Data protection notice to tenants of the Akelius Group regarding the processing of personal data
What is personal data? Dealings and communications create records. Some of these records hold information. Personal data is all kind of information that relates to you or members of your household. Processing of personal data includes every measure taken with regard to personal data such as collection, registration, storage, disclosure and compilation.
This General Data Protection Notice (the “Notice”) serves to inform you that entities within the Akelius Group may process personal data relating to you as a tenant of a company within the Akelius Group.
This Notice is not intended to replace other more detailed notices or consents provided by specific entities of the Akelius Group in accordance with local laws and regulations or for specific processing. In the event of any conflict between notices or consents provided as required by local law and this Notice, such notices or consents as required will prevail.Landlord is controller:
The Akelius Group being a Europe based group takes data protection/data privacy seriously. Under European Union law based rules every data controller (the entity that determines the purpose and means of collection, use etc. of personal data) shall provide the individual whose personal data is processed (you) with information about the processing in accordance with detailed requirements set out in law. Also in relation to operations outside Europe the Akelius Group adheres to local laws. Accordingly, this document does not purport to extend your rights but rather to inform you, to the extent required by law, about the processing of your personal data which may be undertaken due to you being a tenant.
The controller of your personal data described herein is the entity with which you have signed a tenancy agreement, (henceforth the “Landlord”), unless otherwise is provided. It is the Landlord as controller that determines the purposes and means of the processing of your personal data.
If you are uncertain what legal entity that is your Landlord, see your tenancy agreement.
Personal data that you provide (or have provided) to your Landlord is personal data which this Notice is intended to cover and information you provide to Landlord may, thus, be processed as further described in this Notice. Such information may include name, date of birth, social security number or other national identification number, address, telephone number, e-mail address, transaction information, including rental payments, deposits, method of payment and amount, where applicable credit card information, information about a guarantor and trustee if applicable, information about occupants other than the tenant such as family members/dependents names, if there are any, category of accommodation and other information requested on an application form or other documents from the Landlord.
Personal data may also be obtained or generated from other sources, in addition to the data you provide directly. Such sources may include: (i) other tenants (due to their communications with the Landlord, for example in relation to reports of disturbance or nuisance caused by a tenant), (ii) external companies providing security services relating to investigation and report of disturbance, (iii) data from security equipment such as CCTV, and access control systems, and (IV) contractors of the Landlord.
Purpose and legal basis for processing (why):
Processing of your personal data is necessary for the Landlord´s business operations, including to provide services to you and to maintain the relationship between the Landlord and you as tenant, and may, thus, occur for the following purposes and reasons:
- for the performance of the Landlord’s tenancy agreement with you (e.g. property management such as refurbishments, security, health and safety and day to day administration, collection of payments);
- to comply with legal obligations which fall upon the Landlord (e.g. communications to welfare services, or duties to provide information on applied rents);
- when necessary for the establishment, exercise or defence of legal claims your personal data may also be processed for such purpose (e.g. to document reports of disturbance or nuisance caused by a tenant so as to ascertain evidence); and
- to the extent not covered by the above, the Landlord may process your personal data when necessary for purposes of legitimate interests pursued by the Landlord (or by a third party) except where such interests are overridden by your interests or your fundamental rights and freedoms (e.g. property management such as transactions of property, providing collateral in future rent payments, security as well as health and safety of the personnel and contractors of the Akelius Group).
For the above described purposes and reasons personal data may be shared with other entities within the Akelius Group in the interest of ensuring efficient, timely and correct processing of information throughout the Akelius Group. This relates solely to the way the Akelius Group is organized and managed from time to time.
For the above described purposes and reasons, not least to provide cost efficient services, as part of the Landlord´s business operations personal data may be shared with the following categories of third parties inside or outside the EU (also outside the Akelius Group):
- with local authorities for processing housing benefit and ensuring that records are kept up to date as required under applicable laws;
- police and local law enforcement, if they request information;
- to utility companies to ensure bills are invoiced to the correct people covering the correct dates;
- to contractors providing refurbishment services and facility management services, property management services or providing IT-services; and
- to companies providing security services or by Landlord assigned to investigate and handle by other tenants reported disturbance and nuisance.
In addition, personal data may also be shared with other entities within the Akelius Group inside or outside the EU. Such data sharing is regulated by suitable internal arrangements, ensuring protection of your rights as a data subject, see further information below.
Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for you and your rights, appropriate technical and organisational measures to ensure a level of security appropriate to the risk shall have been implemented before processing of personal data takes place by the Landlord as well as by entities with which Landlord shares personal data.
Any person acting under the authority of the Landlord, who is granted access to your personal data, shall not process those data except on, and in accordance with, by the Landlord given instructions or unless required to do so by law. The principal rule is access on “a need to know basis”.
Your personal data may be transferred abroad, i.e. outside the country in which the Landlord and the property in which you are a tenant is located, to the categories of third parties within and outside the Akelius Group described above, for the above set out purposes and reasons. Countries to which such data may be transferred are Sweden, Germany, the United Kingdom, Denmark, France, Canada and the USA. According to an EU Commission decision on the adequacy of personal data in third countries, Canada has an adequate level of protection and your personal data may therefore be transferred to Canada without any further safeguard being necessary. As regards the USA, Akelius has taken necessary measures within its intra-group legal structure regarding the processing of personal data, thereby ensuring an adequate level of protection also for personal information transferred to the USA.
For how long:
It is not possible to generally state a period for which personal data will be stored but the criteria used to determine that period are that your personal data shall not be stored for a period longer than necessary for the purposes for which it is processed and accordingly personal data held shall be screened regularly. The Landlord may keep details of the tenancy agreement and related records also after termination of the tenancy agreement, e.g. if necessary to monitor any remaining debts related to the tenancy or as otherwise determined necessary to fulfil purposes for which the personal data has been collected and kept. For example, if a tenancy is terminated because of misbehaviour of the tenant, the Landlord may store information such as name, the lease object, the date when the tenant moved out and a short explanation of the reason for termination of the tenancy not including information about criminal activities.
As determined by applicable law, as a data subject you have the right to request information about how the Landlord processes your personal data. Thereto you have, as determined by applicable law, the right to receive the personal data in order to exercise your right to data portability, i.e. to transmit your personal data to another controller. Such requests shall be in writing, be signed and sent to the Landlord (see contact details below).
You have, as determined by applicable law, the right to request rectification or erasure of personal data or restriction of processing or object to the processing and you can lodge a complaint with a national data protection authority, if the processing of your personal data or rights in relation thereto does not meet the requirements under applicable law. Should you need further information hereabout see further below under “Contact details”.
In case of any questions regarding the processing of your personal data by the Akelius Group, e.g. the purposes of processing of your personal data or information about who may access your data or if you need information about your rights as to the Landlord´s processing of your personal data under applicable law, you can contact Akelius’ Service Center, email@example.com. You can, as an alternative, always contact Akelius’ Group Privacy Officer.
Akelius Group Privacy Officer
P.O Box 104, SE-182 12 Danderyd
E-mail address: firstname.lastname@example.org
Group Privacy Officer: Demetris Syllouris
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