2.3 Our Data Protection Officer is Mr Chris Phillips, and can be contacted by email at email@example.com, by telephone on 07542 991 347, or by post at 5 School House Fold, Riddlesden, West Yorkshire BD20 5PF.
6. How do We use your data? 6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below. 6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes: 6.2.1 Providing and managing your Account; 6.2.2 Providing and managing your access to Our Site; 6.2.3 Supplying Our services to you of facilitating the tenancy process (please note that We require your personal data in order to enter into a contract with you); 6.2.5 Replying to emails from you; 6.2.6 Market research; and 6.2.7 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.§§§§§§§§ 6.3 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it. 6.4We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases): 6.5.1 the Company shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed. 6.5.2 Different types of personal data, used for different purposes, will necessarily be retained for different periods (and its retention periodically reviewed), as set out below. 6.6.3 When establishing and/or reviewing retention periods, the following shall be taken into account: (a) The objectives and requirements of the Company; (b) The type of personal data in question; (c) The purpose(s) for which the data in question is collected, held, and processed; (d) The Company’s legal basis for collecting, holding, and processing that data; and (e) The category or categories of data subject to whom the data relates. 6.6.4 If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria. 6.6.5 Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise). 6.6.6 In limited circumstances, it may also be necessary to retain personal data for longer periods where such retention is for archiving purposes that are in the public interest, for scientific or historical research purposes, or for statistical purposes. All such retention will be subject to the implementation of appropriate technical and organisational measures to protect the rights and freedoms of data subjects, as required by the GDPR. 7. How and where do We store your data? 7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it. 7.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under GDPR including: 7.2.1 Ensuring that appropriate technical and organisational measures are in place for treating the data safely and securely; 7.2.2 Obtaining the explicit and informed consent of the data subject to any data transfer; and 7.2.3 Ensuring that any data transfer is only necessary for the performance of a contract between us and the data subject i.e. for the services to be provided and no other reason; and 7.2.4 Ensuring that any transfer is necessary for the performance of a contract made in the interests of the data subject between us and another party. 7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site. 7.4 Steps We take to secure and protect your data include: Technical Data Security Measures: 7.4.1 All emails containing Personal Data must be encrypted; 7.4.2 All emails containing Personal Data must be marked ‘confidential’; 7.4.3 Personal Data may only be transmitted over secure networks; 7.4.4 Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative; 7.4.5 Personal Data contained in the body of an email, whether sent or received, shall only be available through a double password security system. 7.4.6 Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it; 7.4.7 Where Personal Data is to be transferred in hardcopy form, it should be passed directly to the recipient in accordance with this Policy; 7.4.8 All Personal Data transferred physically should be transferred in a suitable container marked “confidential”; 7.4.9 No Personal Data may be shared informally and if access is required to any Personal Data, such access should be formally requested from the DPO; 7.4.10 All hardcopies of Personal Data, along with any electronic copies stored on physical media should be stored securely; 7.4.11 No Personal Data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without authorisation; 7.4.12 Personal Data must be handled with care at all times and should not be left unattended or on view; 7.4.13 Computers used to view Personal Data must always be locked before being left unattended; 7.4.14 No Personal Data should be stored on any mobile device, whether such device belongs to the Company or otherwise without the formal written approval of the DPO and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary; 7.4.15 No Personal Data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the Company’s Data Protection Policy and the GDPR; 7.4.16 All Personal Data stored electronically should be backed up regularly with backups stored onsite. All backups should be encrypted; 7.4.17 All electronic copies of Personal Data should be stored securely using passwords and encryption; 7.4.18 All passwords used to protect Personal Data should be changed regularly and should must be secure;
7.4.19 All software should be kept up-to-date. Security-related updates should be installed as soon as reasonably possible after becoming available; 7.4.20 No software may be installed on any Company-owned computer or device without approval; and
Organisational Data Security Measures 7.4.23 The following organisational measures are in place within the Company to protect the security of personal data: 7.4.24 All employees and other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under the Company’s GDPR Policy; 7.4.25 Only employees and other parties working on behalf of the Company that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Company; 7.4.26 All employees and other parties working on behalf of the Company handling Personal Data will be appropriately trained to do so; 7.4.27 All employees and other parties working on behalf of the Company handling Personal Data will be appropriately supervised; 7.4.28 All employees and other parties working on behalf of the Company handling Personal Data should exercise care and caution when discussing any work relating to Personal Data at all times; 7.4.29 Methods of collecting, holding, and processing Personal Data shall be regularly evaluated and reviewed; 7.4.30 The performance of those employees and other parties working on behalf of the Company handling Personal Data shall be regularly evaluated and reviewed; 7.4.31 All employees and other parties working on behalf of the Company handling Personal Data will be bound by contract to comply with the GDPR and the Company’s GDPR Policy; 7.4.32 All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all relevant employees are held to the same conditions as those relevant employees of the Company arising out of the GDPR and the Company’s GDPR Policy; 7.4.33 Where any agent, contractor or other party working on behalf of the Company handling Personal Data fails in their obligations under the GDPR and/ or the Company GDPR Policy, that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.