Privacy Notice

General Information

Land Property Management (LPM) trading as BFA Valuers, BFA Estate Agents and BFA Management registered office at Suite 1, Burns House, Town Range, Gibraltar and company number 31260 are committed to protecting and respecting your privacy.

This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be handled.

For the purpose of the General Data Protection Regulation (GDPR) 25th May 2018, the data controller is Land Property Management.

The following index will help you locate information about the data we hold and use in relation to the various services we offer:

Guiding Principles
Estate Management
Rental Management
Estate Agency
Valuers
Our Website
CCTV
Job Applicants
Rights of Data Subjects
Changes to our Privacy Notice
Contact Information

Guiding Principles

We take the handling of your personal data very seriously and, in line with the GDPR, make sure of the following:

Integrity & Confidentiality. We make sure that all data is kept safe and secure at all times.
Minimal. We strive to never hold more data than is necessary to carry out the specific services offered to our clients.
Accurate. We will do our best to keep the data up to date and accurate.
Limited to Purpose. We will only use your data for the specific purpose it was collected or provided for.
Lawful, fair and transparent. We will always be clear about what data we hold, and how we use it, as well as making sure that we have a lawful basis for holding it under the terms of the GDPR.

Estate Management

This service involves management of the common areas of housing estates and commercial property developments on behalf of the owners and occupiers.

The Data We Hold

In respect of owners/keyholders/occupiers: name, address, telephone number(s), email address(es).
In respect of council members: Identification document(s) and any other reasonable documentation in order to comply with our legal and regulatory obligations such as Money Laundering and Terrorist Financing regulations.
In respect of estate employees: Name, address, contract of employment, bank account details, sick leave records, disciplinaries, ETB documentation, CV, qualifications and references.
Minutes of meetings (council meetings, AGM’s, EGM’s) can, on occasion, make reference to specific individuals.
Correspondence from and to owners and occupiers in relation to various matters involving their property/estate, via normal mail and email.
Accounting information in respect of service charge invoicing and payment and related correspondence.
CCTV. Equipment and recordings are held on location, but on occasion, extracts are held at our main offices.

How We Obtain It

Names, addresses and contact information is usually transferred to us by developers or management companies at the point we are contracted as managing agents.

Following changes in property ownership, lawyers involved in the conveyancing provide us with updated information.

We also receive information directly from owners and occupiers.

How We Use It

We use the information we hold in in carrying out our own contractual schedule of services and by extension, meeting the obligations of the management company as defined within each underlease. This includes corresponding with owners, invoicing and collecting service charges, bookkeeping, keeping track of property ownership, calling meetings, enforcing house rules, and managing estate employees.

Lawful Basis

Contractual, both in carrying out our terms of contract with the management company, and also in acting as an agent in fulfilling the obligations of the management company.

Some data, such as that relating to financial transactions, is held on the basis of legal and regulatory obligations.

How Long We Keep It

All contact information is held for the duration of ownership, and subsequently, for 6 years.

Financial information is held for 6 years in order to comply with accounting legislation.

3rd Party Transfers

Information is periodically shared with authorised auditors, law enforcement officials, lawyers, and regulatory bodies.

Rental Management

This service involves the management of private rental properties on behalf of their landlords. We invoice and collect rent, carry out bookkeeping, manage leases and deal with any problems with the properties.

The Data We Hold

In respect of landlords: name, address, contact telephone number(s), email address(es), bank account details.
In respect of rental tenants: name, address, telephone number(s), email address(es).
Accounting information including invoices, payments, statements of account and related correspondence.

How We Obtain It

Information is provided by landlords when they engage our services or obtained directly from rental tenants when they enter rental agreements. In meeting the terms of their rental contract, rental tenants are expected to keep us informed of changes to their contact information.

How We Use It

We use the information in order to carry out general management of the rental property which includes rent collection, chasing of arrears, sending correspondence and contacting rental tenants in case of emergency.

Lawful Basis

It is essential for us to hold the abovementioned data in order to meet contractual obligations both to the landlord of the property being managed, as well as the rental tenants.

Some data, such as that relating to financial transactions, is held on the basis of legal and regulatory obligations.

How Long We Keep It

Contact information will be held for as long as contracts with the landlord and tenant are active. Financial information is held for 6 years in order to comply with accounting legislation.

A tenancy register limited to names and occupation dates will be held for 20 years.

3rd Party Transfers

Information is periodically shared with authorised auditors, law enforcement officials, lawyers, and regulatory bodies.

Estate Agency

This service involves the purchasing, selling and letting of properties.

The Data We Hold

In respect of clients wishing to sell or rent their property: name(s), address, contact telephone number(s), email address(es) .
In respect of clients who have sold or rented their property using our services: name(s), address, contact telephone number(s), email address(es), Identification document(s), financial data, billing address.
In respect of clients wishing to buy or rent a property: name(s), address, contact telephone number(s), email address(es), Identification document(s) and any other reasonable documentation in order to comply with our legal and regulatory obligations such as Money Laundering and Terrorist Financing regulations.
In respect of clients who have bought or rented a property using our services: name(s), address, contact telephone number(s), email address(es), Identification document(s), financial data, billing address.
In respect of Investment clients: name(s), address, contact telephone number(s), email address(es).
Clients making queries via telephone or email: name, contact telephone number(s), email address.

How We Obtain It

Provided by vendor, tenants, purchaser, lawyer or Financial Institutions when filling in one of our forms, corresponding with us or when engaging our services. Additionally, we may obtain data from publicly available sources such as Companies House and Land Property Services in Gibraltar.

How We Use It

To carry out our contractual obligations to you and provide the information and services you request from us.

Lawful Basis

For casual queries the limited data we hold is on the basis of our legitimate interests in carrying out the services you would reasonably expect.

For longer term marketing, such as our mailing list, the basis is explicit consent.

Some data, such as that relating to financial transactions, is held on the basis of legal and regulatory obligations.

How Long We Keep It

Information supplied during a telephone conversation, walk-in or email query will be kept for as long as required to fulfil the query and longer if the query results in the client engaging our services.

Financial information is held for 6 years in order to comply with accounting legislation.

3rd Party Transfers

Information is periodically shared with authorised auditors, law enforcement officials, lawyers, and regulatory bodies.

Valuers

Our team offers surveys, valuations, advice and appraisals of property for a multitude of purposes and clients including valuations for mortgage/accounting purposes, rental purposes and insurance purposes.

The Data We Hold

In respect of private clients: name, address, contact telephone number(s), email address(es), financial data.
In respect of clients referred by lending institutions: name(s), address, contact telephone number(s), email address(es).
Third party contacts (for example keyholders providing access to a property): name, contact telephone number(s).
Customers queries: name(s), contact telephone number, email address(es).

How We Obtain It

Information is provided by property owners, financial institutions, lawyers and property agents when they engage our services, by telephone, email, in person or by filling in one of our forms, signing Terms of Engagement or via bank instructions. Additionally, we may obtain data from publicly available sources such as Companies House and Land Property Services in Gibraltar.

How We Use It

We use the information in order to carry our professional services as per our Terms of Engagement and Terms and Conditions of Use.
To satisfy our insurers.
To meet our obligations to the Royal Institute of Chartered Surveyors (the professional body that regulates us).
Information supplied by clients in respect of third party contacts are used for invoicing purposes or to get access to the property being inspected.
We anonymise data kept for later use in market studies. Market studies are not publicised to the general public but used by for example by financial institutions for statistical purposes and to be used as part of the valuation process for the provision of comparables.

Lawful Basis

For casual queries the limited data we hold is on the basis of our legitimate interests in carrying out the services you would reasonably expect.

The information held in carrying out our services is on the basis of meeting our contractual obligations.

Some data, such as that relating to financial transactions, is held on the basis of legal and regulatory obligations.

How long We Keep It

Financial information is held for 6 years in order to comply with accounting legislation.

3rd Party Transfers

Information is periodically shared with authorised auditors, law enforcement officials, lawyers, and regulatory bodies.

Our Website

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For more information about our use of cookies, please see our Cookie Policy.

Our website is hosted within the EU. Our website providers use adequate encryption to ensure the data you submit is secure.

If you choose to provide us with personal information by submitting a “Contact Form” via our website, we will use that information simply in responding to your query. We will not use the information provided for commercial marketing or for distribution to any other private organisation.

CCTV

We operate CCTV on our premises. CCTV captures recognisable images but not sound. Our use of CCTV is always communicated via signage indicating the area covered.

The Data We Hold

We hold video footage of our cashiers and office entry points.

How We Use It

It is used exclusively for the detection and prevention of crime and processed in a manner compatible with these purposes.

Lawful Basis

It helps us meet our contractual obligations for the safe handling of client monies.

We have a legitimate interest in respect of safeguarding our employees and the data and assets we store on the premises.

How Long We Keep It

Data is kept for six months.

3rd Party Transfers

Information will be shared with law enforcement when necessary.

Job Applicants/Recruitment

From time to time, we have vacancies within our company, and need to collect information in order to asses candidates.

The Data We Hold

For most vacancies we will ask you to provide:

Contact details to include name, address, telephone number(s) and email address(es).
Personal information included in your CV, any application form &/or cover letter.
Job History.
Degree certificates or school transcripts or qualifications.
Proof/copy of valid Driver’s licence.
References.
Proof of right to work within Gibraltar.
Other background check information.
Proof of professional membership; e.g. membership with RICS or AAT.

How We Obtain It

Most of the information will be freely supplied by you when submitting your application, by telephone or in person and in some cases by external sources such as referees, recruitment agencies and government or professional bodies in relation to criminal record checks.

How We Use It

The data you supply us with will be used during the recruitment process to assess your suitability for the role and to comply with our obligations in ensuring you are eligible to work within Gibraltar.

Lawful Basis

At the application stage, any information held will be on the basis of explicit consent.

Subsequent to recruitment, information is held on a contractual and legal basis.

How Long We Keep It

If your application results in an offer of employment your information will be stored within our company’s database and used for a number of purposes to meet with our contractual and legal obligations.

Unsuccessful applicant data will be held for a period of six months from application and then erased unless you have explicitly consented to having us keep your information for longer.

3rd Party Transfers

Information is periodically shared with authorised auditors, law enforcement officials, lawyers, government agencies and regulatory bodies.

Rights of Data Subjects

As a data subject you have the following rights under the GDPR.

The right to be informed.
The right of access.
The right to rectification.
The right to erasure.
The right to restrict processing.
The right to data portability.
The right to object.
Rights in relation to automated decision making and profiling.

Changes to our Privacy Policy

If and when there are any updates to our Privacy Policy relevant to our users and clients, we will reflect these within this Privacy Notice and, where appropriate, contact you informing you of the change.

Contact Information

If you wish to access the data we hold on you, make a formal complaint, or simply request more information about our data protection policy and working practices, please contact us as follows:

Email:	dataprotection@bfagib.com
Telephone:	(+350) 200 42326
Mail:	The Directors Private & Confidential BFA Management 1st Floor Hadfield House Library Street Gibraltar