PRIVACY POLICY

This Privacy Policy lets you know how we deal with any personal data you give to us, or any that we may collect from or about you. It applies to all our staff, contractors, customers and anyone else who may provide us with personal data.

Seafield Estate recognises the GDPR and is actively working towards compliance with that Regulation. Seafield Estate is the Data Controller for the personal data which you provide to the following businesses: -

The Rt. Hon. The Earl of Seafield
The Rt. Hon. The Countess of Seafield
The Reidhaven Trust
The Hon. Alexander Ogilvie-Grant
Old Cullen Farms Partnership
Seafield Rural
Reidhaven Farms
The Seafield Heirs 2009 Trust
The Seafield 2015 Agricultural Trust
Dava Enterprises Limited
Seafield Builders Limited

We have a Data Protection Officer (DPO) who can be contacted at the following address:

Data Protection Officer
Seafield Estate Office
Cullen
Buckie
AB56 4UW
01542 840777
mail@seafield-estate.co.uk

This privacy policy tells you how we will collect and use your personal data to enable us to carry out our property management services, promote and advertise our services, maintain our own accounts and records, support and manage our employees and provide information to data subjects.

Personal data

Under the EU's General Data Protection Regulation (GDPR) personal data is defined as:

"any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person."

Transfers

It may sometimes be necessary to transfer personal information overseas. When this is needed information is only shared within the European Economic Area (EEA). Any transfers made will be in full compliance with all aspects of the General Data Protection legislation.

Consent

Consent is required for Seafield Estate to process your personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by contacting our data protection officer using the details above.

To comply with our legal obligations, we need your explicit consent before we process data concerning:

  • Some direct marketing communications;
  • Processing of special categories of personal data such as health, criminal records or credit reference checks.

Why does Seafield Estate need to collect and store personal data?

For us to carry out property management services; promote and advertise our services; maintain our own accounts and records, support and manage our employees and provide information to data subjects. we need to collect personal data.

Personal data will be collected and processed only to the extent that it is needed to fulfil business needs or legal requirements. We will not collect excessive information which is not relevant to the purpose intended.

All collection of personal information for the purposes of running our business is done so on the basis of contractual necessity.

Where personal information relates to business contacts or potential customers, collection and retention is on the basis of legitimate interest. We do take into consideration the balance between our interests and yours.

We are committed to ensuring that the information we collect, and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

What Kind of Personal Data about you do we process?

Types and classes of data processed and relevant to this can include:

  • Personal details;
  • Family details;
  • Lifestyle and social circumstances;
  • Employment and education details;
  • Services we provide;
  • Financial details; and
  • Data contained in references.

To meet our obligations under UK law we also process sensitive classes of data that may include:

  • Racial or ethnic origin;
  • Religious or other beliefs;
  • Trade Union membership; and
  • Physical and mental health details.

What is the source of the personal data we collect about you?

We collect data from the following general sources depending on your relationship to us:

  • Customers;
  • Tenants;
  • Professional advisors and consultants;
  • Complainants/enquirers
  • Suppliers;
  • Landlords; and
  • Staff.

For what purposes do we use your personal data?

Seafield Estate uses data to enable us to: carry out property management services, promote and advertise our services, maintain our own accounts and records, support and manage our employees and provide information to data subjects.

What are the legal grounds for collecting and processing your personal data?

We collect and use your personal data to help us meet our legal obligations.

What are the legitimate grounds in collecting and processing your personal data?

Any legitimate interests pursued by us, or third parties we use, are as follows:

  • Where it is needed to provide you with our products and services;
  • When it is within our legitimate interests to do so;
  • To comply with legal and regulatory obligations; and
  • With your explicit consent.

When do we share your personal data with other organisations?

We sometimes need to share the personal information we process with the individual them self and with other organisations. Where this is necessary we are required to comply with all aspects of the General Data Protection Regulation. What follows is a description of the types of organisations we may need to share some of the personal information we process with for one or more reasons.

Where necessary or required, we share information with:

  • business associates;
  • suppliers of goods or services;
  • financial organisations;
  • credit reference agencies;
  • debt collection and tracing agencies;
  • local and central government;
  • police forces;
  • security organisations;
  • current, past and prospective employers;
  • employment and recruitment agencies;
  • Educators, trainers and examining bodies; and
  • other companies in the same group.

Will Seafield Estate share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to Seafield Estate during our dealings dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Seafield Estate's procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

How will Seafield Estate use the personal data it collects about me?

Seafield Estate will process (collect, store and use) the information you provide in a manner compatible with the EU's General Data Protection Regulation (GDPR). We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. Seafield Estate is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

For how long is your personal data retained by us?

Seafield Estate will process personal data for the duration of your contract or business with us or longer where we have a legitimate reason or legal obligation to do so.

Under what circumstances will Seafield Estate contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to measures and procedures to minimize the risk of unauthorised access or disclosure.

Can I find out the personal data that you hold about me?

Seafield Estate, at your request, can confirm what information we hold about you and how it is used:

Contact details of the data protection officer, where applicable;

  • The purpose of the processing as well as the legal basis for processing;
  • If the processing is based on the legitimate interests of Seafield Estate or a third party, information about those interests;
  • The categories of personal data collected, stored and processed;
  • Recipient(s) or categories of recipients to whom the data is/will be disclosed;
  • If we intend to transfer the personal data to a third country or international organization, information about how we ensure this is done securely. (The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information);
  • How long the data will be stored;
  • Details of your rights to correct, erase, restrict or object to such processing;
  • Information about your right to withdraw consent at any time;
  • How to lodge a complaint with the supervisory authority;
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data;
  • The source of personal data if it wasn't collected directly from you; and
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?

Seafield Estate accepts the following forms of ID when information on your personal data is requested:

  • Passport;
  • Driving license;
  • Birth certificate; and
  • Utility bill (from last 3 months).

Changes to this privacy notice

We may change the privacy notice to reflect changes in the law and/or our privacy practices.

Disclosure

Seafield Estate will not pass on your personal data to third parties without first obtaining your consent or unless legally obliged to do so.

Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • The right to be informed about processing of your personal data;
  • The right to have your personal data corrected if it is inaccurate;
  • Right of access: you have the right to request a copy of the information that we hold about you;
  • Right of rectification: you have a right to correct data that we hold about you that is inaccurate or incomplete;
  • Right to be forgotten: in certain circumstances you can ask for the data we hold about you to be erased from our records;
  • Right to restriction of processing: where certain conditions apply to have a right to restrict the processing;
  • Right of portability: you have the right to have the data we hold about you transferred to another organisation;
  • Right to object: you have the right to object to certain types of processing such as direct marketing;
  • Right to object to automated processing: including profiling - you also have the right to be subject to the legal effects of automated processing or profiling; and
  • Right to judicial review: if Seafield Estate refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined.

Do you have to provide your personal data to us?

In certain circumstances you have a legal requirement to provide us with personal data. In order for us to interact with you and provide you with services or for us to utilise your services it will be necessary for you to provide us with personal data and express permission to use that data.

What to do if your personal data changes

If your personal data changes you may have a legal obligation to inform us to correct the information we hold about you to enable us to process that data to carry out our business. While we will make periodic contact to confirm the accuracy of data it is in your interest to ensure the data we hold is updated should it change.

Complaints

If you wish to make a complaint about how your personal data is being processed by Seafield Estate or third parties, or how a complaint has been handled, you have the right to lodge a complaint directly Seafield Estate's Data Protection Officer or with the supervisory authority.