Code  
Version 1.0
Created by Dr Philip Donnellan
Approved by  
Date of version 30/01/2019
Signature  

 

 

Change History

Date Version Created by Description of change
       
       
       
       
       
       

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Contents

1        Scope and Purpose.. 1

2        Who Are We?. 1

3        What data do we collect, why do we collect it, and how long do we keep it?  2

3.1       Inquiries. 2

3.1.1       What data do we collect?. 2

3.1.2       Why do we collect this information?. 2

3.1.3       How long do we keep this information?. 2

3.1.4       Do any third parties process your data?. 2

3.2       Residential landlords. 3

3.2.1       What data do we collect?. 3

3.2.2       Why do we collect this information?. 3

3.2.3       How long do we keep this information?. 3

3.2.4       Do any third parties process your data?. 3

3.3       Residential tenants. 4

3.3.1       What data do we collect?. 4

3.3.2       Why do we collect this information?. 4

3.3.3       How long do we keep this information?. 4

3.3.4       Do any third parties process your data?. 5

3.4       Residential property sales. 6

3.4.1       What data do we collect?. 6

3.4.2       Why do we collect this information?. 6

3.4.3       How long do we keep this information?. 6

3.4.4       Do any third parties process your data?. 6

3.5       Residential property purchases. 7

3.5.1       What data do we collect?. 7

3.5.2       Why do we collect this information?. 7

3.5.3       How long do we keep this information?. 7

3.5.4       Do any third parties process your data?. 8

3.6       Commercial landlords. 9

3.6.1       What data do we collect?. 9

3.6.2       Why do we collect this information?. 9

3.6.3       How long do we keep this information?. 9

3.6.4       Do any third parties process your data?. 10

3.7       Commercial tenants. 11

3.7.1       What data do we collect?. 11

3.7.2       Why do we collect this information?. 11

3.7.3       How long do we keep this information?. 11

3.7.4       Do any third parties process your data?. 12

3.8       Vendors and Suppliers. 13

3.8.1       What data do we collect?. 13

3.8.2       Why do we collect this information?. 13

3.8.3       How long do we keep this information?. 13

3.8.4       Do any third parties process your data?. 13

4        Third Party Data Processing.. 14

5        Security of Your Information.. 15

5.1       Training.. 15

5.2       Physical Security. 15

5.3       Encryption.. 15

6        Your Rights. 16

6.1       The Right of Access. 16

6.2       Right to Portability. 16

6.3       Right of Rectification.. 16

6.4       Right to Erasure.. 16

6.5       Right to Restrict Processing.. 16

6.6       Right to Object 16

7        Complaints. 17

8        Changes to our privacy policy. 17

 

 

 

 

 

1       Scope and Purpose

This document outlines to all data subjects, who interact with Smart Property, under what conditions their data will be processed, how Smart Property strives to ensure that the individual’s privacy is respected at all times, who conducts the processing, what security features are in place, and what rights the data subject retains at all times. Above all, this document aims to ensure that transparency exists with respect to how Smart Property processes data.

If you have any questions in relation to this document or if you wish to exercise any of your rights concerning your personal data, please email us at info@smartproperty.ie.

 

2       Who Are We?

Smart Property Ltd is an organisation specialising in rental, sales and management of property throughout Dublin and surrounding areas.

With a large number of properties under our management, we offer tailor made letting and management packages for residential and commercial properties.

 

 

 

3       What data do we collect, why do we collect it, and how long do we keep it?

3.1    Inquiries

We advertise all of our properties through our website www.smartproperty.ie as well as through platforms www.daft.ie and/or www.myhome.ie. Should you be interested in one of our properties, all of these websites/platforms have the functionality to message our team.

Inquiry information may also be collected from you as part of direct e-mail or verbal communications with any of our team or through sign-in sheets at property viewing events.

3.1.1    What data do we collect?

As part of this contact, we will require from you your:

  • Name
  • Telephone number
  • Email address

3.1.2    Why do we collect this information?

This information is collected to allow us to revert to you with the appropriate response to your inquiry and to ensure that your query is satisfactorily dealt with.

3.1.3    How long do we keep this information?

If you do not enter in a letting, sales or vendor engagement process (including the initial stages of such a process), your information will be deleted from our e-mail servers within one month of receipt.

3.1.4    Do any third parties process your data?

Your information may be processed by the generic list of third-party processors engaged by Smart Property as outlined in section 4, in conjunction with the following list of third parties:

Third Party Data Processed Why it’s processed Role
www.daft.ie Name

Telephone number

Email address

Platform facilitating the inquiry  communication Data Processor
www.myhome.ie Name

Telephone number

Email address

Platform facilitating the inquiry  communication Data Processor

3.2    Residential landlords

If you have a property which you would like us to manage or sell, we will collect certain information from you.

3.2.1    What data do we collect?

Upon your first engagement with us, we will ask you to complete a residential landlord details form which will include your:

  • Name
  • Address
  • Email
  • Phone number,
  • PPS number
  • Bank details
  • Anti money-laundering documentation such as photo identification and a recent utility bill

3.2.2    Why do we collect this information?

This information is required in order to:

  • Enable us to effectively communicate with you during the leasing process
  • Enable payments to be made to you upon successful leasing of the property
  • Comply with our anti money-laundering obligations

3.2.3    How long do we keep this information?

We will keep all of the information which you have provided to us as part of the letting process while the lease is active and for seven years following the cessation of the lease agreement in order to ensure that we satisfy our obligations to the PSRA and the Revenue Commissioner’s Office.

3.2.4    Do any third parties process your data?

Your information may be processed by the generic list of third-party processors engaged by Smart Property as outlined in section 4, in conjunction with the following list of third parties:

Third Party Data Processed Why it’s processed Role
RTB PPS number

Phone number

Registration of the tenancy with the RTB Data Controller

 

3.3    Residential tenants

When you wish to apply to rent a property which we manage, we will be required to collect further information from you.

3.3.1    What data do we collect?

We will ask you for data such as your:

  • Full name
  • PPS number
  • Telephone number
  • Nationality
  • Current address
  • Current landlord name
  • Employment details
  • Rent allowance and HAP scheme details
  • References from your employer and from previous rented properties
  • Photo identification
  • Evidence to support income levels
  • Bank details

As part of the payments process, we may also ask you for evidence of payments made to us or the landlord.

3.3.2    Why do we collect this information?

As part of the application process, this information is obtained in order to:

  • Select the most suitable candidate(s) for the property in question
  • Ensure your ability to support the ongoing payment of rent for the property

If you are selected as the successful candidate, the information will be required in order to:

  • Register the lease agreement with the RTB (Residential Tenancy Board)
  • Provide your information to the property owner
  • Fulfil our obligations to the Revenue Commissioner

3.3.3    How long do we keep this information?

If you are not successful in your application your information will be deleted from our systems within seven working days from the day on which the deposit is taken for the property lease in question.

If you are successful in your application and you become a tenant in one of our managed properties, we will retain all information which you provide us (or relating to you) while you are a tenant in the property for a period of seven years following the cessation of the tenancy in order to ensure that we satisfy our obligations to the PSRA and the Revenue Commissioner’s Office.

3.3.4    Do any third parties process your data?

Your information may be processed by the generic list of third-party processors engaged by Smart Property as outlined in section 4, in conjunction with the following list of third parties:

Third Party Data Processed Why it’s processed Role
RTB PPS number

Phone number

Registration of the tenancy with the RTB Data Controller
Landlord Name

Phone number

Rent charge details

Contractual requirements with the landlord Data Controller
External maintenance team Name

Address

Phone number

 

Provision of necessary maintenance services to the building in question Data Processor
www.remindme.ie Name

Address

Phone number

Communication platform facilitating property management Data Processor
Property button Name

Address

E-mail

Phone number PPS number

Provision of utility selection services Data Controller

 

 

 

 

3.4    Residential property sales

If you have a property which you are looking to sell, we will require a certain amount of personal data in order to facilitate this process.

3.4.1    What data do we collect?

As part of the sales process, we will ask you to complete a vendor details form which will contain your:

  • Name
  • Address
  • Email
  • Phone number,
  • PPS number
  • Bank details
  • Anti money-laundering documentation such as photo identification and a recent utility bill

3.4.2    Why do we collect this information?

We collect this information in order to enable us to process the sale of the property in question and to communicate with you throughout the sales process.

3.4.3    How long do we keep this information?

If the sale is successfully completed, we will keep all of the information which you have provided to us as part of the sales process for seven years following the completion of the sale in question in order to ensure that we satisfy our obligations to the Revenue Commissioner’s Office.

If no sale is made, your details will be deleted within 30 days of the official cessation of our sales engagement.

3.4.4    Do any third parties process your data?

Your information may be processed by the generic list of third-party processors engaged by Smart Property as outlined in section 4.

 

 

3.5    Residential property purchases

Upon selection of a property for which you would like to make an offer, we will ask you to provide us with a bid for the property in question via e-mail. Any such received bid will be passed to the property owner for evaluation. You may receive communications (via phone or e-mail) in relation to the offer which you have made.

3.5.1    What data do we collect?

As part of a sales inquiry, we may collect various data from you such as your:

  • Name
  • E-mail address
  • Telephone Number
  • Budgetary information

If you are successful in your application, we will ask you to provide evidence of payments made to us as part of the sales completion process.

3.5.2    Why do we collect this information?

We collect this information in order to enable us to identify a suitable property for you and to adequately provide our services to you as part of the sales process.

3.5.3    How long do we keep this information?

If you are not successful in your application your information will be deleted from our systems within seven working days from the day on which the sale is completed for the property in question.

If you are successful in your application, we will keep all of the information which you have provided to us for seven years following the day on which the sale is completed in order to ensure that we satisfy our obligations to the Revenue Commissioner’s Office.

 

 

3.5.4    Do any third parties process your data?

Your information may be processed by the generic list of third-party processors engaged by Smart Property as outlined in section 4, in conjunction with the following list of third parties:

Third Party Data Processed Why it’s processed Role
Property Owner All information received during the sales process Facilitation of the sales process Data Controller
Property Owner’s Solicitor All information received during the sales process Facilitation of the sales process Data Controller

 

 

3.6    Commercial landlords

If you have a commercial unit or property which you would like us to manage, we will collect certain information from you.

3.6.1    What data do we collect?

Upon your first engagement with us, we will ask you to complete a commercial landlord details form which will include your:

  • Name
  • Address
  • Email
  • Phone number,
  • PPS number
  • Bank details
  • Anti money-laundering documentation such as photo identification and a recent utility bill

3.6.2    Why do we collect this information?

This information is required in order to:

  • Enable us to effectively communicate with you during the leasing process
  • Enable payments to be made to you upon successful leasing of the property
  • Comply with our anti money-laundering obligations
  • Enable adequate management of your process and provision of necessary services

3.6.3    How long do we keep this information?

We will keep all of the information which you have provided to us as part of the letting process while the lease is active and for seven years following the cessation of the lease agreement in order to ensure that we satisfy our obligations to the PSRA and the Revenue Commissioner’s Office.

 

 

3.6.4    Do any third parties process your data?

Your information may be processed by the generic list of third-party processors engaged by Smart Property as outlined in section 4, in conjunction with the following list of third parties:

Third Party Data Processed Why it’s processed Role
Smart Property Accountant Names provided to us

Address

Phone number

Lease details

Financial support services to Smart Property Data Controller
Smart Property Solicitor All details provided by you Legal support services to Smart Property Data Controller
External maintenance team Names provided to us

Address

Phone number

Email

 

Provision of necessary maintenance services to the building in question Data Processor
Purple Property Names provided to us

Address

Phone number

Email

 

Provision of necessary maintenance services to the building in question Data Processor

 

 

 

3.7    Commercial tenants

If you are seeking to enter in to a commercial lease in a unit which we manage, then we will collect data which may be considered (under certain circumstances) to be personal data from you as part of this process.

3.7.1    What data do we collect?

As part of a commercial letting engagement we require certain information relating to company and its directors (or other appointed members of the organisation):

  • Names
  • Phone numbers
  • E-mail address
  • Job details within the company

This information may be collected directly from you by us or else may be inherited from your previous landlord if you already have an existing lease in the building. If inherited from your previous landlord, we will also receive your lease agreement, which will contain all associated details such as your rental amount.

As part of the tenant selection process, various additional information may be requested from you to enable us to gain a better insight in to your commercial activities such as:

  • Business plans
  • Financial verification documents
  • Audited accounts

3.7.2    Why do we collect this information?

This information is requested from you in order to allow us to:

  • Gain a better insight in to the business activities which would be conducted in the property
  • Select the most suitable candidate(s) for the property in question
  • Ensure your ability to support the ongoing payment of rent for the property

3.7.3    How long do we keep this information?

If you are not successful in your application your information will be deleted from our systems within seven days from the day on which the lease documents are signed for the unit in question.

If you are successful in your application and you become a tenant in one of our managed properties, we will retain all information which you provide us (or relating to you) while you are a tenant in the property and for a period of seven years following the cessation of the tenancy in order to ensure that we satisfy our obligations to the PSRA and the Revenue Commissioner’s Office.

3.7.4    Do any third parties process your data?

Your information may be processed by the generic list of third-party processors engaged by Smart Property as outlined in section 4, in conjunction with the following list of third parties:

Third Party Data Processed Why it’s processed Role
Property Owner Names

Address details

Contact Information

Your solicitor’s details

Agreed lease terms

Facilitation of the leasing process Data Controller
Property Owner’s Solicitor Names

Address details

Contact Information

Your solicitor’s details

Agreed lease terms

Facilitation of the leasing process Data Controller
External maintenance team Names provided to us

Address

Phone number

Email

 

Provision of necessary maintenance services to the building in question Data Processor
Purple Property Names provided to us

Address

Phone number

Email

 

Provision of necessary maintenance services to the building in question Data Processor
Smart Property Accountant Names provided to us

Address

Phone number

Lease details

Financial support services to Smart Property Data Controller

 

 

 

3.8    Vendors and Suppliers

If you engage with us either a vendor or as a supplier, we will require certain information to facilitate this interaction.

3.8.1    What data do we collect?

We will ask you for your:

  • Name
  • Address
  • Email
  • Phone number

3.8.2    Why do we collect this information?

This information is required in order to enable us to effectively communicate with you during our subsequent engagements

3.8.3    How long do we keep this information?

We will keep all of the information which you have provided to us while you have an active engagement agreement with us, and for seven years following the cessation of this engagement agreement in order to ensure that we satisfy our obligations to the Revenue Commissioner’s Office.

3.8.4    Do any third parties process your data?

Your information may be processed by the generic list of third-party processors engaged by Smart Property as outlined in section 4, in conjunction with the following list of third parties:

Third Party Data Processed Why it’s processed Role
Smart Property Accountant All data provided to us Financial support services to Smart Property Data Controller

 

 

 

4       Third Party Data Processing

As outlined in section 3, it is sometimes required that third parties process your data. Any data which you provide to us will be processed under conditions of absolute confidentiality and we will ensure that we do not share this information with anyone other than a select group of trusted partners. All of our partners have provided guarantees of GDPR compliance, such that we have confidence that your information will be processed with the highest standards of data privacy.

Under no conditions do we transfer any of the data which you provide us outside of the European Economic Area (EEA).

In section 3, specific instances of such data processing are provided relevant to the type data which has been collected. Several generic data processing third parties are also used as part of the daily operation of Smart Property which are outlined in this section. It should be noted that these third parties may process data provided to us in conjunction to those listed in section 3.

Third Party Why it processes data Role
Salesforce Internal property management operational requirements within Smart Property Data Processor
Microsoft Cloud-based documentation, storage, analysis and communication tools used within Smart Property Data Processor
Origins Internal financial operational requirements within Smart Property Data Processor

 

Several third-party processors listed in this document are designated as acting as data controllers. This means that these third parties will make decisions relating to how your data is processed and are required to ensure that they treat your data in accordance with relevant data protection regulation. This involves adequate communication with you to ensure that you have full transparency relating to what processing they will conduct with your information. If you do not feel that your data protection rights are not being observed, you should contact these directly or the data protection commissioner.

 

 

5       Retention Periods

The specific retention periods which will be applied to your information are outlined in section 3.

Information relating to you may also be contained in routine communications with us, such as via e-mail transactions. We apply a general retention period of seven years to any such communications. Therefore although stricter retention periods may be applied to all formal records of your data as outlined in section 3, copies of this information may be retained for longer if contained in written communications with us.

 

6       Security of Your Information

We take our information security responsibilities very seriously and employ the most appropriate physical and technical measures, including staff training and awareness, to ensure that your information is safe. These measures are regularly reviewed.

6.1    Training

All members of the Smart Property team have received training relating to data security and the processing of personal information. Individuals have been additionally provided with training relating to the processing of data specific to their roles within Smart Property.

6.2    Physical Security

All of the data provided to Smart Property in either physical (paper) form or by digital means is stored securely on premise in the Smart Property offices or else using trusted third party processors as listed in sections 3 and 4.

6.3    Encryption

All data processed by Smart Property by digital means is, where possible, encrypted in transit and also at rest. Encryption in transit is achieved by the use of SSL certificates, while encryption at rest is achieved on multiple levels, using both server level and application level encryption.

 

 

 

7       Your Rights

You have a number of rights in relation to your personal data. We have summarised those rights for you below

7.1    The Right of Access

You have the right to be informed about which of your data we are currently processing, why we are processing it, and how this processing is taking place. As part of any such request, you may ask us to provide you with a copy of this data.

7.2    Right to Portability

You may wish for your data to be transferred to another data controller of your choice, in which case we will either pass this information to you, or to the controller of your choice.

7.3    Right of Rectification

If you feel that data which we are processing pertaining to you is inaccurate, then please let us know, and we will fulfil your right to have it amended and rectified.

7.4    Right to Erasure

Under many conditions, you will have the right to be completely “forgotten” by Smart Property. If you make such a request, we will strive to delete or anonymise all of your personal data.

7.5    Right to Restrict Processing

You have the right to ask us to restrict processing of your personal data for a particular reason. This means that while this request exists, we will still store your data, but won’t use it.

7.6    Right to Object

If you feel that we are processing your data in a way which is unlawful, excessive, or if you would simply like us to stop, you have the right to object to this processing.

 

 

 

8       Complaints

If you have any complaints about any data processing activities which are being conducted relating to you or any information which you have supplied to us, please contact us and let us know (info@smartproperty.ie). We will do everything in our power to resolve the situation. You always reserve the right of course to make an official complaint to the Data Protection Commissioner’s Office.

 

9       Changes to our privacy policy

We keep our privacy statement under regular review and we will place any updates on this web page. The privacy statement was last updated on 30th of January 2019.