1.   Summary

This Notice relates to Carington Estates Ltd, Manor House Farm Partnership, Hon Rupert Carington, Moulsoe Buildings Farm, Toftleys Farm, Rt. Hon. Lord Carrington, Lord Carrington’s 1963 Settlement, Isabella Carington, Robert Carington, Daws Hill Farm Partnership, Hon R&V Carington, Ichabod Enterprises Ltd and Lord Carrington’s Charitable Settlement, hereinafter referred to as “The Carington Estate” or “The Estate”

The Carington Estate collects and processes data to deliver the services that we provide. These include property lettings, tenancy administration, rent collection, property maintenance, estate management, employment, farming, forestry, the promotion organisation and administration of facilities, events and activities, and the promotion supply and delivery of estate products.

This privacy notice summarises how and why we collect, protect and use your data, in line with the General Data Protection Regulation (GDPR), through appropriate policies, procedures and precautions. It also describes your rights in relation to that data.

2.   Sources of Information

The Carington Estate collects information from a variety of sources, including when you become or apply to become a tenant of one of our properties, enquire about or attend our activities and events, when you telephone, write to us, fax, e-mail, visit our offices, apply for employment, provide services to us or do business with us. We use Google Analytics to collect information when you visit our web site, which uses Cookies.

We operate CCTV and security systems at various locations and in our vehicles for the detection and prevention of crime. These operate continuously and records are held for up to one month.

We may take photographs at our properties, events and activities to use for marketing and publicity. However, identifiable photographs of individuals will only be used for those purposes with your consent.

We may receive personal information from third parties including:

• Previous landlords, employers and credit reference agencies
• Utility Companies and departments of local and central government
• Financial institutions
• Rightmove and letting agents

3.   Information we may collect

The information we may collect includes:

• Full name and title
• Date of birth
• Gender and marital status
• Nationality
• National Insurance number (your unique identifier).
• Contact details (phone, e-mail and correspondence address).
• Basic details (name and DOB) of other household residents.
• Banking and employment details
• Financial information including payment history
• References
• Photo ID, bank statements, payslips, utility bills
• (From our website) Information about your computer and about your visits to our website including IP address, browser, referral source and location

4.   Use and Storage of Information

The information we obtain is used to deliver our services and to manage your relationship with the Carington Estate.

The legal basis for the processing of this data is usually under the following paragraphs of the GDPR: Article 6 1.(b), the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, and Article 6 1.(f), it is in the legitimate interests of the data controller.

Our legitimate interest is the need to perform credit, anti money laundering and right-to-rent checks, to take up references as part of a tenancy or employment application or before doing business with you, to administer property lettings, tenancies, licences, employment, facilities, activities and events, to comply with repair and maintenance obligations within a tenancy agreement including legal obligations such as gas and electrical safety inspections and energy performance certificate requirements, to carry out estate management, farming, forestry and recreational activities, the supply of Estate products, to comply with relevant legislation and regulations, and for internal record keeping, reporting and business planning.

We will not collect any personal data from you that we do not need in order to provide and administer our services.

We operate a range of information and communications systems. Personal information is stored and managed on paper and electronically.

We take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. Where held electronically, information is located on servers within the European Union.

5.   Additional Activities

The Carington Estate carries out additional activities including the provision of film locations, operation of a caravan site, planning and development, property refurbishment, project management, solar generation, covenant administration, property acquisition and sale.

If your personal information is needed in order to carry out these additional activities, we will ask for your consent

6.   Property information

Much of the data that we hold relates to our properties and their maintenance and repair. We do not consider this to be personal information.

However, if your name, contact details or other personal information is used in conjunction with property information, such as to organise a property repair appointment, then this is treated as personal information.

7.   Data Sharing

In order to provide our services and/or meet our legal obligations, The Carington Estate may share information with third parties including contractors who carry out property repairs, inspections and assessments on our behalf. Our contractors are required to ensure that our data is managed appropriately.

The Carington Estate may also need to share personal information with government departments and agencies, with our accountants, tax advisers, solicitors and auditors, pension providers, insurers, credit reference agencies, financial organisations, utility companies, data storage services, consultants and with other organisations and agencies where we are legally allowed or obliged to do so.

8.   Data Retention

Detailed information relating to a tenancy or contract will be kept for as long as the agreement is active or where funds are outstanding on the account, and for a period not exceeding seven years afterwards. The basic history of who held a tenancy at which property and when will be held forever.

We will keep some records permanently if we are legally required to do so.  We may keep other records for an extended period of time, for example in order to defend or pursue claims, or for capital tax calculations.  We also have legal obligations to retain some data in connection with our statutory obligations.  We will keep data only for as long as we reasonably need it.

Any information we hold with your consent for marketing purposes will be kept until you notify us that you no longer wish to receive such information from us.

9.   Marketing and Privacy

We will only use your data for marketing purposes where we have your consent to do so.

We will not pass on your personal data to third parties for marketing purposes.

Where our website contains links to other websites we are not responsible for the privacy policies or practices of third party websites.

10.        Your rights

You have the right to request a copy of the data we hold about you. Please contact enquiries@carington.co.uk to request access to your personal data. We will respond within one month. There are no fees or charges for the first request but additional requests for the same personal data or requests which are manifestly unfounded or excessive may be subject to an administrative fee.

You have the right to correct information that we hold. Please advise us of any changes or corrections by contacting us on 01844 273508 or by email at enquiries@carington.co.uk. We will respond within one month.

You may withdraw your consent to use any information that was previously provided with your consent. Please advise us if you wish to withdraw any consent previously given on enquiries@carington.co.uk or 01844 273508

You have the right to object to our processing of your personal data on the basis of legitimate interest or to restrict it to certain purposes only. If we receive your objection, we will stop processing your data and delete it unless there are clear legitimate grounds for us to continue, in which case we will confirm the reason why it cannot be deleted (for example because we need it to comply with a legal obligation)

You also have other rights which can be seen by visiting the Information Commissioner’s Office (ICO) website at https://ico.org.uk/.

If you wish to raise a query or complaint relating to your personal data:

• In the first instance please contact our Data Protection Representative on 01844 273508 or e-mail enquiries@carington.co.uk
• If you remain dissatisfied, you have the right to refer the matter to the Information Commissioner. The Information Commissioner can be contacted at: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF – Tel: 01625 545745, email: enquiries@ico.gsi.gov.uk