QuadReal Residential Properties UK is committed to protecting the privacy and security of your personal information. This privacy policy describes how we collect, use and otherwise process your personal information, which we do in accordance with applicable data protection law, including the UK General Data Protection Regulation (UK GDPR).

QuadReal Residential Properties UK manages private rented accommodation and student accommodation in the UK.  In this policy, whenever you see the words ‘we’, ‘us’, ‘our’, or ‘QuadReal Residential Properties UK, it refers to QuadReal Residential Properties UK and the owners of the properties it manages.

• Residents (i.e. everyone living in a property)
• Residents’ guarantors
• Prospective residents and guarantors
• Residents’ guests
• Business customers
• Suppliers/contractors (including prospective)
• QuadReal Residential Properties UK website visitors
• Any other persons who are not employees of QuadReal Residential Properties UK

QuadReal Residential Properties UK is a ‘data controller’. This means that we are responsible for deciding how we collect, hold, use and otherwise process your personal information. We are required under data protection legislation to notify you of the information contained in this privacy policy. We may update this policy at any time as described below in this policy.

It is important that you read this privacy policy, together with any other privacy notice we may provide on specific occasions when we are collecting or otherwise processing your personal information, so that you are aware of how and why we are using such information.

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; and
• Kept securely.

Generally, we collect personal information directly from you, but we may also collect personal information from other sources, such as our affiliated companies in the QuadReal group, consumer reporting agencies, government agencies, employers universities or other educational institutions, and other third parties. For example:

• we collect credit information from credit reporting agencies if you apply to rent one of our properties or if you act as guarantor for a resident;
• we may request information about you from owners or landlords of properties that you have previously rented or lived in;
• we may request information about you from your current and former banks, credit unions, employers and educational institutions;
• we collect personal information from CCTV footage on the properties that we own and/or manage; and

we also may also collect information about you from other sources, such as public databases, publicly available internet searches and/or social media content. We limit the collection of personal information to that which is necessary for the purposes identified to you including those purposes specified below in this privacy policy.

Personal information (also known as personal data), means any information regarding an individual from which that person can be identified, or that can be linked with other information in order to identify that person. It does not include data where all identifying information has been removed (anonymous data).

We may collect, store, use and otherwise process the following categories of personal information about you for the purposes indicated below:

Lawful basis for processing

We will only use and otherwise process your personal information when data protection law allows us to.

Most commonly, we will process your personal information on one of the following lawful grounds as set forth in the UK GDPR:

• where the processing is necessary for the performance of a contract that we have entered into with you;
• Where the processing is necessary to enable us to comply with a legal obligation that applies to us; or
• where the processing is necessary for our legitimate interests (or those of a third party), provided those interests are not overridden by your fundamental rights and freedoms.

In some cases were may rely on one of the following additional lawful grounds:

• where we have requested, and you have granted, your consent (which you are free to withdraw at any time) to the processing;
• where the processing is necessary to protect your (or someone else’s) vital interests;
• where the processing is necessary for the performance of a task of ours that is carried out in the public interest; or
• where the processing is necessary for the purposes of a ‘recognised legitimate interest’ within the meaning of the UK GDPR.

Special category personal information

Where we process special category (also known as sensitive) personal information, including personal information concerning health (including welfare or disability), racial or ethnic origin, religious beliefs or sex life, we do so only where permitted by law and we rely on the following additional lawful grounds to process your special category personal data:

• where we have requested, and you have granted, your explicit consent (which you are free to withdraw at any time) to the processing;
• where the processing is necessary for purposes of employment, social security or social welfare law;
• where the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent;
• where you have clearly made your personal information public (eg, on social media);
• where the processing is necessary for legal proceedings, obtaining legal advice or establishing or defending legal claims;
• where the processing is necessary for reasons of substantial public interest specified in law (eg, fraud prevention, safeguarding or equality monitoring); or
• where the processing is necessary for reasons of public interest in the area of public health (eg, disease control or pandemic management).

We have suitable safeguards, policies and procedures in place to ensure this information is treated confidentially and is only accessed on a need-to-know basis by appropriately authorised persons.

In some circumstances where we are concerned about the welfare or behaviour of a resident we may share this information with third parties where necessary to protect the vital interest of the data subject or other persons, where necessary for reasons of substantial public interest specified by law, or in accordance with other lawful grounds permitted under data protection law. Where information of this nature is shared, it will usually be shared with one of the third parties listed below:

• Healthcare professionals (e.g. local authority mental healthcare team);
• Emergency services; or
• If applicable, a resident’s university/educational establishment (e.g. university welfare office) or a resident’s family or employer.

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 resident or a third party.

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 of the data privacy rights and freedoms of the resident.

Occasionally we may receive health data or other special category (or 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 which case we will inform you about this and securely delete such information unless you have provided explicit consent to us to retain it.

Our website may enable you to provide personal information to us. Given that the internet is a global environment, you acknowledge that by browsing our website and communicating electronically with us, your personal information may be transferred outside the UK as further described below in this privacy policy. .

Unfortunately, the transmission of information via the internet is not completely secure. We cannot guarantee the security of your personal information during its transmission to us through our website; any transmission is at your own risk. Once we have received your personal information we will implement appropriate information security measures as described below in this privacy policy.

Our website may, from time to time, contain links to third party websites which are operated by third parties and outside our control and are not covered by this privacy policy. If you access those third party websites using the links provided, the operators of those websites may collect personal information from and about you which will be used by them in accordance with their own privacy policy, which may differ from ours. We do not accept any responsibility or liability for these policies or for any products or services made available through those third party websites. Please carefully review those third party websites’ privacy policies, as well as those websites’ terms and conditions, before you submit any personal data to third parties through those websites.

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.

For example, we generally retain records relating to right to rent checks for one year after the tenancy ends and more general tenancy information is retained for around six to seven years from the end of the tenancy.

If you fail to provide certain personal information when requested, or if you subsequently withdraw your consent to the processing of such information, 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 or we may be unable to continue providing services or otherwise fulfilling our contractual or other relationship with you.

It is also very important that we keep your personal information accurate, complete and up-to-date, so please email our privacy contact at [TBC] promptly if your personal information changes and we will update our records accordingly.

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.

Please note that we may process your personal information without your knowledge or consent, where this is required or permitted by law.

Decisions based solely on automated decision-making take place when an electronic system uses personal information to make a decision about you without any meaningful human intervention.

If we carry out automated decision-making that produces legal effects for you or will similarly significantly affect you, on the basis of any special category (or sensitive) personal information, we must either:

• have your explicit written consent to process your special category personal data for the purpose of making the automated decision; or
• the automated decision must be necessary for entering into, or performing our contract with you, and the processing must be necessary for reasons of substantial public interest specified by law; or
• the automated decision must be required or authorised by law, and the processing must be necessary for reasons of substantial public interest specified by law,

and in each case, we must also put in place appropriate measures to safeguard your rights and legitimate interests, including the right for you to obtain human intervention in relation to such decision.

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 for profiling for purposes of providing you with targeted advertising. For example, we may use your personal data to provide you with products or services that we believe may be of interest to you. You can opt-out of receiving marketing messages from us at any time as explained below.

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 the privacy contact at the email address below [TBC]

We may share your personal information with third parties as listed below in this privacy notice.  In sharing personal information with these third parties, we take reasonable contractual and other measures to protect the personal information, specifically to ensure the third parties use the personal information only for the purposes for which we disclose it to them, and to process it with similar standards as set out in this privacy policy and in accordance with the law. 

We will also share your personal information with third parties where required by law, where it is necessary to administer our relationship with you or where we have another legitimate interest in doing so.

• IT service providers, including internet service providers, our head office IT system provider, web application service providers, data backup providers, mail hosting providers, customer management system providers, call recording system providers, postal package tracking system providers, asset tracking system providers, data hosting and processing service providers
• Organisations providing legal services to us
• Health and safety advisors
• Auditors, accountants, lawyers and other professional advisors who provide services to us
• 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 personal information
• Banks, credit unions, card payment gateways, merchant acquirers, and other financial services organisations
• Emergency services or other persons where we are required to act in urgent circumstances to protect the safety or security of residents, other persons or property
• Place of employment, universities and other educational establishments
• Local authorities and other governmental authorities (eg, where they are providing funding or conducting an investigation)
• Organisations requesting landlord references
• Investors
• Guarantors of residents
• QuadReal Residential Properties UK marketing agencies
• Contractors working for QuadReal Residential Properties UK including security contractors, maintenance contractors, IT contractors and other relevant contractors
• Our insurance providers
• To other QuadReal group entities
• to a buyer or other successor in the event of a divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our customers and residents is among the assets transferred
• to a buyer in a business transaction, for the purposes of their due diligence investigations. If the business transaction is completed, the parties to the transaction may use and disclose the personal information for carrying on the business or activity that was the object of the transaction, in accordance with data protection law
• if required to do so by law or legal process or if we are otherwise requested by any law enforcement officer or agency having demonstrated their right to access the personal information.

We may transfer the personal information we collect or otherwise process about you to countries outside the UK for the purposes specified above in this privacy policy. For example, we may transfer your personal information to other QuadReal group entities and our service providers located in countries outside the UK.

For example, we share personal information with:

– Yardi which is based in Canada and provides us with client relationship management services, including storage of residents’ data. This is in line with The Personal Information Protection and Electronic Documents Act (PIPEDA); and

– HubSpot which is based in the US and provides us with marketing and communications tools. HubSpot is subject to the US Data Privacy Programme and has the UK extension to the EU-US Data Privacy Framework.

Some countries and territories outside the UK may not have laws as protective of your personal information as the data protection laws that apply in the UK. However, we will make sure appropriate safeguards are in place before we transfer your personal information to countries outside the UK in accordance with UK data protection law; for example, by implementing specific contractual clauses (such as the UK ICO’s International Data Transfer Agreement) with entities with whom we share your personal information.

Under certain circumstances, by law you have the right to:

• Request confirmation from us as to whether we are processing your personal information and 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.
• 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 completed or corrected.
• Request erasure of your personal information. This enables you to ask us to delete your personal information where there is no permitted 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 successfully exercised your right to object to processing (see below).
• Object to the processing of your personal information on grounds relating to your particular situation where we are relying on a legitimate interest of ours (or of a third party) unless we can demonstrate compelling legitimate grounds for the processing. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of the processing of your personal information. This enables you to ask us to suspend the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
• Request to receive your personal information in a commonly-used, machine-readable format that enables you to transmit it to another controller (known as the ‘right to data portability’).

Please note that under data protection law, the rights described above are not absolute and they do not apply in all circumstances. If you want to exercise any of these rights, please email [TBC]. We will respond without delay and usually within one month of receiving your request. However, if we believe that dealing with your request may take longer, we will let you know.

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 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.

In the limited circumstances where you may have provided your consent to the collection, transfer and other processing 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 [TBC].  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.

If you have any questions about this privacy policy or how we handle your personal information, please email our privacy contact on [TBC].

If you have any complaints regarding our compliance with data protection legislation, please email the privacy contact at the email address here: [TBC]. We will respond without delay and usually within one month of receiving your request. However, if we believe that dealing with your request may take longer, we will let you know. mailto:dataprotection@realstargroup.com

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. You can find the ICO’s contact information at https://ico.org.uk/.

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We reserve the right to update this privacy policy at any time. When we do so we will display the updated privacy notice on this website. We encourage you to visit this website from time-to-time to view the most recent version of this privacy notice.