West Ella Group is a collection of privately owned companies, trading residential property throughout the UK, made up of West Ella Holdings Ltd, West Ella Finance Ltd & West Ella Estates Ltd.

West Ella Group (“the Group”) respects your privacy and is committed to protecting your personal data.  This Privacy Notice states how we collect, store, use and retain personal data that we have obtained from individuals, including tenants of and applicants for our rented accommodation.

This Privacy Notice applies whenever you submit personal data to us, whether it be by using our website, by email, by post, over the telephone, in person or by any other means.

We are committed to ensuring that all personal data we hold is treated properly and in accordance with applicable data protection legislation (which includes the General Data Protection Regulation and the Data Protection Act 2018).  In accordance with data protection legislation we are required to explain to you how we will treat any personal data we collect from you.

The Group’s purpose is to provide tenants with quality housing.  The Group needs to use the data it holds on its tenants of, and applicants for, the Group’s rented accommodation in order to manage the Group’s business in furtherance of its purpose.

The Group includes: West Ella Holding Limited; West Ella Finance Limited; West Ella Estates Limited; Yorkshire Estates Limited; San Remo Towers Limited; Rothes & Aikenway Fishings Limited and includes all Bladon trusts and settlements involved in residential property ownership, trading and letting.

The controller responsible for your personal data is the Group company responsible for dealing with your rented accommodation or equity release.  If you have any queries about this Privacy Notice or your personal data please contact your normal Group contact using the contact details set out at the bottom of this Privacy Notice.

How do we collect information?
We obtain information from you when you:

• apply for rented accommodation or equity release;
• correspond with us by any means (including via the website, over the phone, by email or by post) with enquiries, complaints etc.;
•  become a tenant of our accommodation;
• request or obtain any services from us;
•  complete any forms or provide any information requested by us in relation to your accommodation and/or our services;
• choose to complete any surveys or research we send you;
• use our website.

What information do we collect and how do we use it?

1. If you contact us and you are not applying for rented accommodation or equity release
   
   If you have submitted a request, enquiry, complaint or correspondence to us, we will use any personal data you submit as necessary for our legitimate interest in responding to the relevant request, enquiry, complaint or correspondence.  We may keep a record of our communications with you to inform any future communication we have with you and to demonstrate how we communicated with you throughout.
2. If you apply for rented accommodation or equity release

When you apply to us for accommodation (or are named in an application submitted to us by someone else for accommodation) or when you apply for equity release, we may collect information about you from any related application form and from subsequent correspondence (whether by telephone, email or otherwise).  The personal data we collect might include:

• name;
• address;
• email address;
• telephone numbers;
• details regarding spouse and next of kin;
• financial information, such as bank account numbers, sort codes, payment card details and national insurance numbers used in payment for rent;
• any other personal data you disclose to us pursuant to your application.

By providing us with your information you will be providing us with your consent to us using any personal data provided for the purposes of processing your application for rented accommodation or equity release.
If you fail to provide certain information when requested which is necessary for us to consider your application, we may not be able to consider your application any further.

3. If you are a tenant

When we agree to provide you with rented accommodation, we will also use your information (including information collected during the application process as detailed above) as explained below:

• your contact details will be used to send you updates regarding your rented accommodation and our services (for example changes to your rent and your rights under applicable legislation).  We will also use your contact details to assist us with any accommodation or other issues, such as dealing with complaints or any other issues connected to your rented accommodation.  We will only process your personal data for this purpose where it is necessary for the performance of our agreement with you or where it is in our legitimate interests to do so;
• information that you provide to us for the purpose of submitting a request, enquiry, complaint or other correspondence will be used as necessary for our legitimate interest in responding to the relevant request, enquiry, complaint or correspondence.  We may also keep a record of our communications with you to inform any future communication we have with you and to demonstrate how we communicated with you throughout;
• information that you provide to us for the purpose of reporting a repair will be used by us for the purpose of reviewing the repair, reporting and administering the subsequent repair where we are under a contractual obligation to do so or where it is in our legitimate interest to do so;
• we may have to process your personal data to comply with a legal obligation to which we are subject (for example, any statutory obligations to HM Revenue & Customs or any requirements of health and safety law);
• we may use your personal data where necessary for our legitimate interests in administering and improving our services, complying with our regulatory requirements and for our own audit and assurance purposes.  Where we process particularly sensitive information for such purposes, we do so on the basis that the processing is necessary for the substantial public interest in providing effective rented accommodation and services; and
• if your image is captured in any general photograph that we take, we may use that photograph where necessary for our legitimate interests in publicising our activities and services.  You are free to object to us doing this at any time by contacting us using the contact details set out in this Privacy Notice.

We may request additional information from you from time to time in order to ensure that the services we are providing meet you requirements.

In limited circumstances, we may approach you for your consent to allow us to process certain personal data for purposes not referred to in this Privacy Notice.  If we do so, we will provide you with full details of the personal data we would like and the reason we need it, so that you can carefully consider whether you wish to consent.  If you do provide us with consent, you will be able to withdraw it at any time via any of the methods set out in this Privacy Notice.  Any such withdrawal will not affect the lawfulness of our processing of your personal data before you withdrew consent.

4. If you are using our website
   We may automatically collect data about you such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website (“Technical Data”) as you interact with our website.  We collect Technical data by using cookies and other similar technologies.  Such processing is based on our legitimate interests (to keep our website updated and relevant).

Sharing your information

• We may disclose your personal data:
• with third parties who are directly involved in dealing with any request, enquiry, complaint or other correspondence submitted by you;
• with service providers acting as processors who provide IT and system administration services;
• where such disclosure is required by law;
• where the disclosure is necessary to protect the interests of you or another person where you are physically or legally incapable of giving us your consent;
• with third parties who are providing us with professional advice where permitted by law;
• in connection with criminal investigations, legal proceedings or prospective legal proceedings where permitted by law;
• where necessary for our legitimate interests in establishing, exercising or defending our legal rights (including providing information to others for the purposes of fraud prevention) and where permitted by law; and
• where we have stated or informed you otherwise.

If you receive services from us which involve the services of a third party, we will pass information about you to that third party so they can provide you with those services on our behalf in accordance with our instructions.  For example, if we engage a third party to perform repairs at your accommodation on our behalf, we will disclose to the third party contractor such of your personal data (for example, name, address and contact information) as is reasonably required by the contractor in order to be able to access your accommodation and perform the repairs.

We may also disclose your personal data to third parties in the event that we propose to sell or buy any business or assets (in which case we may disclose your personal data to the prospective seller or buyer of such business or assets) or if we or substantially all of our assets are proposed to be acquired by a third party.  Any such disclosure will be made where necessary for the legitimate interests of us and/or the third party in respect of the proposed transaction; however we will not transfer your personal data to any such third party unless we are satisfied that they are able to provide an adequate level of protection in respect of your personal data.

Except as provided in this Privacy Notice, we will not provide or disclose your information to third parties without your consent for any purpose (including but not limited to direct marketing).  We do not sell personal data under any circumstances.

Security, retention and deletion of your personal data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know that information.

We have put in place procedures to deal with any suspected data security breach and will notify you and/or any applicable regulator of a suspected breach where we are legally required to do so.

Your Rights

If you have given your consent to us processing your personal data for any purpose (including for marketing purposes) you have the right to withdraw your consent at any time by contacting us using the contact details below.

You have a legal right to see a copy of the personal data that we keep about you and to require us to correct any inaccuracies, subject to certain exemptions.  In some circumstances you may also have the right to:

• request that we erase any personal data held about you;
• restrict our processing of your personal data (for example, to ask to suspend the processing of personal data to establish its accuracy or the reasons for processing it);
• data portability (i.e. to request the transfer of your personal data to a third party); and
• object to our processing of your personal data.

Requests in respect of the above should be made in writing using the contact details set out below.  We will respond to your request as soon as possible and, in any event, within one month from the date of receiving the request.  Please note that we may, where legally permitted, reject any such request or limit the scope of our response (e.g. if, in the circumstances, the right does not apply to you).

In accordance with applicable data protection legislation, we follow security procedures in the storage and disclosure of your information.  We may therefore request proof of your identity before complying with any other request of a nature described above.

You will not generally have to pay a fee to exercise any of your rights described above.  However, we may charge a reasonable fee if you make a request to see a copy of your personal data which is clearly unfounded or excessive.  Alternatively we may refuse to comply with your request in such circumstances.

You also have the right to lodge a complaint with the Information Commissioner’s Office if you are unhappy with the way in which we have processed your personal data.

How long do we keep personal data?

Any personal data held by us in relation to any of the purposes described in this Privacy Notice will be retained by us for as long as we need it to fulfil the purpose(s) for which it was collected (including the specific purposes of satisfying any legal, accounting or reporting requirements) and as may be required in order to defend or pursue actual or potential claims.  These periods are often set by statute (for example, 6 years in respect of certain contract claims).  Further details of our retention periods can be obtained by contacting us using the contact details set out below.  Your personal data will be securely destroyed at the end of the relevant retention period.

Whilst taking into consideration our legal obligations, we will on an ongoing basis:  review the length of time that we retain personal data for; consider the purpose or purposes for which we hold the personal data in deciding whether (and for how long) to retain it for; securely delete personal data that is no longer needed for such purpose or purposes; and update, archive or securely delete information if it goes out of date.

Changes to this notice

We may amend this Privacy Notice from time to time.  If we make any changes to the way in which we use your personal data we will notify you by writing to you or by sending you an e-mail.  We will also post a notice on our website’s homepage.  You can view the current version of our Privacy Notice at any time by accessing our website (https://westellagroup.co.uk/).

Contact Details
If you have any questions about this Privacy Notice or the personal data we hold on you, or if you wish to exercise any of your rights or raise any queries or complaints, please contact your normal Group contact:

Simon Bladon (South)
Jenkyn Place Estate Office,, Hole Lane, Bentley, Hampshire, GU10 5LU.
simon.bladon@westella.org

James Bladon (South)
West Ella Estates Ltd, Bitham House, Cutting Hill, Hungerford, RG17 0RW.
james.bladon@westella.org

John Bladon (North)
Hall Garth, Goodmanham, York, Y043 3HLX
alisonbladon@btinternet.com