In operating our business we have access to personal and commercial information and property. When processing this information and managing access to property we have to consider our legal obligations and our duty to our customers, employees, suppliers and other data subjects.
Types of information we collect
- Personal information
- Financial history and records
- Credit information
- Criminal record information
- CCTV images and videos
- Telephone recordings
Types of property we have access to
- Properties we own
- Properties we manage
- Possessions left in our custody
- Possessions left in a property we own or manage
How we will use the information we collect
- The administration of our business
- Servicing our relationship with you, whether as a customer, employee, supplier or member of the public.
- Training our staff and monitoring their performance
- Monitoring the quality of our products and services
- Monitoring compliance with contracts (including commercial contracts, leases, licences and tenancy agreements).
- Crime prevention and detection
How we will handle the information we collect and access to properties
- We will ensure your information is held securely.
- We will ensure that staff only have access to the level of information required for them to carry out their duties.
- We will ensure that keys and access devices are held securely.
- We will ensure that staff usage of keys and access devices is logged.
- We will only access your property with your consent, unless:
- we have reasonable grounds to act urgently (for example, to investigate or carry out an urgent repair, or if we believe that the occupant may be incapacitated)
- we are investigating a serious breach of your lease, licence or tenancy agreement
- we are allowed access to the property by virtue of legislation or your lease, licence or tenancy agreement
- If we do access your property without your consent or prior notification we will notify you as soon as reasonably possible, unless we are legally prevented from doing so, and make a record of:
- the date and time of access
- who accessed the property
- the reason for access
How we will share the information we collect and access to properties
- With our sub-contractors or agents to allow us to carry out a service for you or deliver a product to you. We will only share the level of information and/or access needed to facilitate this. We will ask them to apply the same level of protection in handling this information / access.
- With credit agencies where we assess your application for a product or service, or to share information about your payment history with other businesses and landlords.
- With our accountants, solicitors and advisers as necessary to carry out our business. We will only share the level of information and/or access needed to facilitate this. We will ask them to apply the same level of protection in handling this information / access.
- With our bankers, finance providers and investors to enable them to understand our business and for the packaging of debt assignment or securitisation. We will only share the level of information and/or access needed to facilitate this. We will ask them to apply the same level of protection in handling this information / access.
- With the police or similar authority in any relevant jurisdiction to prevent or detect crime against ASN Capital, its employees or related parties.
- With the police or similar authority in any relevant jurisdiction to prevent or detect any other crimes where Section 29 of the Data Protection Act 1998 is satisfied.
- With any other person or organisation that is legally empowered to make a request for disclosure or access having taken reasonable steps to ascertain:
- what information/access is being sought
- the exact purpose(s) for which that information/access is being sought
- under what statute, if any, the organisation seeking the information/access is making the request
- the validity of the legal authority claimed