At Hallmark, we take care of all aspects of financial management; taking responsibility for the collection of ground rent, service charges and reserve funds.

  • Services


    At Hallmark, we take care of all aspects of financial management; taking responsibility for the collection of ground rent, service charges and reserve funds.


  • Services


    We also ensure a thorough day-to-day management of sites. We can be reached 24/7. Our Property Managers visit sites on a regular basis in order to ensure the best service to our residents.


  • Services


    Before any contractor can work on any site managed by us, the contractor must complete a Health & Safety questionnaire in order that we can ensure that the contractor has knowledge of and adopts safe working practices, is financially viable and operates non-discriminatory employment polices.


Good financial management of the service charge and reserves is essential to enable the property to be properly maintained.

All Hallmark's client funds, including ground rent, service charge and reserve funds are held in separate statutory trust client bank accounts. The funds held on behalf of our clients are held with Barclays Bank PLC.

Hallmark is always looking to add value to the service provided and, with that in mind, has invested heavily in both its IT hardware and software infrastructure. We recently upgraded the property management software we use to the Propman system, a highly sophisticated software package. We will be shortly introducing on-line facilities to allow our customers to view their accounts, make payments and give access to accounting and management information.

Annual Budget

In the months prior to the start of each service charge year, Hallmark will prepare the draft service charge budget and reserve fund programme, for agreement with the client. Following approval by the client and prior to the start of the new service charge year, the budget is issued to all lessees together with an explanatory letter.

During the course of the service charge year we monitor the expenditure against budget.

Collection of Funds

The timely collection of the service charges is important for the smooth running of your property. Most lessees pay their service charges when requested but, for those that do not, we follow a strict procedure which ensures the efficient collection of funds within set timescales.

Site Visits

Frequent site visits are a very important part of the property management process. A designated Property Manager is responsible for the day to day contact with the client and where applicable for managing the on-site staff. During the site visits the Property Manager reviews the work being carried out, checks for any additional maintenance issues and is available for meetings.

Face to face, or personal contact is vital for good communication with residents. We advise residents and keep them informed of the relevant issues in a number of ways, which can be tailored to suit the needs of individual developments. These could include, for example, a welcome pack, newsletters, circular letters or a residents' website.

Responding to Requests

Our office hours are 9.00 am to 5.30 pm Monday to Friday. In addition, we can be contacted 24/7 and the relevant numbers will be made available.

Record keeping

All the information we hold is subject to the Data Protection Act and is not released to third parties without prior written consent.



Contracts and Contractors

We have a robust code of conduct which all of our contractors must comply with. In order for a contractor to be employed on any development that we manage they must first of all apply to go on our approved contractors list. This process will include the contractor supplying us with information on their insurance and safe working methods.

The contractor must complete a questionnaire in order that we can ensure that the contractor has knowledge of all Health & Safety requirements and adopts safe working practices, is financially viable and operates non-discriminatory employment policies. The quality of all works is assessed and the cost of works is continually monitored to ensure that value for money is being obtained.

We always obtain at least three competitive tenders in respect of any major works.

We place the buildings insurance through FCA regulated agencies that go to the market and obtain quotations from major insurers.

Major Works

We would recommend that we carry out an audit of all the items that need to be maintained within each development and we would ensure that the relevant contracts are in place.

It is essential that there are sufficient reserve funds available to meet the cost of programmed works when they fall due. In order to provide for this a long term reserve fund programme should be prepared. We can arrange for the appropriate specialist to do this if required.

Site staff

Hallmark administers all standard payroll functions for on-site staff.

We can also provide, at a small additional cost, insurance-backed legal services, whereby the employer will be indemnified in the event of claims being made against them in respect of employment law. This will also include awards made by a tribunal.

Hallmark Property Management Limited

 

Data Protection Compliance Policy - General

 

This document demonstrates our commitment to protecting the privacy and security of your personal information. It contains information regarding how we collect and use personal data or personal information about you in accordance with the General Data Protection Regulation (GDPR) and all other data protection legislation currently in force. 

 

Pursuant to that legislation, when processing data we will;

 

  • process it fairly, lawfully and in a clear, transparent way
  • collect your data only for reasons that we find proper for the course of your employment in ways that have been explained to you
  • only use it in the way that we have told you about
  • ensure it is correct and up to date
  • keep your data for only as long as we need it
  • process it in a way that ensures it will not be lost or destroyed or used for anything that you are not aware of or have not consented to (as appropriate)

 

Hallmark Property Management is a “data controller”. This means that we are responsible for determining the purpose and means of processing personal data relating to you.

 

“Personal data”, or “personal information”, means any information relating to an identified, or identifiable individual in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

There are “special categories” of sensitive personal data, meaning data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, , physical or mental health conditions, sex life or sexual orientation, genetic data, and biometric data which require a higher level of protection.

 

This data protection compliance statement (privacy notice) applies to all lessees, tenants and third parties whose data is stored on our system.

   


DETAILS OF INFORMATION WE MAY HOLD ABOUT YOU  

  

The list below identifies the kind of data that we will hold about you:

 

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
  • Emergency contacts or next of kin and their details
  • Bank account details  
  • Complaints and compensation history
  • Service charge payment history
  • Information about your health, including any medical conditions and disabilities where it affects your living conditions and or ability to pay service charges
  • Genetic information and biometric data
  • Criminal activity where we need to comply with law enforcement
  • Data from estate agents and other third parties
  • Data we must provide to and hold from insurance companies as part of any claims
  • Data we must provide to contractors for example to access your property, with your consent
  • Data we must provide to experts, such as surveyors.

 

 

METHOD OF COLLECTION OF PERSONAL INFORMATION

 

Your personal information is obtained through the handover of the development to us in order to manage the site or from your solicitors on your purchase. Further information will be collected directly from you as appropriate, for example, your bank and emergency contact details. Data may be collected during the course of your occupation at the development to enable our effective management.

 

PROCESSING INFORMATION ABOUT YOU  

 

We will only administer personal information in accordance with the lawful bases for processing. At least one of the following will apply when we process personal data:

 

  • Consent: You have given clear consent for us to process your personal data for a specific purpose.
  • Lease: The processing is necessary for the terms of the lease you have.
  • Legal obligation: The processing is necessary for us to comply with the law (not including contractual obligations).
  • Vital interests: the processing is necessary to protect someone’s life.
  • Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
  • Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests.

 

LAWFUL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

 

We consider that the basis for which we will process the data contained in the list above (see section above - details of information we will hold about you) is necessary for the performance of the terms of the lease and to enable us to comply with our legal obligations. Occasionally, we may process personal information about you to pursue legitimate interests of our own or those of third parties, provided there is no good reason to protect your interests and your fundamental rights do not override those interests.

The circumstances in which we will process your personal information are listed below. 

 

  • Making decisions about debt collection
  • Responding to requests from third parties such as the landlord or your solicitor.
  • Maintaining comprehensive up to date personnel records about you to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in the event of an emergency are maintained
  • Effectively monitoring of both yours and your neighbours conduct in the event of disputes or complaints.
  • Gaining expert opinion on the site where you live when making decisions about any changes or improvements.
  • Managing statutory obligations and Health & Safety.
  • Business planning and restructuring exercises
  • Dealing with legal claims made against us
  • Preventing fraud
  • Ensuring our administrative and IT systems are secure and robust against unauthorised access

There may be more than one reason to validate the reason for processing your personal information.

 

LAWFUL BASIS FOR PROCESSING “SPECIAL CATEGORIES” OF SENSITIVE DATA

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

 

  • Consent: You have given clear consent for us to process your personal data for a specific purpose.
  • Lease: The processing is necessary for the terms of the lease, or because we have been asked to take specific steps by the landlord.
  • Legal obligation: The processing is necessary for us to comply with the law (not including contractual obligations) and meets the obligations under our data protection policy.
  • Vital interests: the processing is necessary to protect someone’s life.
  • Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law and meets the obligations under our data protection policy. (For example in the case of equal opportunities monitoring)
  • Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests. (For example to assess your capacity to work on the grounds of ill health)

Occasionally, special categories of data may be processed where you are not capable of giving your consent, where you have already made the information public or in the course of legitimate business activities or legal obligations and in line with the appropriate safeguards.

 

Examples of the circumstances in which we will process special categories of your particularly sensitive personal information are listed below (this list is non-exhaustive): 

 

  • In order to protect your Health and Safety at the development
  • To determine if reasonable adjustments are needed or are in place
  • To comply with the requests of the landlord

 

Where appropriate, we may seek your written authorisation to process special categories of data. Upon such an occasion we will endeavor to provide full and clear reasons at that time in order for you to make an informed decision. In any situation where consent is sought, please be advised that you are under no contractual obligation to comply with a request. Should you decline to consent you will not suffer a detriment.

 

INFORMATION ABOUT CRIMINAL CONVICTIONS  

 

Information regarding criminal convictions may be processed in accordance with our legal obligations. Occasionally we may process such information to protect yours, or someone else’s interests and you are not able to give your consent or we may process such information in cases where you have already made the information public. Such information may be sought as part of a criminal investigation.

 

AUTOMATED DECISION-MAKING

 

We do not anticipate that any of our decisions will occur without human involvement. Should we use any form of automated decision making we will advise you of any change in writing.

 

SHARING DATA  

 

Your data will be shared with the landlord or colleagues within the Company where it is necessary for them to undertake their duties. This includes, for example, the head of the department for their management of the site, the legal department for maintaining personnel records and the accounts department for administering payments under your lease.

 

It may be necessary for us to share your personal data with a third party or third party service provider (including, but not limited to, contractors, agents or other associated/group companies) within, or outside of, the European Union (EU). Data sharing may arise due to a legal obligation, as part of the performance of a contract or in situations where there is another legitimate interest (including a legitimate interest of a third party) to do so.

The list below identifies which activities are carried out by third parties on our behalf:

 

  • Contractors
  • Surveyors
  • Legal advisors
  • Security
  • Insurance providers
  • On site staff
  • Landlord

 

Data may be shared with 3rd parties in the following circumstances:

 

  • In the process of regular reporting activities regarding our performance,
  • With regards to a business or group reorganisation, sale or restructure,
  • In relation to the maintenance support and/or hosting of data
  • To adhere with a legal obligation
  • In the process of obtaining advice and help in order to adhere with legal obligations

 

If data is shared, we expect third parties to adhere and comply with the GDPR and protect any data of yours that they process. We do not permit any third parties to process personal data for their own reasons. Where they process your data it is for a specific purpose according to our instructions.

 

We do not anticipate that we will transfer data to other countries.

 

DATA SECURITY  

 

As part of our commitment to protecting the security of any data we process. If you would like further details please contact Sonya Galvin or Tanya Vyas.

 

In addition, we have put further security measures in place to avoid data from being accessed, damaged, interfered with, lost, damaged, stolen or compromised. In cases of a breach, or suspected breach, of data security you will be informed, as will any appropriate regulator, in accordance with our legal obligations.

 

Any data that is shared with third parties is restricted to those who have a business need, in accordance with our guidance and in accordance with the duty of confidentiality.

 

DATA RETENTION  

 

We anticipate that we will retain your data as part of the recruitment process for no longer than is necessary for the purpose for which it was collected.

We have given consideration to the following in order to decide the appropriate retention period:

 

  • Nature
  • Sensitivity
  • Risk of harm
  • Purpose for processing
  • Legal obligations

 

At the end of the retention period, upon conclusion of any contract we may have with you, or until we are no longer legally required to retain it, it will be reviewed and deleted, unless there is some special reason for keeping it. Occasionally, we may continue to use data without further notice to you. This will only be the case where any such data is anonymised and you cannot be identified as being associated with that data

 

YOUR RIGHTS IN RELATION TO YOUR DATA  

 

We commit to ensure that any data we process is correct and up to date. It is your obligation to make us aware of any changes to your personal information.

 

In some situations, you may have the;

 

Right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice. 

Right to request access. You have the right to access the data that we hold on you. To do so, you should make a subject access request

Right to request correction. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it.

Right to request erasure. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.

Right to object to the inclusion of any information. In situations where we are relying on a legitimate interest (or those of a third party) you have the right to object to the way we use your data where we are using it.

Right to request the restriction of processing. You have the right to ask us to stop the processing of data of your personal information. We will stop processing the data (whilst still holding it) until we have ensured that the data is correct.

Right to portability. You may transfer the data that we hold on you for your own purposes. 

Right to request the transfer. You have the right to request the transfer of your personal information to another party.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

 

If you wish to exercise any of the rights explained above, please contact Sonya Galvin or Tanya Vyas

 

 

Consequences of your failure to provide personal information

 

If you neglect to provide certain information when requested, it may affect our ability to enter into or continue with our management, and it may prevent us from complying with our legal or contractual obligations.

 

Change of purpose for processing data

 

We commit to only process your personal information for the purposes for which it was collected, except where we reasonably consider that the reason for processing changes to another reason and that reason is consistent with the original basis for processing. Should we need to process personal information for another reason, we will inform you of this and advise you of the lawful basis upon which we will process.

 

Important note: We may process your personal information without your knowledge or consent, in compliance with the above rules (see above section - lawful basis for processing your personal information).

 

QUESTIONS OR COMPLAINTS

 

It is the responsibility of our Data Protection Officer (DPO) to oversee compliance with this statement. Should you have any questions regarding this statement, or how we process your personal information, please contact Sonya Galvin or Tanya Vyas. 

 

The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.

 

 

 

Hallmark Property Management Limited

 

Data Protection Compliance Policy For Clients

 

 

This document demonstrates our commitment to protecting the privacy and security of your personal information. It contains information regarding how we collect and use personal data or personal information about you in accordance with the General Data Protection Regulation (GDPR) and all other data protection legislation currently in force. 

 

Pursuant to that legislation, when processing data we will;

 

  • process it fairly, lawfully and in a clear, transparent way
  • collect your data only for reasons that we find proper for the course of your contract with us.
  • only use it in the way that we have told you about
  • ensure it is correct and up to date
  • keep your data for only as long as we need it
  • process it in a way that ensures it will not be lost or destroyed or used for anything that you are not aware of or have not consented to (as appropriate) 

 

Hallmark Property Management Limited is a “data controller”. This means that we are responsible for determining the purpose and means of processing personal data relating to you.

 

“Personal data”, or “personal information”, means any information relating to an identified, or identifiable individual in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of that natural person.

There are “special categories” of sensitive personal data, meaning data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health conditions, sex life or sexual orientation, genetic data, and biometric data which require a higher level of protection.

 

This data protection compliance statement (privacy policy) applies to all Hallmark’s clients.

   


DETAILS OF INFORMATION WE WILL HOLD ABOUT YOU   

 

The list below identifies the kind of data that we will hold about you:

 

  • contact details such as name, title, addresses, telephone numbers, and email addresses
  • where necessary - bank account details, payroll records and tax codes
  • location of workplace
  • Information including job titles, job descriptions, professional membership and other terms and conditions relating to your contract with us
  • company history - related company documentation.
  • information and relevant communications regarding site or development
  • CCTV footage and other information obtained through electronic means such as building entry records
  • information about your use of our information and communications systems
  • the following list identifies the kind of data that that we will process and which falls within the scope of “special categories” of more sensitive personal information:
  • genetic information and biometric data

 

METHOD OF COLLECTION OF PERSONAL INFORMATION

 

Your information is obtained through the application and tendering processes, this may be directly from you, or third party recommendations. Further information will be collected directly from you when we are engaged at the start of the contract, for example, your bank details and health & safety records for our compliance. Other details may be collected directly from you in the form of official documentation. Data may be collected during the course of your engagement with us to enable its continued existence or development.

 

PROCESSING INFORMATION ABOUT YOU  

 

We will only administer personal information in accordance with the lawful bases for processing. At least one of the following will apply when we process personal data:

 

  • consent: You have given clear consent for us to process your personal data for a specific purpose.
  • contract: The processing is necessary for a contract we have with you, or because we have asked you to take specific steps before entering into a contract.
  • legal obligation: The processing is necessary for us to comply with the law (not including contractual obligations).
  • vital interests: the processing is necessary to protect someone’s life.
  • public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
  • legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests.

 

 

LAWFUL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

 

We consider that the basis for which we will process the data contained in the list above (see section above - details of information we will hold about you) is necessary for the performance of the contract we have with you and to enable us to comply with our legal obligations. Occasionally, we may process personal information about you to pursue legitimate interests of our own or those of third parties, provided there is no good reason to protect your interests and your fundamental rights do not override those interests.

 

The circumstances in which we will process your personal information are listed below. 

 

  • making decisions about the contacts and subsequent appointments, etc.
  • providing contractual and management services to you
  • maintaining comprehensive up to date records about your company to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in the event of an emergency are maintained
  • effectively monitoring both your conduct and your performance and to undertake procedures with regard to both of these if the need arises
  • offering a method of recourse for you against decisions made about you via a complaints procedure
  • reviewing compliance needs
  • business planning and restructuring exercises
  • dealing with legal claims made against us
  • preventing fraud
  • ensuring our administrative and IT systems are secure and robust against unauthorised access

There may be more than one reason to validate the reason for processing your personal information.

 

LAWFUL BASIS FOR PROCESSING “SPECIAL CATEGORIES” OF SENSITIVE DATA

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

 

  • consent: You have given clear consent for us to process your personal data for a specific purpose.
  • contract: The processing is necessary for a contract we have with you, or because we have asked you to take specific steps before entering into a contract.
  • legal obligation: The processing is necessary for us to comply with the law (not including contractual obligations) and meets the obligations under our data protection policy.
  • vital interests: the processing is necessary to protect someone’s life.
  • public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law and meets the obligations under our data protection policy.
  • legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests.
  • Occasionally, special categories of data may be processed where you are not capable of giving your consent, where you have already made the information public or in the course of legitimate business activities or legal obligations and in line with the appropriate safeguards.

 

Examples of the circumstances in which we will process special categories of your particularly sensitive personal information are listed below (this list is non-exhaustive): 

 

  • in order to protect health and safety in the workplace
  • to assess your contractors physical or emotional fitness to work
  • to determine if reasonable adjustments are needed or are in place
  • In order to fulfill monitoring or reporting obligations

 

Where appropriate, we may seek your written authorisation to process special categories of data. Upon such an occasion we will endeavor to provide full and clear reasons at that time in order for you to make an informed decision. In any situation where consent is sought, please be advised that you are under no contractual obligation to comply with a request. Should you decline to consent you will not suffer a detriment

 

INFORMATION ABOUT CRIMINAL CONVICTIONS  

 

Information regarding criminal convictions of employees or contractors may be processed in accordance with our legal obligations. Occasionally we may process such information to protect yours, or someone else’s interests and you are not able to give your consent or we may process such information in cases where you have already made the information public.

  

AUTOMATED DECISION-MAKING

We do not anticipate that any of our decisions will occur without human involvement. Should we use any form of automated decision making we will advise you of any change in writing.

 

SHARING DATA  

 

Your data will be shared with colleagues within the Company where it is necessary for them to undertake their duties. This includes, for example, Property Managers for their management of the development, the accounts department for maintaining records and the payroll department for administering payments under your contract.

 

It may be necessary for us to share your personal data with a third party or third party service provider (including, but not limited to, contractors, agents or other associated/group companies) within, or outside of, the European Union (EU). Data sharing may arise due to a legal obligation, as part of the performance of a contract or in situations where there is another legitimate interest (including a legitimate interest of a third party) to do so.

 

The list below identifies which activities are carried out by third parties on our behalf:

 

  • Payroll/ accounts
  • IT services
  • Legal advisors
  • Security
  • Insurance providers
  • Health & Safety checks
  • Fire Risk Assessments

 

Data may be shared with third parties in the following circumstances:

 

  • in the process of regular reporting activities regarding our performance,
  • with regards to a business or group reorganisation, sale or restructure,
  • in relation to the maintenance support and/or hosting of data
  • to adhere with a legal obligation
  • in the process of obtaining advice and help in order to adhere with legal obligations

 

If data is shared, we expect third parties to adhere and comply with the GDPR and protect any data of yours that they process. We do not permit any third parties to process personal data for their own reasons. Where they process your data it is for a specific purpose according to our instructions.

 

We do not anticipate that we will transfer data to other countries.

 

DATA SECURITY  

 

As part of our commitment to protecting the security of any data we process, we have put the following measures in place to secure firewalls for our IT systems and anti-virus protection under contract with a reputable IT company.

 

In addition, we have put further security measures and staff training in place to avoid data from being accessed, damaged, interfered with, lost, damaged, stolen or compromised. In cases of a breach, or suspected breach, of data security you will be informed, as will any appropriate regulator, in accordance with our legal obligations.

 

Any data that is shared with third parties is restricted to those who have a business need, in accordance with our guidance and in accordance with the duty of confidentiality.

 

DATA RETENTION  

 

We anticipate that we will retain your data as part of the tendering process for no longer than is necessary for the purpose for which it was collected.

We have given consideration to the following in order to decide the appropriate retention period:

  • quantity
  • nature
  • sensitivity
  • risk of harm
  • purpose for processing
  • legal obligations

 

At the end of the retention period, upon conclusion of any contract we may have with you, or until we are no longer legally required to retain it, it will be reviewed and deleted, unless there is some special reason for keeping it. Occasionally, we may continue to use data without further notice to you. This will only be the case where any such data is anonymised and you cannot be identified as being associated with that data

 

YOUR RIGHTS IN RELATION TO YOUR DATA  

 

We commit to ensure that any data we process is correct and up to date. It is your obligation to make us aware of any changes to your personal information.

 

In some situations, you may have the;

 

Right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice. 

Right to request access. You have the right to access the data that we hold on you. To do so, you should make a subject access request

Right to request correction. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it.

Right to request erasure. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.

Right to object to the inclusion of any information. In situations where we are relying on a legitimate interest (or those of a third party) you have the right to object to the way we use your data where we are using it.

Right to request the restriction of processing. You have the right to ask us to stop the processing of data of your personal information. We will stop processing the data (whilst still holding it) until we have ensured that the data is correct.

Right to portability. You may transfer the data that we hold on you for your own purposes.

Right to request the transfer. You have the right to request the transfer of your personal information to another party.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

 

If you wish to exercise any of the rights explained above, please contact Tanya Vyas by email: tvyas@hallmarkpml.com. 

 

Consequences of your failure to provide personal information

 

If you neglect to provide certain information when requested, it may affect our ability to enter into or continue with a contract with you, and it may prevent us from complying with our legal obligations.

 

Change of purpose for processing data

 

We commit to only process your personal information for the purposes for which it was collected, except where we reasonably consider that the reason for processing changes to another reason and that reason is consistent with the original basis for processing. Should we need to process personal information for any another reason, we will inform you of this and advise you of the lawful basis upon which we will process this information.

 

Important note: We may process your personal information without your knowledge or consent, in compliance with the above rules (see above section - lawful basis for processing your personal information).

In the event that you enter into a contract with us, any information already collected may be processed further in accordance with our data protection policy, a copy of which will be provided to you.

 

QUESTIONS OR COMPLAINTS

 

Should you have any questions regarding this statement, please contact Tanya Vyas on Tel: 01992 761419 / DDI: 01992 707 476, tvyas@hallmarkpml.com

 

The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.

Hallmark Property Management Limited

 

Data Protection Compliance Policy for Contractors

 

 

This document demonstrates our commitment to protecting the privacy and security of your personal information. It contains information regarding how we collect and use personal data or personal information about you in accordance with the General Data Protection Regulation (GDPR) and all other data protection legislation currently in force. 

 

Pursuant to that legislation, when processing data we will;

 

  • process it fairly, lawfully and in a clear, transparent way
  • collect your data only for reasons that we find proper for the course of your employment in ways that have been explained to you
  • only use it in the way that we have told you about
  • ensure it is correct and up to date
  • keep your data for only as long as we need it
  • process it in a way that ensures it will not be lost or destroyed or used for anything that you are not aware of or have not consented to (as appropriate) 

 

Hallmark Property Management Limited is a “data controller”. This means that we are responsible for determining the purpose and means of processing personal data relating to you.

 

“Personal data”, or “personal information”, means any information relating to an identified, or identifiable individual in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

There are “special categories” of sensitive personal data, meaning data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health conditions, sex life or sexual orientation, genetic data, and biometric data which require a higher level of protection.

 

This data protection compliance statement (privacy policy) applies to all Hallmark’s contractors.

   


DETAILS OF INFORMATION WE WILL HOLD ABOUT YOU   

 

The list below identifies the kind of data that we will hold about you:

 

  • personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
  • bank account details, payroll records and tax codes
  • location of employment or workplace
  • Information including job titles, job descriptions, training records, hours of work, professional membership and other terms and conditions relating to your contract with us
  • compensation history
  • Internal performance information including measurements against deadlines, costings, formal complaints and related documentation.
  • information and relevant communications regarding site issues
  • CCTV footage and other information obtained through electronic means such as building entry records
  • information about your use of our information and communications systems
  • The following list identifies the kind of data that that we will process and which falls within the scope of “special categories” of more sensitive personal information:
  • information about workers disabilities
  • information about workers criminal convictions and offences
  • genetic information and biometric data

 

 

METHOD OF COLLECTION OF PERSONAL INFORMATION

 

Your personal information is obtained through the application and tendering processes, this may be directly from contractors, or third party recommendations who undertake background checks. Further information will be collected directly from you when you are engaged at the start of the contract to Hallmark, for example, your bank details and health & safety records for our compliance. Other details may be collected directly from you in the form of official documentation, for example, right to work evidence. Data may be collected during the course of your engagement with us to enable its continued existence or development.

 

PROCESSING INFORMATION ABOUT YOU  

 

We will only administer personal information in accordance with the lawful bases for processing. At least one of the following will apply when we process personal data:

 

  • consent: You have given clear consent for us to process your personal data for a specific purpose.
  • contract: The processing is necessary for a contract we have with you, or because we have asked you to take specific steps before entering into a contract.
  • legal obligation: The processing is necessary for us to comply with the law (not including contractual obligations).
  • vital interests: the processing is necessary to protect someone’s life.
  • public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
  • legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests.

 

 

LAWFUL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

 

We consider that the basis for which we will process the data contained in the list above (see section above - details of information we will hold about you) is necessary for the performance of the contract we have with you and to enable us to comply with our legal obligations. Occasionally, we may process personal information about you to pursue legitimate interests of our own or those of third parties, provided there is no good reason to protect your interests and your fundamental rights do not override those interests.

 

The circumstances in which we will process your personal information are listed below. 

 

  • making decisions about who to offer initial contacts to, and subsequent internal appointments, etc.
  • responding to requests from third parties such as a reference request etc.
  • providing contractual benefits to you
  • maintaining comprehensive up to date records about you to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in the event of an emergency are maintained
  • effectively monitoring both your conduct and your performance and to undertake procedures with regard to both of these if the need arises
  • offering a method of recourse for you against decisions made about you via a complaints procedure
  • reviewing compliance needs
  • business planning and restructuring exercises
  • dealing with legal claims made against us
  • preventing fraud
  • ensuring our administrative and IT systems are secure and robust against unauthorised access

There may be more than one reason to validate the reason for processing your personal information.

 

LAWFUL BASIS FOR PROCESSING “SPECIAL CATEGORIES” OF SENSITIVE DATA

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

 

  • consent: You have given clear consent for us to process your personal data for a specific purpose.
  • contract: The processing is necessary for a contract we have with you, or because we have asked you to take specific steps before entering into a contract.
  • legal obligation: The processing is necessary for us to comply with the law (not including contractual obligations) and meets the obligations under our data protection policy.
  • vital interests: the processing is necessary to protect someone’s life.
  • public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law and meets the obligations under our data protection policy. (For example in the case of equal opportunities monitoring)
  • legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests. (For example to assess your capacity to work on the grounds of ill health)

Occasionally, special categories of data may be processed where you are not capable of giving your consent, where you have already made the information public or in the course of legitimate business activities or legal obligations and in line with the appropriate safeguards.

 

Examples of the circumstances in which we will process special categories of your particularly sensitive personal information are listed below (this list is non-exhaustive): 

 

  • in order to protect your health and safety in the workplace
  • to assess your contactors physical or emotional fitness to work
  • to determine if reasonable adjustments are needed or are in place
  • In order to fulfill equal opportunity monitoring or reporting obligations

 

Where appropriate, we may seek your written authorisation to process special categories of data. Upon such an occasion we will endeavor to provide full and clear reasons at that time in order for you to make an informed decision. In any situation where consent is sought, please be advised that you are under no contractual obligation to comply with a request. Should you decline to consent you will not suffer a detriment

 

INFORMATION ABOUT CRIMINAL CONVICTIONS  

 

Information regarding criminal convictions may be processed in accordance with our legal obligations. Occasionally we may process such information to protect yours, or someone else’s interests and you are not able to give your consent or we may process such information in cases where you have already made the information public. Such information may be sought as part of the recruitment process or in the course of your employment with us.

 

We anticipate that we will process information about criminal convictions.

  

AUTOMATED DECISION-MAKING

We do not anticipate that any of our decisions will occur without human involvement. Should we use any form of automated decision making we will advise you of any change in writing.

 

SHARING DATA  

 

Your data will be shared with colleagues within the Company where it is necessary for them to undertake their duties. This includes, for example, Property Managers for their management of you, the accounts department for maintaining records and the payroll department for administering payment under your contract of employment.

 

It may be necessary for us to share your personal data with a third party or third party service provider (including, but not limited to, contractors, agents or other associated/group companies) within, or outside of, the European Union (EU). Data sharing may arise due to a legal obligation, as part of the performance of a contract or in situations where there is another legitimate interest (including a legitimate interest of a third party) to do so.

 

The list below identifies which activities are carried out by third parties on our behalf:

  • Payroll/ accounts
  • IT services
  • legal advisors
  • security
  • insurance providers

 

Data may be shared with 3rd parties in the following circumstances:

 

  • in the process of regular reporting activities regarding our performance,
  • with regards to a business or group reorganisation, sale or restructure,
  • in relation to the maintenance support and/or hosting of data
  • to adhere with a legal obligation
  • in the process of obtaining advice and help in order to adhere with legal obligations

 

If data is shared, we expect third parties to adhere and comply with the GDPR and protect any data of yours that they process. We do not permit any third parties to process personal data for their own reasons. Where they process your data it is for a specific purpose according to our instructions.

 

We do not anticipate that we will transfer data to other countries.

 

DATA SECURITY  

 

As part of our commitment to protecting the security of any data we process, we have put the following measures in place secure firewalls for our IT systems and anti-virus protection under contract with a reputable IT company.

 

In addition, we have put further security measures in place to avoid data from being accessed, damaged, interfered with, lost, damaged, stolen or compromised. In cases of a breach, or suspected breach, of data security you will be informed, as will any appropriate regulator, in accordance with our legal obligations.

 

Any data that is shared with third parties is restricted to those who have a business need, in accordance with our guidance and in accordance with the duty of confidentiality.

 

DATA RETENTION  

 

We anticipate that we will retain your data as part of the tendering process for no longer than is necessary for the purpose for which it was collected.

We have given consideration to the following in order to decide the appropriate retention period:

  • quantity
  • nature
  • sensitivity
  • risk of harm
  • purpose for processing
  • legal obligations

 

At the end of the retention period, upon conclusion of any contract we may have with you, or until we are no longer legally required to retain it, it will be reviewed and deleted, unless there is some special reason for keeping it. Occasionally, we may continue to use data without further notice to you. This will only be the case where any such data is anonymised and you cannot be identified as being associated with that data

 

YOUR RIGHTS IN RELATION TO YOUR DATA  

 

We commit to ensure that any data we process is correct and up to date. It is your obligation to make us aware of any changes to your personal information.

 

In some situations, you may have the;

 

Right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice. 

Right to request access. You have the right to access the data that we hold on you. To do so, you should make a subject access request

Right to request correction. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it.

Right to request erasure. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.

Right to object to the inclusion of any information. In situations where we are relying on a legitimate interest (or those of a third party) you have the right to object to the way we use your data where we are using it.

Right to request the restriction of processing. You have the right to ask us to stop the processing of data of your personal information. We will stop processing the data (whilst still holding it) until we have ensured that the data is correct.

Right to portability. You may transfer the data that we hold on you for your own purposes.

Right to request the transfer. You have the right to request the transfer of your personal information to another party.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

 

If you wish to exercise any of the rights explained above, please contact Tanya Vyas. 

 

Consequences of your failure to provide personal information

 

If you neglect to provide certain information when requested, it may affect our ability to enter into or continue with a contract with you, and it may prevent us from complying with our legal obligations.

 

Change of purpose for processing data

 

We commit to only process your personal information for the purposes for which it was collected, except where we reasonably consider that the reason for processing changes to another reason and that reason is consistent with the original basis for processing. Should we need to process personal information for another reason, we will inform you of this and advise you of the lawful basis upon which we will process.

 

Important note: We may process your personal information without your knowledge or consent, in compliance with the above rules (see above section - lawful basis for processing your personal information).

In the event that you enter into a contract with us, any information already collected may be processed further in accordance with our data protection policy, a copy of which will be provided to you.

 

QUESTIONS OR COMPLAINTS

 

Should you have any questions regarding this statement, please contact Tanya Vyas on Tel: 01992 761419 / DDI: 01992 707 476, tvyas@hallmarkpml.com

 

The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.

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