1. Purpose & Scope of Notice
This data protection notice (“Notice“) is intended to explain how your Personal Data will be handled by Inspex Limited (the “Company“, “we“, “us“) and sets out the information including the personal information detailed below relating to you (“Personal Data“) that will be collected and processed by the Company in the context of your engagement with us as:
- a tenant residing in a property subject to a private rented sector inspection (“PRS Inspection“) commissioned by your local authority, approved housing body, letting agent and/or landlord and you have provided your Personal Data directly to us or
- a property buyer commissioning an Inspex Condition Survey from us
Please note, in certain instances, we may process your Personal Data as a processor acting for and on behalf of the local authority, approved housing body, letting agent and/or landlord who has commissioned your PRS Inspection. In such circumstances, the body who commissioned your PRS Inspection will be the controller of your Personal Data and you should consult their data protection notice to find out how your Personal Data are processed.
For the purposes of this Notice, the controller of your Personal Data is Inspex Limited (company number 517920) with an address at S24, The Pottery, Bakers Point, Pottery Road, Dun Laoghaire, Co Dublin A96 C82Y. If you have questions about this Notice, you can contact us at email@example.com/ Data Protection Officer Inspex Ltd. S24 The Pottery Bakers Point Pottery Road Dun Laoghaire Dublin A96 C82Y
2. Your Personal Data Collected & Obtained
IMPORTANT: Please note that the below list of Personal Data we may collect about you, while intended to be as complete and accurate as reasonably possible, is not exhaustive and may be updated from time to time in accordance with section 8 of this Notice. We may collect and process some or all of the following Personal Data directly from you:
|Information you give us||You may give us information about you by filling in forms, engaging with our inspectors, or by corresponding with us (for example, by e-mail or phone). |
The information you give us may include your name, address (including proof of identification and proof of address), e-mail address, phone number, signature, and rental history.
|Information the Company collects or generates||This may include information relating to the inspection of your property, and may include your name, address (including proof of identity and address), email address, phone number, signature, rental history, photographs of the property, sketches created by the Company’s inspectors and video or sound recordings taken at the property.|
We may receive the following Personal Data about you from third party sources and we have set out below where this Personal Data may be obtained from.
|Categories of Personal Data||Source|
|The information provided to us may include your name, address (including proof of identification and proof of address), e-mail address, phone number, rental history, information regarding your receipt of government supports (e.g. the Housing Assistance Payment or the Rental Accommodation Scheme) and details of your property.||We may receive this Personal Data from your: |
approved housing body
housing association or co-operative
3. How & Why We Process Your Personal Data
This section details the legal bases on and purposes for which we collect and process your Personal Data:
- entering into or performance of a contract: it is necessary for us to process your Personal Data in order to enter into and perform our contract with you. For example, where you enter into a contract with us as a homebuyer to conduct an Inspex Condition Survey of your property;
- consent: we process Personal Data where you have freely and voluntarily consented for us to do so. For example, as part of a PRS Inspection, where you voluntarily provide us with Personal Data about a health-related complaint (e.g. a trip and fall experienced at the property). You may withdraw consent for us to process your Personal Data at any time however any processing carried out before you withdraw your consent will remain valid;
- compliance with a legal obligation: it is necessary for us to process your Personal Data in order to comply with health and safety legislation and other legal obligations to which we are subject under Irish and EU law;
- legitimate interest: it is necessary for us to process your Personal Data for our legitimate business interests, including, but not limited to contacting you to arrange a PRS Inspection or Inspex Condition Survey, obtaining details from you as to your residency in the property, rental history etc. You have a right to object at any time to the processing of your Personal Data where the processing is pursuant to our legitimate interests. When we process your Personal Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law); and
- legal claims: it may be necessary for us to process your Personal Data to establish, investigate, exercise, or defend a legal claim.
4. Disclosure of Personal Data
We may disclose some or all of your Personal Data to the following parties:
- your local authority, approved housing body or housing association or co-operative
- your letting agent or landlord
- health, housing, and other public sector bodies including the Department of Housing, Local Government and Heritage and Residential Tenancies Board
- our service providers such as legal advisors, consultants, and accountants
- third parties in connection with the sale or purchase of the Company or assets owned by the Company
- members and shareholders of the Company and internal business units of the Company
We may also disclose or share your Personal Data with other third parties such as An Garda Síochána where we are under a legal or regulatory obligation or it is in our legitimate interests to do so.
5. Transfer of Personal Data
We may transfer your Personal Data outside the European Economic Area (“EEA“). Certain recipients, for example, some of our third-party service providers, may process your Personal Data outside the EEA to a country that does not provide an adequate level of protection to your Personal Data. Where such transfers occur, it is our policy that: (a) they do not occur without our prior written authority; and (b) that an appropriate transfer agreement such as the Model Clause Contracts or other approved transfer mechanisms approved by the European Commission and supervisory authorities (such as the Data Protection Commission) put in place to protect your Personal Data. If you would like to find out more about any such transfers, please contact us on the details set out in section 8 of this Notice.
6. Retention of Personal Data
In general, we expect to keep your Personal Data for a reasonable period after the inspection of your property in line with our contractual and legal obligations. Once we have determined that we no longer need to hold your Personal Data, we will delete it from our systems.
Please note that in certain circumstances, we may hold your data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably, in our view, expect or require us to preserve your Personal Data.
7. Your Rights
You have a number of rights in relation to your Personal Data, which are set out below. Please note that in certain circumstances these rights may not be absolute. You have the:
- right of access: you are entitled to receive a copy of your Personal Data which we hold. We will only charge you for such a request where we feel your request is manifestly unfounded or excessive.
- right to rectification: you can request that we amend any inaccurate Personal Data that we have about you;
- right to erasure: you can request us to erase the Personal Data we hold about you in certain circumstances;
- right to restriction of processing: you can request that we restrict our processing of your Personal Data in certain circumstances;
- right to data portability: you can request your Personal Data be provided to you in a structured, commonly used, and machine-readable format and have your Personal Data transmitted to another controller in certain circumstances where it is technically feasible; and
- right to object: you can object at any time where we process your Personal Data on the legal basis of our legitimate interests or where we make a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you
- You can exercise any of these rights by submitting a request using the contact details set out in section 8 of this Notice.
We will provide you with information on any action taken upon your request in relation to any of these rights without undue delay and at the latest within one month of receiving your request. We may extend this up to 2 months if necessary, however we will inform you if this arises. Please note that we may ask you to verify your identity when you seek to exercise any of your data protection rights.
You also have the right to lodge a complaint with the Data Protection Commission. For further information see www.dataprotection.ie.
8. Changes to this Privacy Notice & Questions
We may amend this Notice on occasion, in whole or part, at our sole discretion. Any changes will be effective immediately upon communicating the revised Notice to you.
If at any time we decide to use your Personal Data in a manner significantly different from that stated in this Notice, or otherwise disclosed to you at the time it was collected, we will notify you and you will have a choice as to whether or not we use your Personal Data in the new manner.
If you have any questions, comments, or concerns about the way your Personal Data are being used or processed by the Company, please contact firstname.lastname@example.org/ Data Protection Officer Inspex Ltd. S24 The Pottery Bakers Point Pottery Road Dun Laoghaire Dublin A96 C82Y.