Fieldend Residents Association Ltd
Fieldend Residents Association Limited (FRAL) is a not-for-profit organisation exempt from registering with The Information Commissioner (ICO). However, it is important that FRAL adheres to the principles of the General Data Protection Regulation (GDPR) and adopts best practice for managing information.
Identity and contact details of Controller
FRAL is a controller of personal information for the purposes of the GDPR. Our contact details for data protection purposes are as follows:
Registered Office: 26 Fieldend, Twickenham, Middlesex, TW1 4TF
Purpose of this Privacy Notice
This Privacy Notice tells you what to expect when FRAL processes personal information. It tells you the purposes for which we may process your personal information and the legal basis for the processing (‘processing’ includes us just keeping your personal information).
Why do we collect and store personal information?
FRAL needs to collect, process and store personal information about you and other household members (when you provide information about household members we assume that you do so with their full knowledge and consent) in order to operate as a residents association and deliver efficient and effective services.
Legal basis for processing
Where possible, we will always try to get your consent (i.e. agreement) for processing your personal information. Our residents are asked to sign a data consent form when they move to Fieldend or later if they did not sign one when they first moved in.
Under the GDPR, consent is a legal basis for processing personal information.
Where we can’t get consent, there are other reasons why we can process your personal information under the GDPR:
- Legitimate interests: where it is in our legitimate business interests to process your information we can do that so long as we do not interfere with your fundamental rights or freedoms;
- Where we are under a legal obligation or an obligation under a contract to process/disclose the information;
- Where we need to protect the vital interests (i.e. the health and safety) of you or another person.
Some personal information is treated as more sensitive (for example information about health, religion, ethnic background and others – see footnote below for a full list). We do not collect this information.
Information we may hold about you and how we use it
The information we hold on our records concerns our relationship with you. For example:
- We hold contact details for you so we can communicate with you by your preferred means, and keep you informed about services/events we offer which may be useful to you;
- We keep a record of correspondence between FRAL and residents about matters such as house maintenance, landscape or infrastructure issues, and planning permission applications;
- We keep financial records about the amount of money you have paid us; any amount(s) outstanding and action taken to recover money you owe;
- We may photograph you when recording social events on Fieldend. We will not use these images without your explicit consent;
- We record the findings of surveys and other research to help us improve our service to residents. The information you provide will be anonymous unless you agree that we can use your details.
This list is not exhaustive, as we hold records of most contacts we have with you, or about you, and we process this information so we can deliver services to you.
We will only ask for personal information that is appropriate to enable us to deliver our services.
How we manage your personal information
We process your personal information in accordance with the principles of the General Data Protection Regulation (‘GDPR’).
We will treat your personal information fairly and lawfully and we will ensure that information is:
- Processed for limited purposes;
- Kept up-to-date, accurate, relevant and not excessive;
- Not kept longer than is necessary;
- Kept secure.
Access to personal information is restricted to authorised individuals on a strictly need to know basis.
We are committed to keeping your personal details up to date, and we encourage you to inform us about any changes needed to ensure your details are accurate.
Periods for which we will store your personal information
We will only hold your records during the period of our relationship with you and for a set period afterwards to allow us to meet our legal obligations including resolving any follow up issues between us.
Sharing your personal information
Normally, only FRAL Board members will be able to see and process your personal information. However, there may be times when we will share relevant information with third parties for the purposes as outlined, or where we are legally required to do so. When sharing personal information, we will comply with all aspects of the GDPR.
Where necessary or required, we may share information as follows:
- to comply with the law (e.g. the police, Inland Revenue, Council Tax Registration Officer) or a court order;
- where there is a clear health or safety risk to an individual or members of the public, evidence of fraud against FRAL, other irregular behaviour or a matter FRAL is investigating;
- in connection with court proceedings or statutory action to enforce compliance with the Scheme of Management;
- providing the name, address and contact number of a resident to contractors or other agents providing services on FRAL’s behalf (eg window cleaning, repainting or gardening);
- to protect the vital interests of an individual (in a life or death situation).
Your rights under the GDPR
You have rights under the GDPR:
Access to personal information
Under the GDPR, you have a right to ask us what personal information we hold about you, and to request a copy of your information. This is known as a ‘subject access request’ (SAR). SARs need to be made in writing. We have one calendar month within which to provide you with the information you’ve asked for (although we will try to provide this to you as promptly as possible).
Following your SAR, we will provide you with a copy of the information we hold that relates to you. This will not generally include information that relates to your property such as repair logs or details of contractor visits, as this is not considered personal information.
If you need us to correct any mistakes contained in the information we hold about you, you can let us know by contacting us at FRALbusiness@outlook.com.
Erasure (‘right to be forgotten’)
You have the right to ask us to delete personal information we hold about you. You can do this where:
- the information is no longer necessary in relation to the purpose for which we originally collected/processed it;
- where you withdraw consent;
- where you object to the processing and there is no overriding legitimate interest for us continuing the processing;
- where we unlawfully processed the information;
- the personal information has to be erased in order to comply with a legal obligation;
- we can refuse to erase your personal information where the personal information is processed for the following reasons:
- to enable functions designed to protect the public to be achieved eg government or regulatory functions;
- to comply with a legal obligation;
- archiving purposes for historical research or statistical purposes;
- the exercise or defence of legal claims; or
- where we have an overriding legitimate interest for continuing with the processing.
Restriction on processing
You have the right to require us to stop processing your personal information. When processing is restricted, we are allowed to store the information, but not do anything with it. You can do this where:
- You challenge the accuracy of the information (we must restrict processing until we have verified its accuracy);
- You challenge whether we have a legitimate interest in using the information;
- If the processing is a breach of the GDPR or otherwise unlawful;
- If we no longer need the personal data but you need the information to establish, exercise or defend a legal claim.
If we have disclosed your personal information to third parties, we must inform them about the restriction on processing, unless it is impossible or involves disproportionate effort to do so.
We must inform you when we decide to remove the restriction giving the reasons why.
Objection to processing
You have the right to object to processing where we say it is in our legitimate business interests. We must stop using the information unless we can show there is a compelling legitimate reason for the processing, which override your interests and rights or the processing is necessary for us or someone else to bring or defend legal claims.
Withdrawal of consent
You have the right to withdraw your consent to us processing your information at any time. If the basis on which we are using your personal information is your consent, then we must stop using the information. We can refuse if we can rely on another reason to process the information such as our legitimate interests.
Right to data portability
The right to data portability allows you to obtain and reuse their personal data for your own purposes across different services. It allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way. The right only applies to personal data you have provided to us where the reason we are relying on to use the information is either your consent or for the performance of a contract. It also only applies when processing is carried out by us using automated means.
Changes to this Privacy Notice
We keep our privacy notice under regular review and will place any updates on our website; you will be notified of any major changes to this policy.
For further information on how to request your personal information and how and why we process your information, you can contact us using the details below
26 Fieldend, Twickenham, Middlesex, TW1 4TF
The Information Commissioner (ICO) is also a source of further information about your data protection rights. The ICO is an independent official body, and one of their primary functions is to administer the provisions of the GDPR.
You have the right to complain to the ICO if you think we have breached the GDPR. You can contact the ICO at:
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
030 123 113
 By this we mean the Regulation as supplemented and amended by the Data Protection Act 2018
 Special categories of personal data is defined within the GDPR and covers racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a person's sex life or sexual orientation