Introduction
Rhodium is a luxury residence management company, providing bespoke property and lifestyle management services to London's super-prime homes and prestigious residential developments. Rhodium is committed to respecting and protecting your privacy and adheres fully to the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).
Your Personal Data
To enable us to deliver an effective service, at times we need to collect and use personal data. This Privacy Notice explains in detail the types of data we collect, and how and why we will use it.
Client Data
Purpose:
To allow us to communicate our progress in the services we are providing for their developments.
How we get the information and what we collect:
Data is sourced directly from clients. Collection of key data to enable us to provide our services. This includes:
• Names and titles
• Office addresses
• Email addresses and communication preferences
• Contact numbers
• Fax
The lawful basis we rely on for processing this information:
• We have a contractual obligation (Performance of a contract).
Where this data will be stored:
Rhodium offices, London and some property management data hosted on the Qube system, which hosts data in UK data centres.
How long will we keep this data:
6 years after the last entry in a record followed by first review and/or destruction to be carried out in the additional current (+1) accounting year.
Leaseholder and Tenant Data
Purpose:
To provide our property management services to specific clients. This includes:
• Administering service charge budgets
• Collecting rent
• Building repairs & maintenance
• Insurance claims, etc.
How we get the information and what we collect:
This information is sourced from leaseholders, solicitors, clients, or through our concierge teams. This is a combination of electronic and paper records, holding the basic data we require to deliver our services. This includes:
• Personal address
• Work address, other address
• Contact numbers
• Email addresses and communication preferences
• Third parties addresses
• All contact details and communication preferences
• Company numbers
The lawful basis we rely on for processing this information:
• We have a contractual obligation (Performance of a contract).
Where this data will be stored:
Rhodium offices, London, other property data is hosted in a variety of systems and locations; Qube (UK), Locale (within the UK/European Economic Area).
How long will we keep this data:
Up to 15 years in line with Royal Institute of Chartered Surveyors (RICS) guidance.
Employee Data
Purpose:
To allow the company to manage the employment of its staff and to ensure we have all the information to prove our employees are eligible to work in the UK and are appropriate for the workplace.
How we get the information and what we collect:
This information is sourced directly from our employees. This information allows us to employ and pay people, and includes:
• Personal address
• Work address
• Bank details
• NOK (Next of Kin) details
• IDs
• Contact numbers
• Email address
• Contracts
• HR documents
• Certificates
The lawful basis we rely on for processing this information:
• We have a contractual obligation (Performance of a contract).
Where this data will be stored:
Rhodium offices, London and hosted on Bamboo HR, which potentially involves processing in UK and USA (in line with the UK extension to EU-U.S. Data Privacy Framework).
How long will we keep this data:
3 years from termination of employment date.
Visitor Data
Purpose:
To allow us to monitor visitors in the buildings we manage, for security purposes of the leaseholders and clients and to meet our duty of care around their personal safety (e.g. in case of a fire).
How we get the information and what we collect:
This information is sourced from employees, clients, leaseholders ,visitors, recruiters and contractors. Visitors book and electronic management system including:
• Names
• Addresses
• Contact numbers
• Email addresses
• Identification
The lawful basis we rely on for processing this information:
• We have a legitimate interest.
Where this data will be stored:
Rhodium offices, London, Qube (UK), Locale (within the UK/European Economic Area).
How long will we keep this data:
Reviewed every twelve months and deleted where no longer current or required.
Supplier Data
Purpose:
To allow us to effectively vet suppliers, and monitor them in the buildings we manage, for security purposes of the leaseholders and clients and to meet our duty of care around their personal safety (e.g. in case of a fire).
How we get the information and what we collect:
This information is sourced from suppliers, clients, employees, visitors and leaseholders. Contact details of suppliers so we can do business with them:
• Names and titles
• Company name
• Bank details
• Office addresses
• Email addresses
• Telephone numbers
• Fax
The lawful basis we rely on for processing this information:
• We have a legitimate interest.
Where this data will be stored:
Rhodium offices, London, Qube (UK), Dwellent (Ireland), Wrike (USA in line with the UK extension to EU-U.S. Data Privacy Framework), Adiuvo (UK), Elogs (UK), Prism (UK)
How long will we keep this data:
6 years after the last entry in a record followed by first review and/or destruction to be carried out in the additional current (+1) accounting year.
Your Rights
Whilst we are holding or processing your personal data , you have the following rights:
Right to be informed – you have the right to be informed about the collection and use of your personal information. Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to have inaccurate data that we may hold about you corrected, or completed if it is incomplete.
Right to erasure (to be forgotten) – in certain circumstances you can ask for the data we hold about you to be deleted.
Right to restriction of processing – where certain conditions apply you can ask us to restrict the processing of your personal data.
Right to object – in certain circumstances you have the right to object to the processing of your personal data.
Right to data portability – you have the right to have the data we hold about you transferred to another organisation, or to you.
Right to object to automated processing – you have the right to not be subject to decisions based solely on automated processing, including profiling.
Right to withdraw consent - where you have consented to the processing of your personal data, you have the right to remove this consent at any time.
Right to complain to the Information Commissioner (ICO) – you have the right to complain to the ICO if you feel your data has not been handled correctly, or if you are dissatisfied with our response to any requests you have made to us regarding the use of your personal data.
You can exercise these rights at any time by contacting the appropriate individual listed under Key Contacts.
Disclosure
At times, we will need to disclose/share certain pieces of personal data so we can deliver our services effectively:
• We may need to disclose some of our client information to other suppliers, insurance companies, regulatory bodies, their leaseholders, or other clients. Sharing personal data with these third parties allows us to deliver our services e.g. to provide value add through additional suppliers, to process insurance claims, to prove regulatory compliance etc.
• We may need to disclose some leaseholder information with organisations such as insurance companies, lawyers, clients, auditors, suppliers, and at times debt collectors. We share data with these third parties to ensure we are complying with our contractual arrangements, and to enable us to deliver our services to the highest possible standards in line with the requests of our clients and their leaseholders. At times this may involve sharing information outside of the United Kingdom, normally we will only so this under the instruction of leaseholders.
• We may disclose minimal personal data on our employees to clients, leaseholders, or suppliers. This is to demonstrate the individual's skills and experience to clients, and to allow leaseholders and suppliers to communicate with our staff.
• We share data with a number of suppliers who host key systems for us. They do not use this data, only host it so we can utilise their software. They are:
– Qube (hosted in London)
– Locale (hosted within the European Economic Area)
– Bamboo HR UK and USA (in line with the UK extension to EU-U.S. Data Privacy Framework) – Dwellent (Ireland)
– Wrike (USA in line with the UK extension to EU-U.S. Data Privacy Framework)
– Adiuvo (UK)
Key Contacts
Our Data Protection Representative is responsible for helping to ensure that we treat your personal data appropriately. They can be contacted through the following means:
Data Protection Representative
Aimi Hunt
E: aimi.hunt@rh-45.com
DL: 0203 457 0970
Post: Rhodium, 65 Curzon Street, London, W1J 8PE
Complaints
If you feel you need to make a complaint about how we are processing your personal data, you can contact the Information Commissioner’s Office (ICO) as the relevant supervisory authority. They can be contacted through the following means:
Information Commissioners Office
Website: https://ico.org.uk/concerns/handling/
Helpline: 0303 123 1113
Email: casework@ico.org.uk
Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Document Control
This Privacy Notice may be subject to change where necessary and is issued on a version controlled basis. We will provide you with a new Privacy Notice when we make any substantial changes.
This Privacy Notice was last reviewed on October 7, 2024
