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Data Protection Policy

Effective Date: 31 July 2026

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1. Introduction

Marcombe Management Ltd ("Marcombe", "we", "us", or "our") is committed to protecting the personal information we process and ensuring that all personal data is handled securely, lawfully, and responsibly.

This Data Protection Policy sets out how Marcombe collects, uses, stores, shares, and protects personal data in accordance with:

  • The UK General Data Protection Regulation (UK GDPR)

  • The Data Protection Act 2018

  • Other applicable data protection legislation

This policy applies to all employees, contractors, suppliers, and any third parties who process personal data on behalf of Marcombe.

2. Data Protection Principles

Marcombe follows the seven key principles of data protection:

Lawfulness, Fairness and Transparency

Personal data must be processed lawfully, fairly, and transparently. We ensure individuals understand how and why their data is used.

Purpose Limitation

Personal data will only be collected for specific, clear, and legitimate purposes.

Data Minimisation

We only collect information that is necessary for the services we provide.

Accuracy

We take reasonable steps to ensure personal information is accurate and kept up to date.

Storage Limitation

Personal data will not be kept for longer than necessary.

Integrity and Confidentiality

Personal data must be kept secure and protected against unauthorised access, loss, or misuse.

Accountability

Marcombe is responsible for complying with data protection requirements and maintaining appropriate records.

3. Types of Personal Data We Process

As a property management and lettings company, Marcombe may process:

Tenant Information

Including:

  • Full name

  • Contact details

  • Date of birth

  • Identification documents

  • Right to rent information

  • Employment details

  • Income information

  • Referencing information

  • Guarantor details

  • Tenancy agreements

  • Rent payment records

  • Maintenance requests

Landlord Information

Including:

  • Name

  • Contact details

  • Property ownership information

  • Bank details

  • Management agreements

  • Property instructions

  • Financial records

Contractor Information

Including:

  • Names

  • Contact details

  • Qualifications and certifications

  • Insurance information

  • Payment details

  • Work records

Website Users

Including:

  • Enquiry details

  • Contact information

  • Website usage information

  • Cookie and analytics information

4. Responsibilities

Directors and Management

Marcombe's directors are responsible for:

  • Ensuring compliance with data protection laws

  • Implementing appropriate security measures

  • Reviewing this policy regularly

  • Ensuring staff understand their responsibilities

Employees and Contractors

Anyone handling personal data must:

  • Only access information required for their role

  • Keep information confidential

  • Follow security procedures

  • Report any suspected data breach immediately

  • Not share personal information without authorisation

5. Collecting Personal Data

Personal data must only be collected where there is a legitimate business reason.

Information may be collected through:

  • Website enquiries

  • Property applications

  • Tenancy agreements

  • Landlord agreements

  • Maintenance requests

  • Email correspondence

  • Telephone conversations

  • Referencing processes

  • Third-party service providers

Individuals must be informed about how their information will be used.

6. Storage and Security of Data

Marcombe takes appropriate steps to protect personal information, including:

  • Secure password protection

  • Restricted access permissions

  • Secure cloud storage systems

  • Regular software updates

  • Device security measures

  • Secure disposal of documents

  • Staff awareness of phishing and cyber security risks

Physical documents containing personal data must be stored securely and not left unattended.

7. Access to Personal Data

Access to personal information is restricted to authorised individuals who require it to perform their role.

Staff must not:

  • Access information unnecessarily

  • Share passwords

  • Download or copy information without permission

  • Share tenant, landlord, or contractor information outside authorised purposes

8. Sharing Personal Data

Marcombe may share personal data where necessary with:

  • Landlords

  • Tenants

  • Referencing companies

  • Deposit protection schemes

  • Contractors

  • Accountants

  • Solicitors

  • Insurance providers

  • Software providers

  • Government authorities where legally required

Before sharing information, Marcombe will ensure there is a lawful basis and that only relevant information is provided.

9. Data Retention

Personal data will only be retained for as long as necessary.

Typical retention periods include:

  • Tenant records: minimum six years after tenancy ends where required for legal and financial purposes

  • Accounting records: retained according to HMRC requirements

  • Maintenance records: retained as necessary for property management purposes

  • Enquiries: reviewed and deleted when no longer required

When information is no longer required, it will be securely deleted or destroyed.

10. Data Breaches

A data breach may include:

  • Loss of personal information

  • Unauthorised access

  • Accidental disclosure

  • Theft of devices containing personal data

  • Sending information to the wrong recipient

Any suspected breach must be reported immediately to Marcombe management.

Marcombe will:

  1. Assess the nature and severity of the breach

  2. Take steps to contain the issue

  3. Record the breach

  4. Notify affected individuals where required

  5. Notify the Information Commissioner's Office (ICO) where legally necessary

11. Individual Rights

Individuals have rights regarding their personal data, including:

  • The right to access their information

  • The right to request corrections

  • The right to request deletion where applicable

  • The right to restrict processing

  • The right to object to certain processing

  • The right to data portability

Requests should be sent to:

Email: privacy@marcombe.co.uk

Marcombe will respond within the required legal timeframe.

12. Data Processors and Suppliers

Where Marcombe uses third-party services that process personal information, we will ensure:

  • Appropriate agreements are in place

  • Suppliers provide adequate security measures

  • Data is only processed for agreed purposes

  • Access is limited appropriately

Examples may include:

  • Property management software

  • Website hosting providers

  • Referencing providers

  • Accounting software

  • Cloud storage providers

13. Staff Training

Marcombe will ensure that individuals handling personal data understand:

  • Their responsibilities under UK GDPR

  • The importance of confidentiality

  • How to identify security risks

  • How to report incidents

Training will be provided where appropriate.

14. Monitoring and Review

This policy will be reviewed regularly to ensure it remains accurate and compliant with current legislation.

Changes will be made where necessary due to:

  • Legal updates

  • Changes to business processes

  • New technology

  • Security improvements

15. Contact Details

Marcombe Management Ltd

Email: info@marcombe.co.uk

Website: https://marcombe.co.uk

Telephone: 0161 674 0569

Registered Office: Unit 4b, Birch Mill Business Centre, Heywood Old Road, Heywood, Manchester, United Kingdom, OL10 2QQ

Policy Owner: Marcombe Management Ltd
Review Frequency: Annually

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