Privacy Policy

THE INSTITUTE OF RESIDENTIAL PROPERTY MANAGEMENT LIMITED:

The Institute of Residential Property Management Limited recognises that data protection is the cornerstone of its operations and is committed to processing information about individuals in ways that comply with its obligations under the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 (“DPA”).

As a membership organisation, it is necessary for us to process information relating to individuals, including our individual members. Whenever we process the personal data of individuals, we will ensure that we are clear with those individuals about what we do (or may do) with their information.

This privacy policy explains what personal data (or “information”) we hold about individuals and contains important information on who we are, how and why we collect, store, use and share personal information, individuals’ rights in relation to their personal information and on how to contact us and supervisory authorities in the event you have a complaint.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy which we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your personal information. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Who we are

The Institute of Residential Property Management Limited collects, uses and is responsible for certain personal information about individuals. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and the Data Protection Act 2018 and we are responsible as the ‘controller’ of that personal information for the purposes of those laws.

In this privacy policy, references to “we” or “us” mean The Institute of Residential Property Management Limited.

We are a company registered in England and Wales with company number 6207464 and the registered address 20 Eversley Road, Bexhill-on-Sea, East Sussex TN40 1HE.

We have a compliance officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise Your rights, please contact the compliance officer using the details set out below.

Contacting our compliance officer

If you have any questions about this privacy policy or our privacy practices, please contact our compliance officer in the following ways:

By post: The Institute of Residential Property Management Limited, 71 Gloucester Place, London W1U 8JW
By email: data@irpm.org.uk

You have the right to make a complaint at any time (please see How to complain) to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues. We would however appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

DATA PROTECTION PRINCIPLES

We will comply with the data protection principles set down by the GDPR when gathering and using personal information.

The personal information we collect and use

In the performance of our role, we collect and process information relating to individuals.

The information we collect (and how we handle that information) differs depending on who the individual is, and why we are collecting their information.

Our services and website(s) are not intended for children and we do not knowingly collect any personal information relating to children.

THE PERSONAL INFORMATION WE COLLECT AND USE RELATING TO OUR MEMBERS

The IRPM will collect and use personal information relating to its members. Members in this context includes all levels of hierarchy of membership, and those undertaking professional qualification via our training programmes and apprenticeships. It also includes any applicants for membership and/or training and apprenticeships.

Our collection and use of this information is necessary for us to meet our key objectives, which include:

Raising standards in the residential property management sector
Providing individuals with independent accreditation of their professional skills
Providing a career development path for individuals
Aiding in the process of recruiting new entrants to the sector
Assisting practitioners in assessing job applicant capabilities
Providing opportunities for Continuing Professional Development
Improving the standing of the sector in the eyes of the public

The information we collect

We may collect the following types of information:

Name, date of birth, address(es) – work and home, email address(es), telephone number(s), employer (if provided), and other contact details
If provided: other qualifications, experience, number of units managed, how referred to IRPM
Financial data, including bank account and payment card details and details of your payments to/from the IRPM for courses, training, exams, events, and other products/services
Details of any enquiry you have made, or any report you have submitted to us
Exam results, CPD activities, notes of important communications between you and us
Profile data relating to your use of our website(s) including usernames and passwords, your interests, preferences, feedback and survey responses
Technical data including your internet protocol address, 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 may use to access the website(s)
Marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences

In limited circumstances, we may collect limited special category data including details about your race or ethnicity, religion and health. We will only collect this information where you choose to provide it to us, and it will be used only to ensure we are able to make appropriate adjustments for you at events, courses or examinations that you may wish to attend and in an anonymised form as part of our use of aggregated data (please see below for further information).

In addition to receiving information directly from our members, from time to time we also receive information about our members from third parties, for example their employers.

How we collect it

We use different methods to collect information from and about you, including through:

Direct interactions: You may give us information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:
- apply for membership
- apply for or purchase our products or services
- create an account on our website(s)
- subscribe to our services or publications
- request marketing to be sent to you
- enter a competition, promotion or survey
- give us feedback or contact us

Automated technologies or interactions: As you interact with our website(s), we will automatically collect technical data about your device, browsing actions and patterns. We may collect this information by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

Third parties or publicly available sources: We will receive personal information about you from various third parties and public sources as set out below:
- technical information from analytics providers such as Google, based outside the EU
- contact details, financial and transactional data from providers of technical, payment and delivery services such as:
  - DotDigital based outside the EU
  - EventBrite based outside the EU
  - SurveyMonkey based outside the EU
  - Moodle based outside the EU
- information from your employer or former employer relating to your employment status, qualifications and experience
- information relating to your identity and contact details from publicly available sources such as Companies House and the Electoral Register based inside the EU.

Why we collect it

The collection of this information is required from our members so that we can:

Provide our members with services they expect to receive from us, including newsletters, technical updates, details of our training and events
Improve and develop our services and performance as an organisation
Develop and provide products and services, including training and events
Meet our regulatory obligations.

Who we share it with

From time to time, we may share your personal information with the following categories of recipients:

Communication platforms and services
Survey platforms and services
IT and software support
Financial services, including Accountants
Member's employer (where the employer is paying the Member's fees and the Member is linked to the employer's account) in connection with the payment of the Member's membership or services fees, or to pass on details of a Member's CPD history, exam results, training attendances or details of a Member's membership status.

Some of those third-party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’.

We will share personal information with law enforcement or other authorities if required by applicable law.

We will not share your personal information with any other third party.

Where your personal information may be held

Information may be held at our offices, and third-party agencies, service providers, representatives and agents as described above.

We have security measures in place to seek to ensure that there is appropriate security for information we hold.

How long your personal information will be kept

We will retain your personal information for no longer than is reasonably necessary for the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, 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 available on request from us by contacting us.

Our lawful basis

We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Our use of your personal data is necessary for us to carry out a contract that we have with you, as our member.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation

THE PERSONAL INFORMATION WE COLLECT AND USE RELATING TO ATTENDEES AT OUR EVENTS AND PARTICIPANTS IN EXAMINATIONS OR COURSES

The IRPM will collect personal information from individuals who attend IRPM hosted events, including our annual seminar and regional roadshows.

The information we collect

We may collect the following types of information:

Name, address, email address, telephone number(s) and other contact details
Your company’s name, your position in the company, the company’s address and your company email address and telephone number
Information required to provide you with a service and details of our services that you have used (for example, attendance at our event)
Details of other qualifications, experience, number of units managed, how referred to IRPM
Financial data, including bank account and payment card details and details of your payments to/from the IRPM for courses, training, exams, events, and other products/services
Details of any enquiry you have made, or any report you have submitted to us
Exam or course entries, results, CPD activities, notes of important communications between you and us
Profile data relating to your use of parts of our website(s) relating to virtual events, courses and examinations including usernames and passwords, preferences, feedback and survey responses
Technical data including your internet protocol address, 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 may use to access the website(s)
Marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences

How we collect it

We use different methods to collect information from and about you, including through:

Direct interactions: You may give us information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:
- book attendance at an event, course or examination
- attend or participate in an event, course or examination
- apply for or purchase our products or services
- subscribe to our services or publications
- request marketing to be sent to you
- enter a competition, promotion or survey
- give us feedback or contact us

Automated technologies or interactions: If you interact with our website(s) as part of booking or attending any event, course or examination, we will automatically collect technical data about your device, browsing actions and patterns. We may collect this information by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

Third parties or publicly available sources: We will receive personal information about you from various third parties and public sources as set out below:
- technical information from analytics providers such as Google, based outside the EU contact details, financial and transactional data from providers of technical, payment and delivery services such as:
  - DotDigital based outside the EU
  - EventBrite based outside the EU
  - SurveyMonkey based outside the EU
  - Moodle based outside the EU
- information from your employer or former employer relating to your employment status, qualifications and experience
- information relating to your identity and contact details from publicly available sources such as Companies House and the Electoral Register based inside the EU.

Why we collect it

The collection of this information is required so that we can host the events, courses and examinations, and it helps us to:

Provide the events, courses and examinations
Improve and develop our services and performance
Develop and provide products and services, either on our own or in conjunction with third parties
Meet our regulatory obligations

We also collect personal information about individuals from their company directly.

Who we share it with

From time to time, the IRPM may share your personal information with the following categories of recipients:

Website and IT support
Marketing platforms and services
Survey platforms and services
Event sponsors
Third parties responsible for providing services at our events
Providers of training courses or examinations, including independent examination moderators
Member's employer (where the employer is paying the Member's fees and the Member is linked to the employer's account) in connection with the payment of the Member's membership or services fees, or to pass on details of a Member's CPD history, exam results, training attendances or details of a Member's membership status

We will share personal information with law enforcement or other authorities if required by applicable law.

We will not share your personal information with any other third party.

Where your personal information may be held

Information may be held at our offices, and third-party agencies, service providers, representatives and agents as described above.

We have security measures in place to seek to ensure that there is appropriate security for information we hold.

How long your personal information will be kept

Details of retention periods for different aspects of your personal data are available on request from us by contacting us.

Our lawful basis

We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Our use of your personal data is necessary for us to carry out a contract that we have with you, as an attendee or participant in an event, course or examination.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation

It is necessary for us to process the personal information so that we can host those events. Our processing activities are a targeted and proportionate way of achieving this. Attendees reasonably expect that we will process their personal information in this manner.

THE PERSONAL INFORMATION WE COLLECT AND USE RELATING TO THIRD PARTIES

The IRPM will collect personal information from third parties, including members of the general public who contact us.

The information we collect

We may collect the following types of information:

Name, address, email address, telephone number(s) and other contact details
Your company’s name, your position in the company, the company’s address and your company email address and telephone number
Details of any enquiry you have made to the IRPM (for example, complaints raised)

How we collect it

We use different methods to collect information from and about you, including through:

Direct interactions: You may give us information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:
- apply for a job or contact another company through our jobs pages
- agree to provide us with any products or services
- apply for or purchase our products or services
- create an account on our website(s)
- subscribe to our services or publications
- request marketing to be sent to you
- enter a competition, promotion or survey
- give us feedback or contact us

Automated technologies or interactions: As you interact with our website(s), we will automatically collect technical data about your device, browsing actions and patterns. We may collect this information by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

Third parties or publicly available sources: We will receive personal information about you from various third parties and public sources as set out below:
- technical information from analytics providers such as Google, based outside the EU
- contact details, financial and transactional data from providers of technical, payment and delivery services such as:
  - DotDigital based outside the EU
  - EventBrite based outside the EU
  - SurveyMonkey based outside the EU
  - Moodle based outside the EU

information from your employer or former employer relating to your employment status, qualifications and experience
information relating to your identity and contact details from publicly available sources such as Companies House and the Electoral Register based inside the EU.

Why we collect it

The collection of this information helps us to:

Provide our members with services they expect to receive from us
Improve and develop our services and performance
Meet our key objectives
Meet our regulatory obligations

Who we share it with

From time to time, we may share your personal information with the following categories of recipients:

Website and IT support
Companies who are advertising jobs which you have applied for through our website(s)
Marketing platforms and services
Survey platforms and services

We will share personal information with law enforcement or other authorities if required by applicable law.

We will not share your personal information with any other third party.

Where your personal information may be held

Information may be held at our offices, and third-party agencies, service providers, representatives and agents as described above.

We have security measures in place to seek to ensure that there is appropriate security for information we hold.

How long your personal information will be kept

Details of retention periods for different aspects of your personal data are available on request from us by contacting us.

Our lawful basis

We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Our use of your personal data is necessary for us to carry out a contract that we have with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation

It is necessary for us to process the personal information we have described so that we can perform our role as a member organisation. Our processing activities are a targeted and proportionate way of achieving this.

FURTHER INFORMATION ABOUT HOW WE MAY USE YOUR PERSONAL INFORMATION

Direct marketing

We strive to provide you with choices regarding certain uses of your personal information, particularly around marketing and advertising.

We may use your information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if:

you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing; or
you have expressly consented to receiving marketing from us.

We will obtain 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 or by contacting us at data@irpm.org.uk at any time.

Where you opt-out of receiving marketing messages, this will not apply to information provided to us as a result of a purchase of products or services, membership or other transactions.

If you fail to provide information

Where we need to collect information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Aggregated information

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal information but is not considered personal information in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your personal information to calculate the percentage of users accessing a specific website feature. However, if we combine or connect personal information so that it can directly or indirectly identify you, we treat the combined information as personal data which will be used in accordance with this privacy policy.

Links to third-party websites

Our website(s) may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for any privacy statements on such. When you leave our website(s), we encourage you to read the privacy policy of every website you visit.

Transfer of your information out of the EEA

We may transfer your personal information to the following countries which are located outside the European Economic Area (EEA):

United States of America

The IRPM is satisfied that any transfer of your personal data to platforms outside of the EEA has adequate levels of data protection for your personal data, through one of the following safeguards:

we will only transfer personal information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission
where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Your rights

Under the GDPR and DPA you have a number of important rights free of charge.

In summary, those include rights to:

fair processing of information and transparency over how we use your use personal information
access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
require us to correct any mistakes in your information which we hold. Our members are encouraged and invited to log in to their online account and amend their contact information and update it where necessary.
require the erasure of personal information concerning you in certain situations
receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal information concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal information
otherwise, restrict our processing of your personal information in certain circumstances
claim compensation for damages caused by our breach of any data protection laws

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you have any questions about this privacy policy, including a request to exercise any of your rights, please:

Email us at data@irpm.org.uk
let us have enough information to identify you (for example your full name and email address)
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
let us know the information to which your request relates, including any membership number or reference number, if you have them

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.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

Changes to this privacy notice

This privacy notice was published on 25 May 2018 and last updated on 1^st September 2020.

We may change this privacy notice from time to time, and when we do we will inform you.

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