Privacy Policy

The Dulwich Estate (“we”, “us”, or “our”) is committed to protecting and respecting the personal data that we hold. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for the purposes described in this privacy statement or as made clear before collecting personal data.

The Dulwich Estate's address is as follows:

The Old College, Gallery Road, London, SE217AE

www.thedulwichestate.org.uk is owned and operated by The Dulwich Estate.

We collect information that you provide to us directly to enable us to deliver our services. We also collect information automatically when you visit our website, namely your IP address, the pages you had previously visited or when you use our services, including usage, log and cookies information or similar technologies.

 

PERSONAL DATA

Under the and Data Protection Act 2018 ('the Act') and the General Data Protection Regulation (Regulation (EU) 2016/679) ('GDPR'), personal data is defined as 'any information relating to an identified or identifiable natural person ('data subject'), by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person'.

We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose are set out in the relevant sections below.

The personal data that is provided to us is provided either directly from the individual concerned, from a third party acting on behalf of an individual, or from publicly available sources (such as internet searches, Companies House).

Where we receive personal data that relates to an individual from a third party, we request that this third party inform the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.

 

THE DATA CONTROLLER

A data controller is the individual or legal person who controls and is responsible to keep and use personal data in paper or electronic files. The Dulwich Estate is the data controller as defined by relevant data protection laws and regulation.

 

LAWFUL PROCESSING

The lawful bases for processing are set out in Article 6 of the GDPR. At least one of these must apply whenever personal data is to be processed:  

  • Consent: you have given to us consent for your personal data to be processed for a specific purpose.
  • Contract performance: the processing is necessary for the performance of a contract you have with us, which had asked you to take specific steps before entering into a contract.
  • Compliance with legal obligation: the processing is necessary for us to comply tax, social security obligation, employment law, etc.
  • Protection of vital interests: the processing is vital to an individual's survival.
  • Public interest: the processing is necessary for us to perform a task that is in the public interest or for its official functions, and the task or function has a clear basis in law.
  • Legitimate interests: the processing is necessary for our legitimate interests, or the legitimate interests of a third-party, unless there is a good reason to protect the individual’s personal data that overrides those legitimate interests.

DATA RIGHTS 

Your data subject rights are listed below:

  • the right of access.
  • the right to rectification.
  • the right to erasure or right to be forgotten.
  • the right to restriction of processing.
  • the right to be informed.
  • the right to data portability.
  • the right to object.
  • the right not to be subject to a decision based solely on automated processing.

Under the Act and the GDPR, you may ask for a copy of the information we hold about you and you may request rectifications be made to this information if it is inaccurate or not up to date. Please write us to info@thedulwichestate.org.uk.

 

PERSONAL DATA WE COLLECT

We provide services to individuals as well as businesses, non-profits, and other organisations. The exact data held will depend on the services to be provided.

Where we engage with clients for professional services, we may collect and process personal data in order to satisfy a contractual obligation. We request that clients only provide the personal data that is required for us to fulfil our contractual obligation.

We collect personal data from our contacts, which covers both potential and prior customers, as well as potential and prior employees, are held in our DMS and CMS systems.

This information is entered into the system after contact is made between a staff member of the Dulwich Estate and a business contact individual.

We use technology profile our business contacts, so that we can assess the health of our relationship with our business contacts. We will rely on the appropriate condition for processing data.

Personal data that may be stored in the CRM tool includes, but is not limited to, name, email address, physical address, job title.

Where an individual is applying to work for The Dulwich Estate, personal data is collected through the application process. Data is often collected through forms on the website, details of which can be found in the section describing people who use our website. Data collected via the website will be used for the purposes detailed below.

There are a number of purposes that personal data for applicants are collected:

  • We process an applicant’s personal data in order to assess their potential employment at the Dulwich Estate.
  • Administration and management. We may also use this personal data in order to make informed management decisions and for administration purposes.

Personal data collected for applicants is held for as long as necessary in order to fulfil the purpose for which it was collected, or for a maximum of two years where those purposes no longer become necessary.

We collect and process personal data about our suppliers, subcontractors, and individuals associated with them. The data is held to manage our relationship, to contract and receive services from them, and in some cases to provide professional services to our clients.

We also have security in place at our tollgate, for the physical security of client information and for the benefit of our staff.

 

WHAT DATA WE PROCESS 

We will process any of your personal data, in accordance with our obligations under the Act and the GDPR.

  • Services to businesses, non-profits, and other organisations. We process the personal data of individuals associated with our clients. Personal data may include any relevant financial or non-financial information necessary for us to provide our services. As an example, this may include contact details, payroll data, employee information (including details about dismissal), lists of shareholders, customers and suppliers and any other specifically relevant data.
  • Services to individuals. Personal data may include contact details and tax identifiers, information about business activities, investments, and other financial interests, payroll and other income, and any other specifically relevant data.

 

WHY WE PROCESS YOUR DATA 

Where personal data on business contacts is held, it is used for a number of purposes, as follows:

  • Administration and management.
  • Promote and develop our offerings.
  • Communication of technical updates.
  • Hosting and facilitating of events.
  • Relationship management.

Where data is collected for professional services, it is used for a number of purposes, as follows;

  • Providing services to clients. Data is processed in accordance with our letter of engagement between our clients and us, and may sometimes be further clarified in written documentation supplied before any data processing may occur. We provide a range of professional services to our clients, which includes;
  • Client management. When communicating with and assessing the needs of clients, personal data may be processed in order to ensure that their needs are appropriately satisfied. This may include assessing whether the collection of services is provided to our clients are appropriate.
  • In order to manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing client relationships, hosting events, administering client facing applications, and maintaining internal operating processes.
  • In order to undertake professional services, we may from time to time be required to collect and process personal data in order to fulfil regulatory, legal or ethical requirements. This may include (but is not limited to) the verification of identity of individuals.

 

SHARING YOUR PERSONAL DATA 

We may disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any agreements, or to protect the rights, property, or safety of the organisation, or other individuals. This includes exchanging information with other companies and organisations for the purposes of safeguarding or other statutory regulations we have to comply with as well as those organisations with whom you and we have reciprocal agreements for providing services for education or professional development.

We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems.  For example, providers of information technology, cloud-based software as a service provider, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are in secure data centres around the world, and personal data may be stored in any one of them.

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

 

THIRD PARTY WEBSITES

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

 

PROTECTING YOUR PERSONAL DATA 

Where possible, personal data resides within the UK territory but may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. If personal data is transferred outside the UK or EEA to a country without a designated adequacy rating, we will request the data subject's consent before processing the data. Consent will not be sought where the processor's Binding Corporate Rules, Standard Contractual Clauses or adhoc contractual clauses stipulate that the data will be processed in accordance with the GDPR.

 

SECURITY OF YOUR INFORMATION

To help protect the privacy of data and personally identifiable information you transmit through use of this our website, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.

 

HOW LONG WE STORE YOUR PERSONAL DATA FOR

We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years).

We may keep data for longer in order to establish, exercise, or defend our legal rights and the legal rights of our clients.

In addition, some of the data we hold may be subject to certain legal and regulatory obligations, which provide a minimum retention period for different types of data. The retention period varies depending on the data we hold.

When we store personal may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

CCTV recordings for the tollgate are typically overwritten after a short period of time unless we identify an issue requiring investigation.

 

CHANGES TO THE THIS PRIVACY POLICY 

This privacy policy was last updated on 28 May 2020. The Dulwich Estate reserves the right to vary this privacy policy from time to time. Such variations become effective on posting on this website. Your subsequent use of this website or submission of personal information to The Dulwich Estate will be deemed to signify your acceptance to the variations.

 

COMPLAINTS 

The Data Protection Officer at The Dulwich Estate and its associated businesses is ClearComm.

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to info@thedulwichestate.org.uk. We will investigate and respond to any complaints we receive.

For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns

Contact details

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113 (local rate)