Where a word appears in bold text in this policy, the definition can be found here
“Schroders”, “we” or “us” means Schroders International Holdings Limited with its registered office at 1 London Wall Place, London, EC2Y 5AU or any of its subsidiaries and/or each entity advised or managed by them, details of which can be found on the Schroders website.
“Schroders Websites” means the websites operated by Schroders or on behalf of Schroders.
“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Schroders (or its representatives or service providers). In addition to factual information such as a name or address, it could include an expression of opinion about or an indication of intention in respect of an individual.
“Tenant” means a tenant or occupier of a property which is owned or managed by Schroders, who may be an individual tenant or a corporate tenant.
“Supplier” means a supplier of services to a property which is owned or managed by Schroders who may be an individual or a corporate supplier.
“You” means each individual to whom this notice is addressed, who may be:
(a) a Tenant or prospective Tenant;
(b) a Supplier or prospective Supplier;
(c) an employee, director, officer or representative of a Tenant or Supplier; or
(d) a visitor to a Schroders Website.
(1.1) Schroders collects and uses certain Personal Data. Schroders is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.
(1.2) At Schroders, we respect your privacy and we are committed to keeping your Personal Data secure.
2. Overview of circumstances in which we handle your personal data
(a) Information we receive during the course of our Tenants’ or prospective Tenants’ relationship with us;
(b) Information we receive during the course of our Suppliers’ or prospective Suppliers’ relationship with us;
(c) Information we receive during the course of the use of the properties which are owned or managed by Schroders; and
The types of personal data we collect
(3.1) We will collect and process the following Personal Data during the course of your relationship with us:
- Information that you provide to Schroders.This includes information about you that you provide to us. The nature of our relationship with you will determine the kind of Personal Data we might ask for, though such information may include:
- basic Personal Data such as first name, family name, national insurance number, email address, phone number, address (including city postcode and country), occupation and job title, bank details, credit and debit card details, ID documentation, tax classifications, gender, and date of birth, and
- sensitive Personal Data, which may be included in information we handle about your nationality, place of birth, health related information, disability status, or details of political affiliations.
- Information that we collect or generate about you. This may include:
- files that we may produce as a record of our relationship with our Tenants and Suppliers, including contact history, property management matters for the administration of our property management system, know your client and anti-money laundering checks and procedures on our Tenants, energy consumption, water usage and usage of other utilities (including meter readings), payment history, authorised signatories of Tenants, health and safety information where insurance claims are made in connection with the use of properties, details of disabilities if requests are made for modifications to buildings to accommodate disabilities, CCTV and other security provisions, car registration plate number for the purpose of car park management; and
- any Personal Data that you provide during telephone and email communications with us which we may monitor and record in order to resolve complaints, improve our service and in order to comply with our legal and regulatory requirements.
- Information we obtain from other sources. This may include:
- information from publicly available sources, including third party agencies such as credit reference agencies; fraud prevention agencies; law enforcement agencies; public databases, registers and records such as Companies House; the FCA Register; the Land Registry; the DVLA, and other publicly accessible sources;
- information obtained from sanctions checking and background screening providers; and
- information held by local authorities, utility providers and other searches undertaken during the conveyancing process.
How we use your information
(4.1) Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
- for the management and administration of properties;
- for the administration of our property management system;
- to set up / on-board new Tenants and/or Suppliers;
- to keep our records up to date;
- to effectively manage Tenant and Supplier relationships and communicate with Tenants and Suppliers in order to provide services or information to them;
- to administer, monitor and maintain IT systems in order to uphold standards of service and protect against cyber threats or malicious activity including abuse and misuse;
- for ongoing review and improvement of the information provided on Schroders Websites to make them user friendly and prevent potential disruptions or cyber attacks;
- in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
- for the administration and maintenance of databases storing your Personal Data.
(4.2) When we use your Personal Data, we comply with applicable law. The law allows or requires us to use your Personal Data for a variety of reasons. These include instances where:
- we are performing our contractual obligations;
- we have legal and regulatory obligations that we have to discharge;
- we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
- we have obtained your consent; or
- the use of your Personal Data as described is necessary for our legitimate business interests, such as:
- allowing us to effectively and efficiently manage and administer the operation of our business;
- maintaining compliance with internal policies and procedures; or
- offering effective, up-to-date security solutions for mobile devices and IT systems.
Disclosure of your information to third parties
(5.1) We may share your Personal Data within Schroders for the purposes described above.
(5.2) We may also share your Personal Data outside of Schroders as further described below:
- with business partners of ours where they are contractually obliged to comply with appropriate data protection obligations;
- with third party agents, contractors and service providers for the purposes of them providing services both to us and to Tenants or Suppliers, for example:
- accountants and auditors;
- professional advisors;
- insurance brokers and providers;
- letting agents and property management agents;
- banks and lenders;
- investors and joint venture partners;
- property maintenance, cleaning, facilities and security providers;
- research analysts and performance benchmarking providers for the real estate industry for the purposes of market analysis;
- business rates advisors;
- registrars and trustees of the relevant Schroders entity; and
- IT and communications providers.
These third parties will be subject to appropriate data protection obligations:
- to the extent required by law or regulation, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators, auditors or public authorities), or to establish, exercise or defend our legal rights; and
- if we sell any part of our business or our assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes.
International transfers of personal data
(6.1) Schroders is a global business with operations around the world. As a result we collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Data to locations outside of your country.
(6.2) Where we transfer your Personal Data to another country it will be protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of the European Economic Area (the “EEA”), for example, this may be done in one of the following ways:
- the country to which we send your Personal Data might be approved by the European Commission as offering an adequate level of protection for Personal Data;
- the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging it to protect your Personal Data, and we assessed that the legislation of the third country of destination enables the recipient to comply with the those clauses;
- in other circumstances the law may permit us to otherwise transfer your Personal Data outside the EEA.
(6.3) You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA by contacting us as described in paragraph 12 below.
How we safeguard your personal data
(7.1) Data is a critical business asset and must be protected appropriate to its risk as well as its importance or value. We operate layers of safeguards and defences designed to ensure that Schroders is able to operate safely. We have extensive controls and mechanisms in place designed to detect, respond and recover in case of any adverse events that may arise.
How long we keep your personal data
(8.1) The length of time for which we hold your Personal Data will vary as determined by the following criteria:
- our legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.
(9.1) In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:
- the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
- the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain your Personal Data to comply with a legal or regulatory obligation or to satisfy our internal audit requirements;
- in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit such data to a third party where this is technically feasible. Please note that this right only applies to Personal Data that you have provided directly to Schroders;
- the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
- the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are required or entitled to retain it;
- the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are required or entitled to refuse that request; and
- the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
(9.2) You can exercise your rights by contacting us using the details provided at paragraph 12 below.
Schroders websites and other websites
Questions and concerns
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.
Last update: July 2020