Privacy policy

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GDPR Privacy Notice ASCEND ESTATES LTD
Company number 08892998 Trading as Ascend.

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Who are we

Ascend is an independent residential sales, lettings and property management agency operating nationally. The Head office is located at Stafford Court, 145 Washway Road, Sale, M33 7PE.

Our intentions

This privacy notice sets out how Ascend processes your data, for what purpose and with who your data may be shared. Ascend intends to only ever process personal data lawfully, fairly and in a transparent manner. Keeping your data safe is important to us and we want to offer you complete transparency on how we will use your data.

Ascend will not pass details on to any company wishing to make, unsolicited calls or communication. Any personal data will only be used with legitimate interest, to protect life, to comply with the law, to process a contract or where expressed consent has been given for marketing purposes.

Data collection

Ascend will collect your data using various collation methods to include website enquiries, property portal enquiries, e-mail enquiries, telephone enquiries, in branch enquiries, Intouch software, online electronic forms and social media enquiries.

Our Website

The Ascend website openly uses cookies which collates information such as your IP address, browser type, operating system, referring URLs and information on actions taken or interaction with our digital assets.

Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic to tailor the website to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

Monitoring and Training

All calls are recorded for Ascend’s internal monitoring and training purposes. The Quality Assurance Department are responsible for carrying out weekly audits to ensure Applicants’ data is being protected, in addition to reviewing the Company’s adherence to the main principles of GDPR across the Branches. Any breaches are raised with the Branch Managers to feedback and follow-up coaching provided

Time

Ascend will only ever keep your personal data for as long as is necessary in line with our data retention policy. Ascend reserves the right to retain your information when any lawful basis, particularly legitimate interests prevail.

Other companies

We may receive personal information from landlords, clients, suppliers, contractors, reference agencies and other business partners where this is necessary to provide our services. Any information received will be processed in accordance with applicable data protection legislation and this Privacy Notice.

Ascend works with various external companies, service providers, and sub-agents, to fulfil the expected day to day operations in terms of initial enquiries, residential sales, and our lettings and property management business, including processing rental and maintenance recharge payments via our payment processing provider, Opayo (a trading name of Elavon Financial Services DAC).

When employing a third-party company to conduct business on our behalf, or when Ascend is employed by a third-party company and/or landlord or vendor to conduct sales, lettings or property management services, we will only share relevant personal information that they would need to perform the services we request or the services they’ve requested from us. 

Where we use third-party service providers to process personal data on our behalf, we have appropriate contractual arrangements in place requiring them to protect personal information, only process it in accordance with our instructions, and comply with applicable data protection legislation

In both instances, they are bound by regulation to protect this information appropriately and not to use it for any other purpose.

Lawful Basis for data processing

Reasons for data collection	Reasons for data collection	Lawful basis
General Enquiries	When enquiring about a property you will be asked for your Name, contact telephone number, e-mail address and registered address.	Legitimate interests
Intouch	When entering your data via our live touch screen software systems to initiate contact and to request further information.	Legitimate interests
Market research and surveys	From time to time Ascend will contact you to ensure that you have received our committed level of customer service and to ensure vital information has been passed on to you.	Quality Assurance
Referencing	Your details will be passed to a third party referencing agency for the purposes of undertaking credit, previous landlord and employment checks.	Contract or Legitimate interest
Right to rent check	You will be required to provide official documentation to prove your right to rent in the UK.	Legal obligation
Debt collection	Should a Tenant fall in to rent arrears or for any late fee payments, personal details will be passed on to third party legal representatives and or debt collection agencies.	Contract
Serving notices	Where necessary your details will be passed on to legal representatives.	Legal obligation
Councils	Your personal and occupancy details will be passed on to the local council for the purposes of council tax.	Legal obligation
Housing Associations and Councils	Your personal and tenancy details will be passed on to a housing association or local council for the purposes of housing benefit.	Legitimate interests
Sale of a property	Up to date rent statements may be sent to third party companies upon the sale of your property.	Legitimate interests
Making an offer to prospective Landlords	Your details including, name, occupation and affordability will be shared with prospective Landlords when making an offer on a property.	Legitimate interests
Landlords	Your details including name and contact details will be shared with a Landlord upon offering a tenancy.	Contract
Utility providers	Your details including name, contact details and tenancy details may be shared with energy providers and/or a third-party utility setup provider in respect of your occupancy at the rental property.	Contract
Deposits	Your details including name, contact and tenancy details will be shared with the relevant deposit protection scheme.	Legal obligation
Repairs	Your details including name, contact and tenancy details will be shared with a third-party contractor or developer in respect of repairs.	Legitimate interests
Survey Access	Your details including name, contact and tenancy details will be shared with a third-party surveyor to arrange access.	Legitimate interests / Contract
Block Management Agents	Your details including name, contact and tenancy details may be shared with block management agents.	Legitimate interests
Other agents	Your details including name, contact and tenancy details may be shared with other agents whereby the other agent has, is or will manage a property relating to your tenancy.	Legitimate interests
Financial institutions	Your details including name, contact and tenancy details may be shared with banks or financial institution in respect of rent payments.	Legitimate interests
References	Your details including name and tenancy to include condition and rental payments will be passed on to other agents and landlords for the purposes of referencing.	Legitimate interests
Eviction	Your details including name, contact and tenancy details may be shared with legal representative and enforcement officers in respect of eviction proceedings.	Legal obligation / Contract
Anti-Money Laundering	You will be required under specific regulations to provide documentation which may be verified by a third party if required.	Legal obligation
Protecting life	Your personal details may be provided to any authority requesting the information should it be necessary to protect life	Vital interests
Sub-agents	When Ascend has no geographical presence in an area a carefully selected sub-agent will be appointed.	Legitimate interests
Inventory software providers	Ascend utilises a trusted software provider to perform tenancy inventories. Tenants’ names are linked to property addresses for the purposes of identification.	Legitimate interests
Conveyancers	When entering in to a property transaction Vendors and Buyers details will be exchanged with the appointed conveyancers.	Contract
Electronic signatures	Ascend uses a trusted electronic signature platform that collates various personal data.	Contract
Website	When registering your interest your personal details will be sent to the relevant branch office to be stored and for contact to be made.	Legitimate interests
Cookies	Ascend only use this cookies for traffic log purposes and does not contain any personal data. This information statistically analysed and then the data is removed from the system.	Legitimate interests
Making payments	If you make rent, deposit, maintenance recharge or other payments through us, we may process your personal information and share relevant payment information with our payment processing service providers in order to administer and process the transaction.	Performance of a contract with you and, where applicable, our legitimate interests in administering payments and managing our business operations.

Ascend's Data Retention Policy

Ascend Estates LTD are committed to protecting and respecting your privacy, it is due to recognising this responsibility that we are registered under the UK Data Protection Act 2018 – MEM Number: ZA065739, for further information please visit www.ico.org.uk.

Introduction

1. While carrying out our various functions, an accumulation of data is taken from both individuals, and external organisations. These documents and records are stored in several formats, examples of which include, (but are not limited to) communications such as letters, emails, call recordings; financial information including invoices, statements and reports; legal documents such as contracts, leases and deeds; and information relating to landlords, vendors, applicants, purchasers, tenants and other individuals expressing interest in property.
2. For the purposes of this policy, the terms ‘document’, ‘data’ and ‘records’ include information in both hard copy, and electronic form.
3. In certain circumstances, it may be necessary to retain specific documents to fulfil our statutory and regulatory requirements, or to meet justifiable operational needs. Document retention will also be required to evidence events or agreements in the case of disputes, and to preserve information which has historic value. This policy has been written with consideration of the needs of both; Ascend, and data subjects alike, it strikes a careful balance between our legal obligations, maintaining operational efficiency, in addition to setting retention periods that are appropriated to the data’s purpose.
4. The retention of all documents and records would be impractical, therefore the disposal of data forms an important aspect of this policy. All data is disposed of responsibly and done to ensure that Ascend can maintain sufficient electronic, and office storage space. Ascend also operate a “paper light” approach to hard copy documents, this means where possible records are retained electronically as opposed to hard copies.

Ascend is keen to be proactive in their approach by providing data subjects full transparency on how their data will be retained, and ultimately disposed. This Data Retention Policy should be read in combination with our Privacy Policy. It takes account of the context within which Ascend operates, including the legal and regulatory environment, for example compliance with the fifth data protection principle, the expectations of stakeholders, and Ascend’s ongoing legal obligations. It is intended primarily as a resource to inform you about how data is held, processed, archived, and destroyed to enable disposal activity to be carried out in a consistently controlled manner.

A table containing the intended retention period is given for each relevant data category. The retention period applies to all records in that category default, and will be adhered to wherever possible, although it is recognised by Ascend that there may be exceptional circumstances which require documents to be kept for either shorter, or longer periods. In addition, it should be noted that, in line with GDPR and Ascend’s obligation to implement appropriate physical and technical security measures, the data and information held by Ascend electronically is periodically backed up. These backup copies are maintained indefinitely and in accordance with Ascend’s IT Security Policy to ensure the consistency and stable framework upon which Ascend operates its business. On this basis these backup copies are unaffected by the retention periods for each relevant data category which form part of this policy. The data set which forms part of each backup copy will be unaffected by the retention periods and action taken in line with the retention periods as referred to below.

Retention periods also apply to all formats of records, i.e. paper and electronic, unless specifically stated otherwise.

The primary factors that inform decisions on retention are:

• Business need.
• Services provided to our customers.
• Provision of professional estate agency and associated activities.
• Our experience of when retention of information and data is likely to be beneficial to the data subject as relevant to the specific services, they seek from Ascend, including estate agency services.
• Legislative and regulatory requirements.
• Informed and express consent of the data subject.

In our experience, data subjects are often keen to consent to Ascend maintaining data and information beyond the periods referred to as part of this policy. The reason and justification for these extended periods of retention, by way of example, can include:

• Provision of extended record keeping services.
• Removing an administrative burden from data subjects.
• Enabling an ease of operation between Ascend and the data subject.
• Maintaining an ongoing business relationship, which may be limited to matters such as a data subject’s ongoing interest in the property market, beyond the periods maintained as part of the policy.

Data Retention Schedule - (Summary)

It is Ascend’s policy to retain all information only for as long as specified in the Data Retention Schedule.

This rule is just a target period for retention, if there is no longer a requirement to keep the personal data for its entirety then it may be disposed of securely before. Ascend will aim to assess and update data held in accordance with this policy on an annual basis, therefore a certain amount of data can periodically be archived, or anonymised.

Below is the retention table for Ascend:

This section gives a guide to the categories which have legislation determining the length of time for which personal data within that category should be retained.

Category	Examples & Retention Period
Complaints	• Correspondence with complainants, The Property Ombudsman Current year plus 6 years
Contractual arrangements	• Supplier agreements, service level agreements, assured shorthold tenancies Legal contracts Tender documentation Life of contract plus 6 years
Governance papers	• Articles, Instruments, and company administration records Agendas and minutes of meetings Current year plus 6 years
Data subject access requests ("SARs")	• Correspondence regarding SARs (including but not limited to; requests for a copy of an individual’s personal data, and requests for personal data to be erased) Current year plus six years
Know Your Client and Money Laundering Information	• Copies of Passports and Proof of Address Minimum of 5 years from the end of the business relationship (unless other criteria exists as per relevant legislation)
Estate Agency Relevant Information	• Details of offers to purchase, deposit information, Memorandum of sales Current year plus 6 years

Update your data

Whether you’re a Landlord or a Tenant you can update your data 24/7. Simply go to www.ascendproperties.com, select either Landlord or Tenant > click on the Login link on the right-hand side of the screen. Once logged in you can go to your personal details, update and submit.

Alternatively, please see ‘How to request your data below’.

Right of Access

You have the right to request what data Ascend holds about you and the lawfulness of processing your data. This is commonly referred to as a Subject Access Request (SAR).

Restriction on data

Anyone engaging with Ascend can request that the processing of their data be restricted if there is no lawful basis for processing your data. In order to do so you must state what data you would like restricting and why.

Erasure of Data

You have the right to request that your personal data be deleted if any of the following rules apply:

• The personal data is no longer necessary in relation to the purposes for which they were collected.
• If you withdraw consent where there is no other lawful basis for retaining your data.
• If the personal data is found to have been unlawfully processed.
• For compliance with a legal obligation in Union or Member State law to which Ascend is subject.

Data Portability

Ascend will provide data in a way that is accessible and machine-readable. You may also request the right for your data to be transferred to another organisation. Ascend will honour the request if technically feasible.

Ascend will only engage with controllers and processors located in the European Economic Area (the EEA).

Objections to the use of Data

If you object to the use of your data, you must identify the exact data that you wish to be protected and why.

Requesting your data

All data requests can be made verbally or in writing to Ascend’s Data Protection Officer.

Ascend will take reasonable measures to verify your identity.

Ascend will respond at the earliest opportunity and in accordance with the Information Commissioner’s Office guidelines.

A reasonable fee may be charged should a request be manifestly unfounded or excessive, particularly if the request is repetitive.

In the event that Ascend can demonstrate the lawful basis for processing the data and only if Ascend should need to, Ascend can continue to process the data despite objection.

If your request is rejected and you believe it be unfounded, then you can refer the matter to the Information Commissioner’s Office.

Ascend’s Data Protection Officer

Chris Norman
chris.norman@ascendproperties.com
0161 413 6542

FAO Chris Norman Ascend,
Stafford Court,
145 Washway Road,
Sale, M33 7PE

Information Commissioner’s Office

https://ico.org.uk/make-a-complaint/
https://ico.org.uk/global/contact-us/

Tel: 0303 123 1113

Data breaches

A 'personal data breach' means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Ascend's Data Protection Officer will notify the ICO of a breach without undue delay with a written explanation for the reasons behind data breach. This will be no later than 72 hours after discovery by Ascend's Data Protection Officer.

If the breach is likely to result in a high risk to the rights and freedoms of individuals, then Ascend’s Data Protection Officer will inform those concerned directly and without undue delay.