Seneca Property Investments Limited (“Seneca”) will hold any personal information provided to it in confidence and in accordance with The Data Protection Act 2018 (DPA 2018), The UK General Data Protection Regulation (UK GDPR) and other applicable data protection legislation.

Seneca is registered with the Information Commissioner as a Data Controller under registration number ZA565356.

What is personal data?

Personal data is any information relating to an identifiable person, who can be directly or indirectly identified by reference to such data. Such information includes, name, email address, mailing address.

Seneca will ensure the lawful processing of your personal data.

In this notice, we explain;

•  the types of information we collect about you;
• how we collect and use this information;
• who we might share this information with;
•  the steps we’ll take to make sure your personal data remains private and secure; and
• your rights to access the information we hold about you.

More information

If you have any questions on this policy, you can call us on 01942 295 987, email us at info@senecaproperty.com or write to us at 9 The Parks, Haydock, WA12 0JQ.

Who we are

Under DPA 2018, Seneca is the data controller and processor of personal data for the purposes of its respective business. The data controller is responsible for deciding how your information is used and ensuring it is private and secure.

The information we collect

We collect information about you from different places including:

• directly from you;
• from a third party acting on your behalf (e.g. an adviser or intermediary);
• from publicly available sources; and
•  from other organisations.

We will only collect your personal data in accordance with relevant regulations and law. This may relate to any of our products or services you apply for, currently hold or have held in the past.

You are responsible for making sure you give us accurate and up to date information.

If you provide another person’s information so that they can act on your behalf or access your account with us, please tell them how to find this Privacy Notice and make sure they agree to us using their information for the purposes set out in it.

How we will use your personal data

We will use your personal data to provide any products and services that you have requested. In addition, we may use if for other purposes, such as:

• to confirm your identity and address;
• to carry out your instructions;
• to help us make any appropriate anti-financial crime checks;
•  to improve our products and services; and
• to offer you other services we believe may benefit you unless you ask us not to.

We will only use your personal data where we are allowed to by law. This may include carrying out an agreement we have with you, fulfilling a legal obligation, where we have a legitimate business interest or where you explicitly agree to us doing so.

Who we can share your personal data with

We may share your personal with certain third parties who work for us but only where it is appropriate to do so. This may include lawyers, receiving agent, subcontractors, agents, or service providers. We may also share your information with other companies and agencies e.g. with other Seneca branded companies (but only where it is appropriate to do so), statutory bodies, insurers, brokers and agents, as well as (if appropriate) fraud prevention agencies.

How long we’ll keep your information

We will keep your personal data for as long as you have a relationship with us. After the relationship ends, we will only keep it where we may need it for our legitimate purposes e.g. to help us respond to queries or complaints, or for other reasons e.g. fighting fraud and financial crime, and responding to requests from any appropriate statutory bodies.

Transferring your information overseas

Your information may be transferred and stored in countries outside the European Economic Area (EEA), including some that may not have laws that provide the same level of protection for personal information. When we do this, we’ll ensure it has an appropriate level of protection.

Your rights

You have a number of rights relating to the personal data we hold. Should you wish to use any of these rights then please contact us using the contact details below. Please note that some of these rights are not strictly automatic and we do have the right to consider any request made. In ordinary circumstances we should respond to any request within 30 days of receipt of a request.

Your rights as per UK GDPR are as follows:

• Right to be informed
  This privacy notice confirms how we collect and use data.
• Right to access
  You can request a copy of the personal data that we hold about you via a ‘Data Subject Access Request’. If you do, we will respond within one month. Our response is normally free of charge although we may charge a reasonable fee if the request is excessive.
• Right to rectification
  We make every effort to hold accurate data about you. Should you be aware that the information we hold is incorrect, please inform us and we will correct our records, normally within one month.
• Right to erasure
  You have the right to request that we erase your personal information. We will do so as long as we no longer have a lawful basis for processing your information.
• Right to restrict
  You can request that we do not process your information in a certain way either in full or in part.
• Right to object
  If you do not believe that we have a legitimate interest to process your personal data, you have the right to object to this processing. Any and all requests will be fully reviewed by our Data Protection Team and responded to with appropriate actions taken within one month of the objection.
• Right to data portability
  In limited circumstances you have the right for us to provide you with your data in a format that can be moved to another computer.  This right only applies to information that you have provided to us which we are processing with your consent or to deliver a contract.  It also only applies to information which is processed electronically.
• Right in respect of automated processes
  If a decision is made as a consequence of an automated process, then you have certain rights. Such rights would include the right to request the decision be reconsidered. At present Seneca does not use automated processes exclusively to make decisions and consequently such rights are not applicable.  However, should you believe that we have made a decision based exclusively on an automated process then please contact us and we will review.

Please note we will only seek to obtain sufficient information to allow us to carry out some or all of the activities listed in the “How we will use your data” section. However, you are free to consider our use of your personal data and make a request to apply one or more of the rights specified in this section.

As stated above we can consider and refuse requests in certain circumstances. Please note that under UK GDPR we are not required to consider all potential consequences of processing a request. For example, your request to restrict the use of your information may result in us being unable to provide you with a service you have sought. Therefore, we would suggest that you consider all consequences of asserting a right and we would be more than happy to discuss any concerns that you may have.

Nothing in this policy should be construed as seeking to limit or remove your statutory rights. Should you have any concerns in this regard please seek appropriate independent legal advice.

Changes to this Notice

This notice may be updated in light of any changes in legislation. If we change our privacy policy we will post the changes on this page and may place notices on other pages of the Website, so that you may be aware of the information we collect and how we use it at all times. Continued use of the service will signify that you agree to any such changes.

Any Concerns or requests

If you have any queries, wish to exert a right or alternatively wish to make a complaint, please contact the Data Protection Team at:

Address: Seneca Property Investments Limited, 9 The Parks, Haydock, WA12 0JQ

Tel: 01942 295 987

Email: info@senecaproperty.com

Right to escalate any complaint to the Information Commissioner

If you are dissatisfied with our use or management of your personal data, you have the right to complain to the Information Commissioner’s Office (ICO). You can contact them via their website: www.ico.org.uk.

Seneca Property Privacy Notice in respect of CCTV

Seneca Property Investments Limited and its related Seneca branded companies (together “Seneca”) are committed to protecting and respecting the privacy of our employees, tenants, contractors and the general public.

Seneca owns and/or manages many commercial property sites across the United Kingdom. At several of these sites Seneca operates closed circuit television systems (“CCTV”) using a combination of external and internal cameras located at strategic points.

This notice explains how we regulate the management, operation and use of the CCTV at all relevant Seneca sites.

The CCTV is linked to a dedicated system. Access to this system is restricted to the Centre Manager at the relevant site and authorised Employees at Seneca’s Head Office. The CCTV relating to any particular site can be accessed at that site. All of the CCTV systems can be accessed at Seneca’s Head Office located at 9 The Parks, Haydock, WA12 0JQ.

This notice should be read in conjunction with our General Privacy Notice which can be viewed at https://senecaproperty.com/privacy-notice/

Objectives of the CCTV Notice

The objectives of the use of CCTV are:

• To help protect Seneca’s employees, buildings and equipment
• To help protect the employees and equipment of Seneca’s tenants.
• To support the Police in a bid to deter and detect crime
• To assist in identifying, apprehending and potentially prosecuting offenders
• To assist in investigation on health and safety related matters

Statement of intent

Seneca is registered with the Information Commissioner’s Office (“ICO”) under the terms of the UK GDPR. Seneca will comply with the Data Protection Act 2018 (“DPA”) and any other equivalent laws.

It is noted that the Surveillance Commissioner’s Code of Practice (“Code”) does not directly apply to Seneca. However, Seneca recognises that the Code is good practice which complements Seneca’s obligations under the DPA. Seneca will therefore look to follow the Code as appropriate.

Seneca will treat all information, documents and recordings obtained from CCTV which relate to a identified or identifiable person as data protected by the DPA.

Cameras will be used to monitor activities within the sites near the Entrances, Exits, Car Parks and at other relevant locations to identify adverse activity that is either occurring, anticipated or perceived.

Cameras are positioned to ensure they do not focus on private homes, gardens and other areas of private property. Seneca does recognise that depending on the location of the camera, private property may inadvertently be captured within the wider frame. However Seneca will use best endeavours to minimise such recordings.

At no time will a camera be directed to follow or track any one individual unless such action would achieve the objectives listed above.

Images will only be released for specific legitimate purposes including:

• Use in the investigation of a specific crime and with the written authority of the police
• Use in the investigation of a health and safety incident
• Use in a complaint or grievance procedure

Images will never be released to the media or any other third party for purposes of entertainment.

Seneca have endeavoured to ensure that the CCTV will give maximum effectiveness and efficiency within available means. Nevertheless, it is not possible to guarantee that the system will cover or detect every single incident taking place in the areas of coverage.

Warning signs and/or other appropriate notices have been placed at relevant access routes to areas covered by the office’s CCTV system.

Operation of the System

The CCTV system at each site will be administered and managed by Seneca in accordance with the values and objectives expressed in the Code. The day-to-day management of an individual CCTV system will be the delegated responsibility of the Centre Manager at the relevant site.

The CCTV system at each site will generally operate 24 hours each day, every day of the year, recording all activity. Nevertheless, there may be occasions in which individual cameras, or the CCTV as a whole may not be in operation. This will generally be when it is being serviced or incurs a fault. Nevertheless, Seneca has sole discretion to disable cameras within the CCTV system either temporarily or permanently.

Control and Liaison

The Centre Manager at the relevant site will periodically check and confirm that the CCTV at their site is acting as expected. Any faults will be reported to a member of staff at Seneca’s Head Office who will take appropriate action.

Should any third party have any concerns over the use of the CCTV then enquiries should be addressed to the Data Protection team using the following details.

Address: Seneca Property Investments Limited, 9 The Parks, Haydock, WA12 0JQ

Tel: 01942 295 987
Email: info@senecaproperty.com

Monitoring procedures

Save for any fault or maintenance then the CCTV system will be operational at all times and footage is recorded on an ongoing basis. Up to [x] days of footage is held on the system memory. Seneca offers no guarantees or warranties that footage will be retained for this period. Consequently, should any third party seek access then they should make a request at the earliest opportunity.

To maintain and preserve the integrity of any DVD or other storage medium used to store data from the hard drive and the facility to use them in any future proceedings, the following procedures for their use and retention will be strictly adhered to:

(a) Each storage medium must be identified by a unique reference number

(b) Before using, each storage medium should be reviewed and any previous recording be removed.

(c) An authorised employee at Seneca’s Head Office will be made responsible for each particular recording and will register the date and time of the recording, including the storage reference number and the type of storage medium.

(d) Where recordings are to be recorded on digital storage medium such as the cloud then appropriate safeguards should be placed to limit access.

(e) Each storage medium required for evidential purposes must be sealed, witnessed, signed by the appropriate officer, dated and stored securely in a safe. Images may be viewed by the Police for the prevention and detection of crime. A record will be maintained of any storage medium released to the Police or other authorised applicants. A register will be maintained for this purpose.

(f) Where recordings are requested under a data subjects right to access, then such recordings will be reviewed to ensure that no other data subjects rights are infringed. If it is impossible to answer the right to access without infringing another data subjects’ rights then we will work with the requestor to look to comply with the request.

Viewing of footage by the Police or any external individual must be recorded in writing and entered in the register. Requests by the Police can only be accepted in line with the appropriate legislation.

Images will only be released to the Police or any other third party on the clear understanding that the storage medium remains the property of Seneca, and both it and images on it are to be treated in accordance relevant legislation and guidelines. This retention of property title will also give Seneca the right to refuse permission for the Police or any third party to pass either the recording or any images to any third party.

The Police may require Seneca to retain any stored storage medium/images for possible use as evidence in the future. Such storage medium/images will be properly indexed and securely stored until the Police need them.

Applications received from third parties to view or release footage stored on storage mediums will be referred to the Facilities Department at Seneca’s Head Office. A Manager within the Facilities Department will consider such request and provide storage mediums/Images in respect to a valid subject access request or where satisfactory documentary evidence is produced showing that they are required for legal proceedings.

Lawfulness of Processing

We process CCTV footage as to comply with our legal obligations with regards to Health and Safety as well as our Legitimate Interests in ensuring the safety and security of staff, visitors, plant and equipment.

Review of this Notice

We keep this notice under review. This Notice was last updated in February 2025.