We are Kin (Students) Limited has registered with the Information Commissioner’s Office, registration number ZA890025.
2 Contact details
Full name of legal entity: We are Kin (Students) Limited
Email address: email@example.com
Postal address: Unit 9, Dalton House, 60 Windsor Avenue, London SW19 2RR
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
4 Third-party links
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Special Category Data
We may collect sensitive (or “special category”), for example personal information relating to your health or whether you have a disability. We will only use this information with your consent, for example to determine whether certain of our homes may be suitable for you and for complying with health and safety requirements.
6 If you fail to provide personal data
Where we need to collect and use personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested (or withdraw your consent so we may no longer use your data), we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with certain products or services). We will advise you if this is the case at the time you fail to provide the data (or withdraw your consent).
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when:
- you register with us to find a home or register an interest in a home;
- you request a home viewing or contact us with an enquiry;
- you enter into a tenancy agreement with us;
- you request marketing to be sent to you;
- you or your organisation register interest in becoming an investor;
- your organisation becomes one of our corporate clients;
- you or your organisation become one of our investors;
- you or your organisation engage with us as a contractor or supplier;
- you submit a job application to us;
- you enter a competition, promotion or survey; or
- you give us feedback or contact us.
- Automated technologies or interactions. When you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data analytics providers such as Google based outside the UK.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
Where we process your personal data as an Employee, this is covered separately in our staff Data Protection Policy.
We will only use your personal data when the law allows us to, that is when we have a Lawful Basis to do so. Please see the Glossary below to find out more about the types of Lawful Basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a Lawful Basis for processing your personal data but in those situations where we do rely on your consent, you have the right to withdraw your consent at any time by contacting us Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you. For example, when you rent a home with us, we will process your information to administer your tenancy agreement.
- Where it is necessary for our legitimate interests (or those of a third party), such as to help us achieve our business objectives and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation. For example, we are required by law to carry out Right to Rent (R2R) checks.
- Where we have your consent. For example, where we want to send you marketing messages by email, or we would like to share your information with third parties so that they may send direct marketing communications to you via email or text message. We will only use your information in such ways if you have given your permission. If you consent to receiving marketing emails from us, you can opt-out at any time by clicking on the unsubscribe link on the email or updating your account preferences. We will only process your special category data with your consent.
9. Credit Reference Rental Exchange
- Not only will we be able to work with you more closely to manage your existing tenancy agreement, your track record as a tenant will enable Experian to use the information supplied to them to assist other landlords and organisations to:
• assess and manage any new tenancy agreements you may enter into;• assess your financial standing to provide you with suitable products and services;• manage any accounts that you may already hold, for example reviewing suitable products or adjusting your product in light of your current circumstances;• contact you in relation to any accounts you may have and recovering debts that you may owe;• verifying your identity, age and address, to help other organisations make decisions about the services they offer;• help to prevent crime, fraud and money laundering;• screen marketing offers to make sure they are appropriate to your circumstances;• for Experian to undertake statistical analysis, analytics and profiling,• and for Experian to conduct system and product testing and database processing activities, such as data loading, data matching and data linkage.
If you would like to see more information on these, and to understand how the credit reference agencies each use and share rental data as bureau data (including the legitimate interests each pursues) this information is provided in this link: www.experian.co.uk/crain (Credit Reference Agency Information Notice (CRAIN)). (For a paper copy, please get in touch with us or with Experian using the contact details in this letter).
10 Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which Lawful Basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
|To allow you to register with us to find a home or register your interest in a home
To allow us to communicate with prospective residents (i.e. tenants) and answer any enquiries
|(a) Identity(b) Contact||(a) Necessary for our legitimate interests (for running our business and responding to enquiries)(b) Necessary to comply with a legal obligation (deposit prescribed information, Right to Rent checks)|
|To accept your tenancy application to become a resident of one of our homes
To allow us to communicate with current residents
|(a) Identity(b) Contact
|(a) Performance of a contract with you (tenancy agreement and maintenance contract)(b) Necessary for our legitimate interests (to recover debts due to us for non-payment of rent)
(c) Necessary to comply with a legal obligation (deposit prescribed information, Right to Rent checks)
|To enable you to work as one of our contractors or suppliers||(a) Identity(b) Contact
|(a) Performance of a contract with you or your organisation(b) Necessary for our legitimate interests (for running our business)
(c) To comply with a legal obligation (e.g. call outs in the event of an emergency)
|To process applications for job applicants||(a) Identity(b) Contact||(a) Necessary for our legitimate interests (for running our business)|
|To contact and manage the relationship with our investors and corporate clients.||(a) Identity(b)Contact
|To manage our relationship with our prospective residents, suppliers and contractors which will include:
(b)where relevant, asking you to leave a review or take a survey
|(a) Identity(b) Contact
(d) Marketing and Communications
|(a) Performance of a contract with you(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services and to develop your website and services and to grow our busines)
|To manage the relationship with our marketing subscribers and current residents including
(b) Asking you to leave a review or take a survey
(c) to make suggestions and recommendations to you about services or homes that may be of interest to you or to ask you to take a survey
|(a) Identity(b) Contact
(d) Marketing and Communications
|(a) On the basis of your consent
(b) Necessary to comply with a legal obligation
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity(b) Contact
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity(b) Contact
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, services, marketing, customer relationships and experiences||(a) Technical(b) Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
11 AUTOMATED DECISION MARKING
We use an automated decision-making system to decide which offers and surveys to send you and how often. We also use third party partners who may use your information to complete automated screening checks that are required for the contract you are entering into with us.
You have the right not to be subject to a decision based solely on automated decision making and processing which has legal consequences for you or similarly significant effects. If you have any questions about this, please contact us by email at: firstname.lastname@example.org
We provide you with choices regarding how we use your personal data for marketing and advertising. Where we do rely on your consent, you have the right to withdraw your consent at any time by contacting us, or by updating your marketing preferences.
13 Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
As you interact with our website, we may automatically collect information about your website usage such as information about your equipment, browsing actions and pattern. We collect this information by using cookies, server logs, and other similar technologies.
Our website uses a limited number of cookies, namely:
- Cookies which simplify the use of our website’s marketing facility;
- Cookies which allow you to store saved advertised properties into a “liked” page;
- Cookies required by Google Analytics in order to measure your website usage and improve the experience for our visitors on an ongoing basis. These cookies collect the information about your IP address, your geolocation and your website usage, namely what pages you visit, how long you stay on each section of the website and what links you click on.
We may use data analytics to improve our website, services, marketing, customer relationship and experiences.
15 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
16 Disclosures of Your Personal Data
We may share your personal data with the parties set out below for the purposes set out in the table above.
We may disclose your information with third parties as follows:
- With any of our companies within the We are Kin Group.
- If we are under a duty to disclose or share it in order to comply with any legal obligations (for example our auditors, legal advisors, other professional advisors, our insurers and HMRC).
- With service suppliers who undertake processing on our behalf (for example reference and credit checks, letting agents, Canopy, and the Tenancy Deposit Scheme).
- With payment providers who undertake processing on our behalf (Go Cardless).
- With debt collection agencies where required to recover rent owned to us.
- With Service providers who provide IT and system administration services and software (such as Arthur Online, Amazon Cloud, Google and SharePoint).
- With third parties that may assist us in providing our services (such as our software providers).
- If you are a resident of one of our homes, we may provide your contact details to tradesmen or contractors who we engage to carry out repairs at the home.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
17 International Transfers
Information about you may held be outside of the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
18 Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, suppliers and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
19 Data Retention
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are set out in
the table below.
|Circumstances in which personal data was provided||How long do we keep it?|
|You contact us as a prospective resident or contact us with an enquiry||2 years in the event you do not become a resident or earlier as part of our annual archiving review.|
|You are a current resident||7 years from termination or expiry of your tenancy agreement or earlier as part of our annual archiving review.|
|You or your organisation are a supplier or contractor providing goods or services to us||7 years from termination of expiry of our contract with you or earlier as part of our annual archiving review.|
|You are job applicant||[2 years] if you do not become an employee, or earlier as party of our annual archiving review.|
|You or your organisation are one of the We are Kin investors||7 years after the cessation of our relationship with you or earlier as part of our annual archiving review.|
|Your organisation is a corporate client||7 years from termination or expiry of our contract or business relationship with you, or earlier as part of our annual archiving review.|
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
20 Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Consent or Consented means you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your Consent at any time by contacting us.
Legitimate Interest(s) means the interest(s) of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our Legitimate Interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our Legitimate Interests against any potential impact on you in respect of specific activities by contacting us.
Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a Legal Obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.