Privacy Policy

1 Background

1.1 "Personal data" are data that can be used to identify you or that we can otherwise link to you using information we may already hold.

1.2 Stanhope plc (“we” or “us") whose registered office is at 2nd Floor, 100 New Oxford Street, London WC1A 1HB collects and uses certain personal data. We are responsible for ensuring that we use that personal data in compliance with data protection laws. We respect your privacy and we are committed to keeping your personal data secure.

1.3 This Privacy Notice is directed to individuals whose personal data we handle in the course of carrying out our commercial activities, principally as a developer, development manager and/or asset manager of properties in England. Those individuals could be our clients or prospective clients, our delivery or service partners such as consultants, contractors and property managers or in each case their representatives, agents or appointees, or tenants at or neighbours to our projects, or an employee, director, officer or other representative of another organisation with which we have a commercial relationship. This Privacy Notice is also directed to visitors to our website and to those applying for jobs or work experience with us. It explains the type of information we collect about those individuals and outlines how we use that information and the individual’s associated rights. Where you are provided with a separate privacy notice by or on our behalf, then that is supplemented by and not overridden by this Privacy Notice.

1.4 Note that where we act on behalf of third parties to manage their development projects or to asset manage their properties, we may be acting as data processor rather than data controller in respect of personal data we hold in relation to those projects, in which case enquiries relating to the processing of your personal data should be directed to the relevant data controller.

2 The type of personal information we collect and why we have it

2.1 We set out below the scenarios where we typically collect personal data/information with an explanation of why we collect the information and who we share it with.

2.2 We do not intend to disclose your personal data other than as described here but note that in all cases we may need to share your personal data with IT, payment and system administration services to enable them to provide their services, in which case we will require those parties to keep that information confidential and secure and to use it solely for the purpose of providing the specified services to us. There may be other circumstances where we need to share personal data such as where we are legally required to disclose the information or disclosure is required to tax or legal authorities or to our auditors or insurers. In some cases, we may be required to transfer your information to countries outside the UK, however, we will ensure that this is done in accordance with data protection laws, including using specific legally approved safeguards where necessary.

3 Where you are an actual or proposed client, agent, consultant, contractor or other service or delivery partner on a project or tenant, occupier or other user of one of the properties we manage or a counterparty on one of our property transactions

3.1 We currently collect and process the following information:

3.1.1 personal identifiers and contact information such as names, residential / corporate addresses or e-mail addresses, contact telephone numbers, your attendance at events and, for companies, details of your directors / shareholders

3.1.2 where necessary for KYC and similar checks, copies of passports or driving licences or other ID documents, copies of documents as proof of address (such as utility bills) and details of national insurance numbers
3.1.3 financial and transaction data such as bank account details and details about payments to and from you.

3.2 We use this data:

3.2.1 to carry out and enable third parties to carry out KYC similar checks on persons/companies we deal with

3.2.2 to comply with our financial reporting requirements or for tax compliance purposes

3.2.3 to send you marketing information

3.2.4 to manage our relationships with you, including in the context of our role in relation to a project. This may involve using your data to contact you, to perform our contractual obligations to you or others (including collecting and processing payments and the administration of your tenancy), managing legal matters and inviting you to meetings, site visits and events.

3.3 We share this information as follows:

3.3.1 we share contact information with our other service/delivery partners on our projects to enable them to perform their services on the project and to enable us to perform our role on the project

3.3.2 we share contact information with our client or joint venture partners, to enable us to report to them and to perform our role on the project

3.3.3 we share contact and financial information with financial institutions, including banks, in order to process payments

3.3.4 we may share your information with our auditors, lawyers, and other professional advisers that owe us a duty of confidentiality to enable them to properly perform the services we have engaged them to provide to us

3.3.5 we don’t typically but we may share KYC information such as ID documents with our clients, joint venture partners, lawyers or auditors as necessary to establish or verify checks we have carried out but not otherwise.

3.4 We typically process this information on the basis of our legitimate interest in:

3.4.1 verifying the identity and creditworthiness of the persons we engage with

3.4.2 engaging with our clients and partners and managing our delivery/service partners and performing our role as an asset / delivery manager including, where relevant, instructing or processing payments

3.5 We may also use this information to contact you about opportunities we think you may be interested in on the basis of our legitimate interests in promoting and building our business. However, if we require your consent for this, we will only do so if we have obtained your consent beforehand. You may withdraw your consent at any time using the contact details below.

3.6 We may also process the information set out above on the basis that it is necessary for us to perform our contract with you or to manage our client’s performance of its contract with you.

4 Where you are a third party with whom we engage or interact with in relation to one of the properties we are developing or asset managing, including if you are a neighbour of one of those properties

4.1 We currently collect and process the following information:

4.1.1 personal identifiers and contact information such as names, residential / corporate addresses or e-mail addresses, contact telephone numbers and, for companies, details of your directors / shareholders and we may record attendance at events, details of your property and other personal information you provide to us

4.1.2 only where necessary for KYC and similar checks, copies of passports or driving licences or other ID documents

4.1.3 only where relevant, financial and transaction data such as bank account details and details about payments to and from you

4.2 We use this data:

4.2.1 to carry out KYC and similar checks on persons/companies we deal with

4.2.2 to carry out / enable consultations with you that we or a delivery partner undertakes on our development projects

4.2.3 to comply with our financial reporting requirements or for tax compliance purposes

4.2.4 to manage our relationship with you, including in the context of our role in relation to a project. This may involve using your data to contact you, to perform our contractual obligations to you or others (including collecting and processing payments), managing legal matters and inviting you to meetings and events.

4.3 We share this information as follows:

4.3.1 we may share the information we collect with local and statutory authorities in order to meet our legal obligations to them

4.3.2 we share contact information with our other service/delivery partners and advisers on our projects to enable them to perform their services on the project and to enable us to perform our role on the project

4.3.3 we share contact information with our client or joint venture partners to enable us to report to them and for us to perform our role on the project

4.3.4 we share contact and financial information with financial institutions, including banks, in order to process payments

4.3.5 we may share your information with our auditors, lawyers, and other professional advisers that owe us a duty of confidentiality to enable them to properly perform the services we have engaged them to provide to us

4.3.6 we don’t typically but we may share KYC information such as ID documents with our clients, joint venture partners, lawyers or auditors as necessary to establish or verify checks we have carried out but not otherwise.

4.4 We typically process this information on the basis of our legitimate interest in:

4.4.1 verifying the identity and creditworthiness of the persons we engage with

4.4.2 wishing to consult with and understand details and interests of our neighbours and other third parties over our projects

4.4.3 engaging with our clients and partners and managing our delivery/service partners and performing our role as an asset / delivery manager including, where relevant, instructing or processing payments.

4.4.4 We may also process the information set out above on the basis that it is necessary for us to perform our contract with you or to manage our client’s performance of its contract with you.

4.4.5 We may also process this information where necessary to comply with our legal obligations. For example, we may be required to process your data to engage in a consultation process with neighbours and other third parties.

5 Where you are involved in the purchase of a residential property where we act as development / asset manager

5.1 We currently collect and process the following information:

5.1.1 personal identifiers and contact information such as names, residential / corporate addresses or e-mail addresses, contact telephone numbers and, for companies, details of your directors / shareholders

5.1.2 other personal details such as age or age range, employment position, your financial position (for example in terms of the property value you are wishing to purchase, whether you are a cash buyer and whether it is a second home or buy to let investment) and details of any property you have purchased from us.

5.2 We use this data:

5.2.1 to enable us to keep a database of interested parties and to send you updates and details relating to requests which you have submitted

5.2.2 send you marketing information on our property developments

5.2.3 to enable us to manage property transactions in which you are involved.

5.3 We share this information as follows:

5.3.1 we share contact information with our other service/delivery partners and advisers on our projects to enable them to perform their services on the project and to enable us to perform our role on the project

5.3.2 we share contact information with our client or joint venture partners to enable us to report to them and for us to perform our role on the project

5.3.3 we may share your information with our auditors, lawyers, and other professional advisers that owe us a duty of confidentiality to enable them to properly perform the services we have engaged them to provide to us.

5.4 We may also use this information to contact you about properties we think you may be interested in on the basis of our legitimate interests in promoting and building our business. However, if we require your consent for this, we will only do so if we have obtained your consent beforehand. You may withdraw your consent at any time using the contact details below.

5.5 We process this information on the basis of our legitimate interest in:

5.5.1 verifying the identity and creditworthiness of the persons we engage with

5.5.2 engaging with our clients and partners and managing our delivery/service partners and performing our role as an asset / delivery manager.

6 Where you are involved in a Stanhope Foundation or other corporate social responsibility event / activity

6.1 We currently collect and process the following information:

6.1.1 personal identifiers and contact information such as names, residential /corporate addresses or e-mail addresses, contact telephone numbers

6.1.2 in relation to our events, we may collect other personal details such as employment position, money raised in relation to charitable events and other information required to organise an event.

6.2 We use this data:

6.2.1 to enable us to keep a list of parties interested in our events and to stay in contact with you

6.2.2 to help us organise relevant events and collect charitable donations

6.2.3 to enable us to record details of and to promote our Stanhope Foundation and other corporate social responsibility events.

6.3 We share this information as follows:

6.3.1 we share relevant personal information to organisers of our events and, where relevant, other participants

6.4 We process this information on the basis of our legitimate interest in:

6.4.1 wishing to keep in contact with current and previous participants and donors with current and future events and charitable opportunities.

7 Where you are applying for a job or work experience

7.1 We currently collect and process the following information:

7.1.1 personal identifiers and contact information such as names, residential / corporate addresses or e-mail addresses, contact telephone numbers

7.1.2 where you or someone on your behalf such as a recruitment agent provides it to us, we will review your CV (and the personal data contained within it) and as part of our recruitment and pre-employment process, we will also review any further information provided to us, including from background check providers and references from former employers.

7.2 We use this data:

7.2.1 to enable us to carry out our recruitment process properly and assess candidates.

7.3 We share this information as follows:

7.3.1 with our background check suppliers to the extent necessary for them to perform their services to us and with former employers providing a reference to the extent necessary for them to identify you and verify information in your CV.

7.4 As you have provided the CV to us, either directly or through a recruitment agency, then you will have consented to us processing the data. Where we process further information as part of our recruitment and pre-employment process, we process this information on the basis of our legitimate interest in recruiting suitable candidates to employ.

8 Where you are a visitor to our website (stanhopeplc.com)

8.1 Depending on your use of our website, we may collect and process the following information:

8.1.1 information that you voluntarily provide us with in interactions with us, such as your name, postal address, email address and contact details

8.1.2 information about your use of our website, such as your IP address and search history

8.1.3 information collected by cookies, please refer to our cookie policy at Stanhope PLC | Cookie Policy which details use of cookies on our website.

8.2 We use this data:

8.2.1 to respond to any queries we receive from you

8.2.2 to test, monitor and analyse and improve the functionality of our website

8.2.3 to provide you with details of services which we believe may be of interest to you.

8.3 We share this information with our service providers that provide services in relation to our website, or as necessary to respond to your request.

8.4 We process this information on the basis of our legitimate interest:

8.4.1 to protect the security and integrity of our systems, manage access and optimise the user experience of visitor to our website

8.4.2 to build and manage relationships with visitors to our website.

8.5 We may also process the information on the basis that it is necessary for us to perform a contract with you.

8.6 Where you visit third party websites in relation to our projects or otherwise, please note that these are outside our control and are not covered by this Privacy Notice. We are not responsible or liable for these websites, their privacy policies or their use of your personal information, and it is your responsibility to read the privacy policies of those websites to understand how they may collect and use information from you.

9 Special categories of personal data

9.1 Some information is classified as "special" personal data under data protection legislation e.g. details about your race or ethnicity, religious beliefs, sexual orientation, and information about your health.

9.2 In very limited circumstances, where you provide it to us through a CV or as part of arranging access arrangements to our premises, we may collect special personal data about you. We will however, only collect or disclosure this special personal data where it is necessary to protect your vital interests.

9.3 If you include any special personal data such as relating to your health when you contact us or within your CV (which we typically do not recommend), it is your responsibility to make sure you are happy for us to use that personal data in accordance with this notice.

9.4 In limited circumstances we may also collect “special” category data in order to ensure your safety and/or comply with health and safety regulations. For example, we may need to process information about your health and medical history if you intend to visit a site or attend an event. This may include any dietary requirements you may have, any adjustments or accessibility requirements you may require, or your height, weight or shoe size, so that we can ensure you are provided with suitable safety equipment.

10 How we get the personal information

10.1 We use different methods to collect data from and about you including through:

10.1.1 direct interactions - you may provide us with personal data by filling in forms or by corresponding with us by post, phone, email or otherwise or by attending our premises or one of our events.

10.1.2 third parties or publicly available sources - we may receive personal data about you from various third parties and public sources such as those set out below:

10.2.1.1 service / delivery partners, consultants, contractors, property managers, clients, joint venture partners, our professional advisors or other third parties involved in our projects

10.2.1.2 information held on Companies House, the Land Registry, electoral roll, websites (such as LinkedIn), social media or other publicly accessible sources.

11 How long we will keep your personal data

11.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

11.2 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 requirements.

12 How we store your personal information

We acknowledge that the information you provide may be confidential and will maintain the confidentiality of and protect your information in accordance with our normal procedures and all applicable laws. We employ appropriate technical and organisational security measures to help protect your personal data against loss and to guard against access by unauthorised persons. We regularly review our security policies and procedures to ensure our systems are secure and protected.

13 Your data protection rights

13.1 Under data protection law, depending on the legal basis under which we are processing your personal data, you have rights including:

13.1.1 your right of access - you have the right to ask us for copies of your personal information

13.1.2 your right to rectification - you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete

13.1.3 your right to erasure - you have the right to ask us to erase your personal information in certain circumstances

13.1.4 your right to restriction of processing - you have the right to ask us to restrict the processing of your personal information in certain circumstances

13.1.5 your right to object to processing - you have the the right to object to the processing of your personal information in certain circumstances

13.1.6 your right to data portability - you have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

13.2 You are not typically required to pay any charge for exercising your rights. If you make a request, we typically have one month to respond to you but it may be longer in more complex cases.

13.3 Please contact us at GDPR@stanhopeplc.com if you wish to make a request.

14 How to complain

14.1 We strive to resolve privacy questions or concerns promptly and effectively. If you have any concerns about our use of your personal information, you can make a complaint to us at GDPR@stanhopeplc.com.

14.2 You can also complain to the ICO if you are unhappy with how we have used your data.

14.3 The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

14.4 Helpline number: 0303 123 1113

14.5 ICO website: https://www.ico.org.uk

15 Revisions to this notice

15.1 We may change this Privacy Notice from time to time by updating this page. You should check this page from time to time to ensure you are happy with any changes.

November 2023