for which your data is held after the end of a occupation contract is seven years. The period for which your data is held following an unsuccessful occupation contract application is one year (for a contract-holder).

10. Who is information shared with?

Your information will be shared internally, including with staff members.
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The Agent also shares your data with third parties where required by law, where it is necessary in order to administer the relationship with you or where there is another legitimate interest in doing so. Information can be shared with:
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- Professional advisers, including surveyors, architects, valuers, quantity surveyors, structural engineers, solicitors and accountants;
- Freeholder and/or their managing agent (for property in block of flats);
- Existing or previous landlords;
- Existing or previous employers;
- Credit referencing agencies;
- Debt collectors and tracing services;
- Local authorities and government/public bodies;
- Ombudsman/redress schemes;
- Professional body/regulator;
- Courts/Tribunals;
- Police/enforcement agencies;
- Internet service providers;
- Banks/building societies;
- Contract-holder’s/resident’s next of kin or close relatives in case of emergency;
- Joint contract-holders and other residents;
- Guarantors;
- Joint owners of the property;
- Deposit Schemes;
- Universal Credit/housing benefit/other benefit administrator;
- H.M. Revenue and Customs;
- Council Tax authority;
- Utilities and service providers;
- Future owners of the property;
- Contractors and trades people providing services at the property;
- Prospective purchasers of property;

Other landlords including where you apply to another landlord for an occupation contract (or tenancy in England).
For contract-holders, residents, and guarantors, the Agent will share any personal data with the landlord client.
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The Agent will only store and/or transfer your personal data within the European Economic Area (the “EEA”). Transfers of personal data from the UK to the EEA are permitted without additional safeguards.

11. How is data protected?

The Agent takes the security of your personal data seriously. Internal policies and controls have been put in place to prevent your personal data being lost, accidentally destroyed, misused or disclosed. Details of these measures are available on request.

When the Agent engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and obliged to implement appropriate technical and organisational measures to ensure the security of data.

12. Your duty to inform us of changes

It is important that the personal data I/we hold about you is accurate and current. Please be sure to keep me/us informed if your personal data changes during the application process or during the course of an occupation contract.

13. Your Rights

As a data subject, you have a number of rights. You can:
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- access and obtain a copy of your data on request (known as a “data subject access request”);
- require the Agent to change incorrect or incomplete data;
- request erasure of your personal data. This enables you to ask the Agent to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- object to the processing of your data, if you believe your fundamental rights and freedoms outweigh our legitimate interests; and
- ask the Agent to suspend the processing of your personal data for a period of time if data is inaccurate or there is a dispute about its accuracy or the reason for processing it.
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If you would like to exercise any of these rights, or you have any questions about the privacy notice, please contact LIBERTAS LETTINGS LIMITED.
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If you believe that your data protection rights have not been complied with, you have the right to make a complaint to the Information Commissioner’s Office.