1. What is the purpose of this policy?
2. Who are we?
3. Who does this private policy apply to?
- Residents guarantors
- Prospective residents and guarantors.
- Resident’s guests
- Business customers.
- Suppliers/contractors (including prospective).
- Corporate social responsibility/scholarship applicants.
- Job applicants
- Realstar website visitors.
- Any other persons who are not employees of Realstar
4. What are Realstar responsible of?
Realstar is a “data controller”. This means that we are responsible for deciding how we hold and use your personal information. We are required under data protection legislation to notify you of the information contained in this privacy notice. We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing your personal information, so that you are aware of how and why we are using such information.
5. Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date
- Kept only as long as necessary for the purposes we have told you about
- Kept securely
6. How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information on the following grounds:
- Contractual – where we need to perform a contract we have entered into with you.
- Legal requirement – where we need to comply with a legal obligation.
- Legitimate interests – 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.
- Vital interest – where we need to protect your interests (or someone else’s interests).
- Public interest – where it is required in the public interest or for official purposes.
7. What kind of personal information do we hold
Personal data, or personal information, means any information regarding an individual from which that person can be identified. It does not include data where identity has been removed (anonymous data).
We may collect, store, and use the following categories of personal information about you:
Categories of information
Purpose of processing personal information
Detailed personal information related to a tenancy application and the tenancy contract (e.g. tenancy start/end date, room number, age, sex, date of birth, ethnicity, income, National Insurance Number, private expenditure data, employment status, contact details, relationship status, address history, nationality, caring responsibilities, details of your next of kin, access to financial services such banks and credit unions, bank details, council tax, affability information, eligibility for UK residency)
Building management, referencing process, tenancy administration, marketing, fraud prevention, and staff training.
Bank account details & payment card information
To allow payments to be made or refunded, fraud prevention, tenancy administration.
Accounting data for resident/suppliers
To determine what resident/suppliers charges are paid/unpaid, fraud prevention and tenancy/contract administration, staff training.
Building management, tenancy administration, marketing, fraud prevention, staff training, and supplier account administration.
Emails to/from Realstar
Building management, tenancy administration, marketing, fraud prevention, complaint handling, staff training, and supplier account administration.
Proof of photo ID
To confirm a person’s identity for commercial and security purposes.
Residents proof of student status
To confirm a person’s student status for commercial and security purposes.
CCTV of communal areas of residential buildings
Building management, tenancy administration, fraud prevention, complaint handling, staff training, security and welfare.
Electronic door access logs
Building management, tenancy administration, fraud prevention, complaint handling, security and welfare.
Web live chat discussions
Tenancy administration, marketing, fraud prevention, complaint handling, staff training.
Web traffic data and IP address/location of visitors to the Realstar website
Marketing, fraud prevention.
Resident postal package delivery data
To permit resident deliveries to be administered in the building, fraud prevention.
Accident book data
Building management, complaint handling, security and welfare, health and safety.
To permit Realstar to provide landlord references for residents.
Asset tracking data
To permit Realstar to lend residents portable items (e.g. irons, games consoles etc).
Resident health data for disabled residents (e.g. personal emergency evacuation plans)
To permit Realstar to plan evacuation and evacuate disabled students in a safe manner. To permit Realstar to provide additional support to disabled residents where required.
Resident welfare and behavioural information (further details on how we might share this information can be found later in this policy).
To permit Realstar to safeguard residents and other 3rd parties within our residential buildings.
Resident health data provided by residents without this information being requested by Realstar
To allow Realstar to receive to receive unrequested health information from residents.
Data provided by resident in the form of a market research questionnaire
To allow Realstar to better understand the student accommodation sector and the preferences of Realstar customers.
Personal data related to corporate social responsibility programmes or scholarship applicants
To allow management of CSR and scholarship programs.
Personal data related to individuals applying for work at Realstar
To allow Realstar to review applications of potential new staff members or individuals seeking work experience.
Personal data related to suppliers/contractors
To allow Realstar to manage supplier/contractor relationships.
Personal data related to business customers
To allow Realstar to manage business customer relationships.
8. Sharing welfare or behavioural information
In some circumstances where we are concerned about the welfare or behaviour of a resident we may share this information with third parties either in the vital interest of the data subjects, the public interest, or in accordance with other exceptions permitted under data protection law. Where information of this nature is shared, it will usually be one of the third parties listed below:
- The tenant’s university/educational establishment (e.g. university welfare office).
- Healthcare professionals (e.g. local authority mental healthcare team).
- Emergency services.
We have suitable safeguards, policies and procedures in place to ensure this information is treated confidentially and is only shared with third parties after careful consideration.
We may share this data without consent of the data subject especially where it is in the public interest or the vital interests of the tenant.
In highly exceptional circumstances, we may also contact next of kin to share welfare or behavioural information. However any decision to share this information can only be authorised at the highest level of the organisation and after careful consideration for the data privacy rights and freedoms of the resident.
9. Unrequested health data or other sensitive data
Occasionally we may receive health data or other sensitive data from a resident without having requested this information. An example of this being when a resident may email us a doctor’s letter that we have not requested. In this situation, we will deem that the tenant has provided explicit consent for us to process this data.
10. Internet data
Given that the internet is a global environment, using the internet to collect and process User Data necessarily involves the transmission of data on an international basis. Therefore, by browsing our Site and communicating electronically with us, you acknowledge and agree to our processing of your User Data in this way.
11. How long will we retain your information for?
We will only retain your personal information for as long as it is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements and limitation periods.
12. If you fail to provide personal information
If you fail to provide certain vital information when requested, we may not be able to perform or complete the referencing process that will allow us to enter into a tenancy contract into with you.
13. Change of purpose
We will only use your personal information 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 we need to use your personal information for a different 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 information without your knowledge or consent, where this is required or permitted by law.
14. Automated decision-making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
- Where we have notified you of the decision and given you 21 days to request a reconsideration.
- Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
Personal data provided to us may be profiled to help us with targeted advertising. For example, we may use your personal data to find online users with a similar profile to yourself who may be interested in our products or services.
16. Opting Out
You can ask us to stop sending you marketing messages at any time by either following the opt-out links on any marketing message sent to you or by contacting us at any time.
17. Data Sharing
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
18. Who will we share your personal information with
- IT service providers, including internet service providers, head office IT system provider, web application service providers, data backup providers, mail hosting providers, customer management systems, call recording systems, postal package tracking systems, asset tracking systems
- Organisations providing legal services
- Health and safety advisors
- Auditors, accountants, lawyers and other professional advisors
- Utility companies and Council Tax offices to ensure billing details are correct
- If you default on any tenancy or licence conditions, information about you may be provided to authorised debt recovery agencies, to enable them to recover the debt. This may affect future applications for tenancies, credit and insurance
- We may pass data about your rent payment record to credit reference agencies. This will enable them to assist other organisations to assess your financial standing if you apply for products and services
- Statutory bodies where we are required to share data
- Banks, card payment gateways, merchant acquirers, and other financial services organisations
- Debt collectors and credit reference agencies
- Emergency services
- Universities and other educational establishments
- Local authorities
- Organisations requesting landlord references
- Realstar marketing agencies
- Contractors working for Realstar including security contractors, maintenance contractors, IT contractors and other relevant contractors
- Other entities within the Realstar group
19. Transferring information outside the EU
We may transfer the personal information we collect about you to the following countries outside the EU in order to perform our contract with you:
- Jersey, Channel Islands.
Jersey, Channel Islands: There is an adequacy decision by the European Commission in respect of this country. This means that the country to which we transfer your data are deemed to provide an adequate level of protection for your personal information.
Canada: For transfers to Canada, we ensure the third party is in line with The Personal Information Protection and Electronic Documents Act (PIPEDA).
Worldwide: Our tenant guarantors are located worldwide. When contacting these guarantors we put in place suitable safeguards and utilise the GDPR minor transfer exemption to allow us to contact them.
20. Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to the processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please email firstname.lastname@example.org
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that no personal information is disclosed to any person who has no right to receive it.
21. Data Security
Information system and data security is imperative to us to ensure that we are keeping our customers and contractors safe.
We operate a robust and thorough process for assessing, managing and protecting new and existing systems which ensures that our systems are up to date and secure against the ever changing data protection threat landscape.
Our staff complete mandatory information security and data protection training annually to reinforce responsibilities and requirements set out in our information security policies.
We have put in place procedures to identify any suspected personal data breach and will notify you and any applicable regulator of a breach wherever we are legally required to do so.
22. Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact email@example.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
23. You have the right to complain
If you have any questions about this privacy notice or how we handle your personal information, please email firstname.lastname@example.org.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) at https://ico.org.uk/, the UK supervisory authority for data protection issues
The legal entities in the table below represent the ‘joint data controllers’ within the Realstar group. The contact address for all these organisations is 1st Floor, 7a Howick Place, London SW1P 1DZ
Allman R2 LP
Beatles R2 LP
Dylan (Jersey) Ltd
Elvis (Jersey) Ltd
Fleetwood (Jersey) Ltd
Newington Butts Management Limited
Presley (Jersey) Ltd