General Data Protection Regulations (GDPR)
The GDPR regulations are due to be implemented on 25th May 2018 and place requirements and responsibilities on both Lambert Smith Hampton (LSH) and its clients.
In terms of this legislation LSH are defined as a ‘data processor’ and you the client are a ‘data controller’. Under the legislation LSH will assume legal obligations as a data processor to maintain records of personally identifiable information. As a data controller you should ensure your contract with us complies with GDPR.
The regulations apply to ‘personal data’ which is defined as any information that directly or indirectly identifies an individual e.g. names, address, national insurance number and even identifiers such as IP address.
Under the legislation you should provide a suitable privacy notice as you are providing the data that is processed by us. Please update your privacy notice accordingly.
PRIVACY NOTICE
Introduction
Eyre Square Shopping Centre is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us or a 3rd party on our behalf. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Who are we?
Under the legislation Eyre Square Shopping Centre is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are:
Management Office
Eyre Square Shopping Centre,
Eyre Square,
Galway, Ireland
For data matters the data processor is LSH.
The purpose(s) of processing your personal data
We use your personal data for the following purposes:
- Operate, monitor, evaluate and improve our products, services, websites, mobile applications, other digital assets and business.
- Developing new products and services
- Managing communications, assess effectiveness and optimisation of advertising
- Functionality of our websites, mobile applications other digital assets
The categories of personal data concerned
With reference to the categories of personal data covered under the regulation we process the following categories of your data:
Typically LSH collect:
| 1. Title | 2. Employer switchboard numbers | 3. DX Number | 4. Tenure details for property requirement |
| 5. First Name | 6. Company Address | 7. DX Exchange | 8. Price band of property requirement |
| 9. Middle Name | 10. Personal Email | 11. Landlord details | 12. Surname |
| 13. Employer Email | 14. Tenant details | 15. Residential Address | 16. Personal Numbers |
| 17. Lease details | 18. Job Title | 19. Employers annual turnover | 20. Size of your property requirement |
| 21. Department | 22. Size of company you work for | 23. Type of property you are looking for | 24. Employer / Registered Company Name |
| 25. Company website | 26. Area of your property requirement |
What is our legal basis for processing your personal data?
LSH processes your information under the following
- Performance of a contract: where you enter into a contract with LSH and we need to process your information as part of this contract
- Legitimate interests: some information is processed by LSH as part of its legitimate interests which include: Fraud, risk assessment, due diligence, network and information security, suppressions and managing opting out of communications, profiling, direct marketing, monitoring, web analytics, cloud storage, acquisitions, updating customer details, lettings, sales, financial services and other core products and service provided by the data controller
- Public interest: some information is processed in accordance with public interest such as relocations
- Consent: where we process information under consent we will seek you clear and unambiguous consent prior to processing your data
Sharing your personal data
Your personal data will be treated as strictly confidential and will be shared only with 3rd parties as necessary for processing and under contract.
How long do we keep your personal data?
We will keep information for a reasonable amount of time in order to perform the purposes listed above.
We only keep your information for as long as necessary. We generally keep personal information for 7 years after last contact with you. However Eyre Square Shopping Centre reserves the right to keep information for longer if we feel that this is in the legitimate interests of Eyre Square Shopping Centre.
Providing us with your personal data
You are under no statutory or contractual requirement or obligation to provide us with your personal data, but failure to do so will have the following consequences:
An inability or severe restriction in providing you with ongoing relevant product and service updates at our Centre.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time.
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller (known as the right to data portability), (where applicable, i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
Automated Decision Making
We do not use any form of automated decision making in our business.
Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
Changes to our privacy policy
We will update this statement from time to time so we suggest that you review this statement at regular intervals. Where we undergo substantial changes to our privacy statement we will endeavor to inform you directly about these changes.
For a more detailed policy definition visit http://www.lsh.ie/privacy-policy