Whenever you provide personal data to the Leaseholder Support Scheme or we collect personal data about you, we will only use it in accordance with this privacy notice. Please read this carefully.
This privacy notice applies to the Leaseholder Support Scheme (the ‘Scheme’), a Scheme which is managed by the Development Bank of Wales subsidiary company DBW Investments (11) Ltd.
Whenever the terms ‘we’, ‘us’, or ‘our’ are used in this notice, it means DBW Investments (11) Ltd. as the Data Controller and the manager of the Leaseholder Support Scheme.
For our full list of privacy documentation click here.
Find out more about our governance structure on our governance page.
Our principles
We take your privacy seriously and are committed to protecting your personal data. This means:
- We will only ask you to provide us with your personal data that is necessary for us to help you in accordance with the Scheme.
- We will hold your personal data securely and responsibly. We use safeguards including electronic encryption, to prevent unauthorised access to your personal data.
- We will only share your personal data with other companies within the DBW Group, with suppliers who perform services on our behalf and as otherwise set out in this notice.
- We will never sell your personal information.
Why we collect and use your personal information
We will collect and use personal data about you for the following reasons:
- In connection with, and for ongoing management of an application to the Scheme.
- Because you would like us to contact you in response to a specific enquiry.
We may contact you by mediums such as post, telephone, email, text messages or other digital methods of communication, including through other methods that may become available in future.
- Ongoing management of any products we have provided to you.
- Meeting our regulatory obligations.
More information about how we use your personal data in connection with each of these purposes can be found below. This website also uses cookies, more details can be found in our cookies policy.
See also gov.wales cookie policy.
1. Using your personal data in connection with, and for ongoing management of an application to the Scheme
Why does the Leaseholder Support Scheme need to use my personal data?
If you are an applicant applying to the Scheme, you will need to provide us with information about you. This is so that we can decide whether you are eligible for support from the Scheme.
If your application is successful and you are determined to be eligible, we will continue to use your personal data as part of our ongoing management of your application as it progresses through the scheme.
If your application is unsuccessful, we will hold your data for 2.5 years, in line with the retention period outlined under the “How long will you keep my data for when I make an application to the Scheme?” heading.
We might also use personal data about you which is provided by others to inform our eligibility decisions. For instance, if you are financially associated with an applicant, then we will need to collect personal data about you both.
What personal data will be collected and processed in association with Leaseholder Support Scheme?
We will collect and process the following types of personal data: Name, Date of Birth, Phone Number, Address, Email Address, Financial Data, and National Identifiers. We will also ask you to provide copies of your identification documents, information about your financial standing and information regarding your property.
What does the Leaseholder Support Scheme do with my personal data?
When you provide your data to us, we will use it to verify your identity, assess your application, and to decide whether you are eligible for support from the Scheme.
If you are determined to be eligible for the scheme, we will use your information to progress your application through the stages of the scheme, including:
- Providing guidance to you on the next steps of the scheme.
- Providing guidance on appointing an Independent Financial Adviser (IFA). If you proceed to this stage of the scheme, once you inform us of your choice of IFA, we will share your details with them for them to contact and advise you.
- Having your property independently valued by a RICS (Royal Institute of Chartered Surveyors) appointed surveyor. If you proceed to this stage of the scheme, we will share your details with the surveyor for them to contact you.
- Liaising with a participating Registered Social Landlord (RSL) or Local Authority (LA) to proceed with purchase of your property. If you proceed to this stage of the scheme, we will share your details with the relevant RSL or LA for the purposes of contacting you and progressing the property transaction.
- Liaising with a legal conveyancer to complete the purchase. If you reach this stage of the scheme, we will share your details with the appropriate conveyancer for them to be able to perform their legal obligations relating to the property transaction.
- Sharing limited amounts of your personal data, such as the address of your property, with the Welsh Government for statistical purposes related to the monitoring of the scheme.
If you provide us with additional information relating to requirements for additional support or adjustments, we will use this information to add notes to your records about any support or adjustments you need (for example using large print when we communicate with you) to ensure it’s easier for you to interact with us.
If you provide us with additional information about your personal circumstances, we will use this information to add notes to your records about your personal circumstances to help us better manage your individual situation.
If you provide us with any special category data in relation to an application you have made, we will process this solely for the purposes of providing additional support and adjustments to applicants who require them, and for the provisions of safeguards for vulnerable applicants. We will not share any special category data you provide to us with other parties.
Where will my data be processed?
Your personal data will be processed within the European Economic Area (“EEA“). We will take precautions (in accordance with relevant guidance by regulatory bodies) to ensure that any transfer of your data outside the UK will be subject to safeguards that protect your privacy rights, and your data will be kept secure at all times.
What is the legal basis for using my data?
Under data protection law, we must have a valid legal basis for collecting and using your personal data. When you apply to the scheme, the following legal bases may apply:
- We have a legitimate interest in processing your application for the purposes of assessing your eligibility for the scheme. We are permitted to use your personal data where it is necessary for our legitimate interests, provided that our interests are not overridden by your own interests. It is also in your legitimate interest to understand your eligibility for the scheme.
- We are subject to various legal obligations and regulatory requirements whenever we consider applications to the scheme. We are permitted to use your personal data where it is necessary in order for us to comply with our legal obligations.
In the event that any information you provide to us comprises of special category personal data, we are permitted to process this data where:
- it is in the substantial public interest to do so (for example, if you disclose health conditions to us, we will use that information to provide additional support or adjustments for you).
- it is for the establishment, exercise, or defence of legal claims.
How long will you keep my data for when I make an application to the Scheme?
If you make an application to the Scheme, we will keep your personal data related to the application you made for 2.5 years following completion of your application to the Scheme.
If your application is unsuccessful or withdrawn, we will retain and destroy your personal data in accordance with our data retention schedule.
We may hold your information for longer where it is necessary to comply with our legal obligations, to exercise legal rights, comply with the Terms and Conditions of the fund or to defend legal claims.
We have a retention period of 2 years in relation to email correspondence. If we need to retain your emails for a period longer than stated, we will do so to either keep to the law, if there are existing claims or complaints that will reasonably require us to keep your information, or for regulatory or technical reasons.
What happens if I do not provide my data to the Leaseholder Support Scheme?
In order for us to consider your application, you must provide information about you, and anyone associated with your application. If you do not provide all of the details we request in the application form, we will be unable to assess your application, and it may result in you not being able to access the Scheme.
2. Using your personal data to respond to your enquiry
Why does the Leaseholder Support Scheme need to use my personal data?
If you contact us for more information, or if you make a general enquiry, we will need to process your personal data in order to respond to you.
What data will be collected and processed in association with an enquiry to the Leaseholder Support Scheme?
We will collect your name, contact details and information relating to your enquiry.
What will we do with your data?
We will use the data to respond to your query.
What is the legal basis for using my data?
Under data protection law, we must have a valid legal basis for collecting and using your personal data. When you make an enquiry about the scheme, the following legal bases may apply:
- We are permitted to use your personal data where it is necessary for our legitimate interests, provided that our interests are not overridden by your own interests. It is in our legitimate interest to be able to provide a high standard of service to both applicants and the wider public, part of which is answering queries.
In the event that any data you provide to us as part of your enquiry comprises of special category personal data, we are permitted to process this data where:
- it is in the substantial public interest to do so (for example, if you disclose health conditions to us, we will use this so we can provide additional support or adjustments for you).
- it is for the establishment, exercise, or defence of legal claims.
How long will you keep my data for when I make an enquiry?
We will hold your personal information for the time it takes to deal with your query. This may include any correspondence you have with us by email or via the 'Contact Us' form on our website.
We will normally delete your personal information after 24 months, unless you would like us to retain your contact details to keep you informed of our products and services.
If we need to retain your personal information for a period longer than stated, we will do so to either keep to the law, if there are existing claims or complaints that will reasonably require us to keep your information, or for regulatory or technical reasons.
Your data protection rights
The personal data you provide to us will be held in accordance with our responsibilities under data protection legislation. This includes the Data Protection Act 2018 and the UK General Data Protection Regulation. These laws contain specific rights for you, including:
- The right to access – You have the right to request copies of your personal data (this is also known as a subject access request).
- The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete information you believe is incomplete.
- The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
- The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
- The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
- The right to data portability – You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
- The right to complain to the regulator - the Information Commissioner's Office, if you are unhappy about how your personal data is being used. The ICO can be contacted at www.ico.org.uk.
- Your rights in relation to automated decision making – You have the right to object to your personal information being used for any automated decision making, including profiling.
If you would like to exercise any of the rights set out above, please email us at dpo@developmentbank.wales or write to us at:
DATA PROTECTION OFFICER
Development Bank of Wales
1 Capital Quarter
Tyndall Street
Cardiff
CF10 4BZ
How to Raise a Concern or Make a Complaint
To the Development Bank of Wales:
If you have any concerns or complaints about our use of your personal information, we would appreciate the chance to resolve your issue in the first instance. You can make a complaint to us at dpo@developmentbank.wales or write to us at the same address as above.
To the Information Commissioner’s Office (ICO):
If you are unhappy with how we have used your personal information, or dealt with your concern or complaint, you can also complain to the UK data protection regulator, the ICO. The ICO can be contacted at www.ico.org.ukor by phone on 0303 123 1113.
