Effective 24th May 2018
View the prior version of our privacy notice (last updated 28th March 2014) here.
Important Information about Downing
Downing may also include the following entities: Downing Property Services Ltd, George Downing Construction Ltd, Downing Property Management Ltd, Downing Students and Downing Construction Ltd.
The entity responsible for your personal information will be the member of Downing that originally collects information from or about you. Downing and its affiliates (collectively referred to as ‘Downing’, ‘we’, ‘us’) takes its data protection and privacy responsibility seriously. This privacy notice explains how we collect, use and share personal information in the course of our business activities. You can find out more about Downing at www.Downing.com or by contacting us using the information in the ‘Contact us’ section.
This privacy notice applies to personal data collected by Downing. It does not apply to personal data collected by third parties or other organisations.
- What personal information we collect and when and why we use it
- How we share personal information within Downing and with our service providers, regulators and other third parties
- Explaining more about Direct Marketing, profiling and automated decision making
- Transferring personal information globally
- How we protect and store personal information
- Legal rights available to help manage your privacy
- How you can contact us for more support
We may amend this notice from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this notice.
You might find external links to third party websites on our website. This privacy notice does not apply to your use of a third-party site.
1. Who we are:
Downing is a leading property company working in construction, development, property management and in the provision of commercial, residential and high-quality purpose-built student accommodation across the UK. You may find out more about Downing and Downing Students at www.downing.com or by contacting us through the web page link ‘Contact us’.
From time to time Downing will use information provided by you in order to carry out our business, and to contact you when necessary to respond to your enquiry and throughout the duration of your contract and manage your account if applicable. We will manage the performance of any agreed third-party partners as required by law for the provision of services to you and in communication with relevant colleges and universities of our student tenants and to enable us to conduct our business in the context of your enquiry.
2. What personal information we collect and when and why we use it
We may collect information about you, directly from or through a third party, if you:
- Register or use one of our website or online services
- Rent one of our properties
- Work in partnership with us
- Enter into a contract with us
- Purchase one of our services
Personal information we collect and which you provide may be used in the following ways:
- For sharing information with Downing employees and third parties in relation to business needs
- To create and manage an account, to include the processing of bank/ card details for the raising and settlement of invoices if applicable.
- To enable and facilitate the creation and management of a tenancy agreement, lease, licence or contract if applicable.
- For recruitment purposes if appropriate
- To provide details to landlords, agents or sub-contractors to enable the provision of services.
- To facilitate third party contracts for the provision of services to you (E.g. security provision /Wi-Fi / insurance) as agreed.
- To facilitate the collection of bad debt.
- For audit and statistical analysis.
- For fraud prevention.
- To opt-in to our mailing list for marketing purposes.
- For identification purposed to support the security infrastructure throughout the business/ buildings e.g. a photograph on an entry system or a biometric access and management system
3. The Legal basis for using your personal information
We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:
- You have provided your consent to us using the personal information (for example, the performance of a contract or the creation of a tenancy agreement)
- Our use of your personal information is in our legitimate interest as a commercial organisation and in these cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in the section below
- Our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you. (For example: to create a tenancy agreement etc.)
- Our use of your personal data is necessary to comply with relevant legal or regulatory obligation that we have (For example: confirmation of student status)
If you would like to find out more about the legal basis for which we process personal information please contact us by email to email@example.com
4. Sharing personal information within Downing Students, with our service providers and regulators
We will share your information in the manner and for the purposes described below:
- Within Downing group where such disclosure is necessary to provide you with our services or to manage our business.
- With third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use of any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These include IT service providers who help manage our IT and back office systems.
- With credit reference agencies and organisations working to prevent fraud in financial services
- With our regulators
- We may share aggregate, statistical form, non-personal information, regarding the visitors to our website, traffic patterns and web page usage with our partners, affiliates and advertisers
- Where required to do so by law
- To local councils, statutory bodies, education establishments such as colleges and universities were applicable.
- For provision of insurance.
- To debt collection agents, solicitors or a Guarantor for the collection of outstanding debts.
- With the persons nominated by you as your emergency contact were, Downing believe you are at risk
- If in the future we were to sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third party purchaser or our business or assets.
We will not sell or pass data to any third party outside the remit of our business with you as described above.
5. Explaining more about direct marketing.
How we use personal information to keep you up to date with our products and services
We may use personal information to let you know about Downing products and services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.
How you can manage your marketing preferences
To protect privacy rights and to ensure you have control over how we manage our marketing with you:
- We will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you.
- You can request us to stop marketing at any time by following the ‘unsubscribe’ link you will find in our email marketing messages we send you. Alternatively, you can contact us at firstname.lastname@example.org and inform us if you wish us to stop all forms of marketing or a particular type.
- You can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser.
6. Transferring personal information globally
Downing operates on a global basis. Accordingly, your personal information may be transferred and stored in countries outside the EU that are subject to different standards of data protection. Downing will take appropriate steps to ensure that any transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognised as providing adequate legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights.
You have the right to contact us for more information about the safeguards we have in place to ensure adequate protection of your personal information when this is transferred as mentioned above.
7. How we protect and store your information
We have implemented and maintained appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature or the information concerned. Measures we take include placing confidentiality requirements on our staff members and Service Providers, destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected. As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect User ID`s and passwords, please take appropriate measures to protect this information.
Storing personal information
We will store your personal information for as long as is reasonable necessary for the purpose for which it was collected, as explained in this notice. In some circumstances, we may store your personal information
for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements.
In specific circumstances, we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonable believe there is a prospect of litigation relating to your personal information.
8. Legal Rights available to help manage your privacy
Subject to certain exemptions, and in some cases dependent upon the processing activities we are undertaking, you have certain rights in relation to your personal information.
Your personal information:
As an individual, you have the following rights which relates to all data we collect and store for customers and contractors.
- The right to be informed
- The right of access to your personal information
- The right to rectification and update your personal information
- The right to erasure: You can request to delete personal information we hold.
- The right to restrict processing
- The right to data portability
- The right to object
- The right to automated decision making and profiling
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you.
You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not be able to fully address your request, for example, if it were to impact on the duty of confidentiality we owe to others, or if we are legally entitle to deal with the request in a different way.
All request regarding the above can be made to email@example.com
If you have any queries or complaints about how we use your personal information please contact us. The primary point of contact for all issues arising from this privacy notice, is our Directors,
5 Myrtle Street
To Contact your data protection supervisory authority:
You have a right to lodge a complaint with your local data protection supervisory authority at any time. We ask that you please attempt to resolve any issues with us before contacting the local supervisory authority by calling or through the website:
T: 0303 123 1113