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Onest Property Management Ltd customer privacy notice

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This privacy notice tells you what to expect us to do with your personal information.

  • Contact details

  • What information we collect, use, and why

  • Lawful bases and data protection rights

  • Where we get personal information from

  • How long we keep information

  • Who we share information with

  • How to complain

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Contact details

 

Post

Onest Property Management Ltd, 71-75 Shelton Street, London, WC2H 9JQ, GB

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Email

admin@onestpropertymanagement.co.uk

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What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

  • Names and contact details

  • Addresses

  • Gender

  • Payment details (including card or bank information for transfers and direct debits)

  • Transaction data (including details about payments to and from you and details of products and services you have purchased)

  • Usage data (including information about how you interact with and use our website, products and services)

  • Special requests, preferences for room setup

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We collect or use the following personal information for the operation of client or customer accounts:

  • Names and contact details

  • Addresses

  • Purchase or service history

  • Account information, including registration details

  • Information used for security purposes

  • Marketing preferences

  • Technical data, including information about browser and operating systems

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We collect or use the following personal information for information updates or marketing purposes:

  • Names and contact details

  • Addresses

  • Profile information

  • Marketing preferences

  • Purchase or account history

  • Website and app user journey information

  • IP addresses

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We collect or use the following personal information to comply with legal requirements:

  • Name

  • Contact information

  • Identification documents

  • Client account information

  • Any other personal information required to comply with legal obligations

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We collect or use the following personal information to protect client welfare:

  • Names and contact information

  • Client account information

  • Emergency contact details

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We collect or use the following personal information for dealing with queries, complaints or claims:

  • Names and contact details

  • Addresses

  • Payment details

  • Account information

  • Purchase or service history

  • Photographs

  • Customer or client accounts and records

  • Information relating to health and safety (including incident investigation details and reports and accident book records)

  • Correspondence

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Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

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Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

  • Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.

  • Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.

  • Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.

  • Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.

  • Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.

  • 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. Read more about the right to data portability.

  • Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

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If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

 

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

    • The processing of personal information is legitimate because it enables us to operate our serviced accommodation business effectively, securely, and in line with legal and industry standards. We collect and use guests’ personal data — such as names, contact details, payment information, booking history, and identity verification documents — to manage reservations, confirm identities, process payments, ensure safety, and provide a professional and reliable service to all guests. This processing is necessary to: Manage and confirm bookings; Communicate essential information such as check-in instructions and safety procedures; Verify the identity of guests to prevent fraud and ensure the security of both guests and property; Process payments and meet financial or insurance obligations; Comply with health, safety, and record-keeping requirements; and Provide relevant updates or marketing information about our services where guests have a reasonable expectation of receiving them. Without processing this data, we would be unable to provide accommodation, meet contractual or legal obligations, or ensure the safety and security of our properties and guests. There are no less intrusive methods to achieve these aims. CCTV Monitoring In some of our properties, CCTV cameras are used in communal or external areas for the legitimate purpose of ensuring guest and property security, deterring crime, and protecting staff and visitors. Cameras are positioned only where necessary and do not monitor private areas such as bedrooms or bathrooms. Footage is securely stored for a limited period and only accessed when needed for security or legal purposes. Balancing Test – Benefits vs. Risks The benefits of this processing include: Maintaining a safe and secure environment for guests, staff, and property; Preventing and investigating incidents such as theft, vandalism, or unauthorised access; Delivering a smooth and professional booking experience; Allowing for effective communication before, during, and after stays; and Sharing relevant service updates or offers that guests may reasonably expect as part of their customer relationship. We recognise that processing personal information and using CCTV may present some privacy risks. To minimise these, we: Limit the amount of personal data collected and only keep it for as long as necessary; Protect data through encryption, secure systems, and restricted staff access; Clearly inform guests about data use through our privacy notice and signage where CCTV operates; and Provide simple ways for individuals to access, correct, or object to the processing of their data. With these safeguards in place, the potential impact on individuals’ privacy is limited and proportionate. The benefits — including guest safety, fraud prevention, and high-quality service delivery — clearly outweigh any minimal risks. We believe the processing represents a fair balance between our business needs and guests’ rights and expectations.

 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

  • Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

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Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

    • The processing of personal information is legitimate because it enables us to operate our serviced accommodation business effectively, securely, and in line with legal and industry standards. We collect and use guests’ personal data — such as names, contact details, payment information, booking history, and identity verification documents — to manage reservations, confirm identities, process payments, ensure safety, and provide a professional and reliable service to all guests. This processing is necessary to: Manage and confirm bookings; Communicate essential information such as check-in instructions and safety procedures; Verify the identity of guests to prevent fraud and ensure the security of both guests and property; Process payments and meet financial or insurance obligations; Comply with health, safety, and record-keeping requirements; and Provide relevant updates or marketing information about our services where guests have a reasonable expectation of receiving them. Without processing this data, we would be unable to provide accommodation, meet contractual or legal obligations, or ensure the safety and security of our properties and guests. There are no less intrusive methods to achieve these aims. CCTV Monitoring In some of our properties, CCTV cameras are used in communal or external areas for the legitimate purpose of ensuring guest and property security, deterring crime, and protecting staff and visitors. Cameras are positioned only where necessary and do not monitor private areas such as bedrooms or bathrooms. Footage is securely stored for a limited period and only accessed when needed for security or legal purposes. Balancing Test – Benefits vs. Risks The benefits of this processing include: Maintaining a safe and secure environment for guests, staff, and property; Preventing and investigating incidents such as theft, vandalism, or unauthorised access; Delivering a smooth and professional booking experience; Allowing for effective communication before, during, and after stays; and Sharing relevant service updates or offers that guests may reasonably expect as part of their customer relationship. We recognise that processing personal information and using CCTV may present some privacy risks. To minimise these, we: Limit the amount of personal data collected and only keep it for as long as necessary; Protect data through encryption, secure systems, and restricted staff access; Clearly inform guests about data use through our privacy notice and signage where CCTV operates; and Provide simple ways for individuals to access, correct, or object to the processing of their data. With these safeguards in place, the potential impact on individuals’ privacy is limited and proportionate. The benefits — including guest safety, fraud prevention, and high-quality service delivery — clearly outweigh any minimal risks. We believe the processing represents a fair balance between our business needs and guests’ rights and expectations.

 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

  • Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

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Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

    • The processing of personal information is legitimate because it enables us to operate our serviced accommodation business effectively, securely, and in line with legal and industry standards. We collect and use guests’ personal data — such as names, contact details, payment information, booking history, and identity verification documents — to manage reservations, confirm identities, process payments, ensure safety, and provide a professional and reliable service to all guests. This processing is necessary to: Manage and confirm bookings; Communicate essential information such as check-in instructions and safety procedures; Verify the identity of guests to prevent fraud and ensure the security of both guests and property; Process payments and meet financial or insurance obligations; Comply with health, safety, and record-keeping requirements; and Provide relevant updates or marketing information about our services where guests have a reasonable expectation of receiving them. Without processing this data, we would be unable to provide accommodation, meet contractual or legal obligations, or ensure the safety and security of our properties and guests. There are no less intrusive methods to achieve these aims. CCTV Monitoring In some of our properties, CCTV cameras are used in communal or external areas for the legitimate purpose of ensuring guest and property security, deterring crime, and protecting staff and visitors. Cameras are positioned only where necessary and do not monitor private areas such as bedrooms or bathrooms. Footage is securely stored for a limited period and only accessed when needed for security or legal purposes. Balancing Test – Benefits vs. Risks The benefits of this processing include: Maintaining a safe and secure environment for guests, staff, and property; Preventing and investigating incidents such as theft, vandalism, or unauthorised access; Delivering a smooth and professional booking experience; Allowing for effective communication before, during, and after stays; and Sharing relevant service updates or offers that guests may reasonably expect as part of their customer relationship. We recognise that processing personal information and using CCTV may present some privacy risks. To minimise these, we: Limit the amount of personal data collected and only keep it for as long as necessary; Protect data through encryption, secure systems, and restricted staff access; Clearly inform guests about data use through our privacy notice and signage where CCTV operates; and Provide simple ways for individuals to access, correct, or object to the processing of their data. With these safeguards in place, the potential impact on individuals’ privacy is limited and proportionate. The benefits — including guest safety, fraud prevention, and high-quality service delivery — clearly outweigh any minimal risks. We believe the processing represents a fair balance between our business needs and guests’ rights and expectations.

 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

  • Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

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Our lawful bases for collecting or using personal information to comply with legal requirements:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

    • The processing of personal information is legitimate because it enables us to operate our serviced accommodation business effectively, securely, and in line with legal and industry standards. We collect and use guests’ personal data — such as names, contact details, payment information, booking history, and identity verification documents — to manage reservations, confirm identities, process payments, ensure safety, and provide a professional and reliable service to all guests. This processing is necessary to: Manage and confirm bookings; Communicate essential information such as check-in instructions and safety procedures; Verify the identity of guests to prevent fraud and ensure the security of both guests and property; Process payments and meet financial or insurance obligations; Comply with health, safety, and record-keeping requirements; and Provide relevant updates or marketing information about our services where guests have a reasonable expectation of receiving them. Without processing this data, we would be unable to provide accommodation, meet contractual or legal obligations, or ensure the safety and security of our properties and guests. There are no less intrusive methods to achieve these aims. CCTV Monitoring In some of our properties, CCTV cameras are used in communal or external areas for the legitimate purpose of ensuring guest and property security, deterring crime, and protecting staff and visitors. Cameras are positioned only where necessary and do not monitor private areas such as bedrooms or bathrooms. Footage is securely stored for a limited period and only accessed when needed for security or legal purposes. Balancing Test – Benefits vs. Risks The benefits of this processing include: Maintaining a safe and secure environment for guests, staff, and property; Preventing and investigating incidents such as theft, vandalism, or unauthorised access; Delivering a smooth and professional booking experience; Allowing for effective communication before, during, and after stays; and Sharing relevant service updates or offers that guests may reasonably expect as part of their customer relationship. We recognise that processing personal information and using CCTV may present some privacy risks. To minimise these, we: Limit the amount of personal data collected and only keep it for as long as necessary; Protect data through encryption, secure systems, and restricted staff access; Clearly inform guests about data use through our privacy notice and signage where CCTV operates; and Provide simple ways for individuals to access, correct, or object to the processing of their data. With these safeguards in place, the potential impact on individuals’ privacy is limited and proportionate. The benefits — including guest safety, fraud prevention, and high-quality service delivery — clearly outweigh any minimal risks. We believe the processing represents a fair balance between our business needs and guests’ rights and expectations.

 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

  • Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

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Our lawful bases for collecting or using personal information to protect client welfare are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

    • The processing of personal information is legitimate because it enables us to operate our serviced accommodation business effectively, securely, and in line with legal and industry standards. We collect and use guests’ personal data — such as names, contact details, payment information, booking history, and identity verification documents — to manage reservations, confirm identities, process payments, ensure safety, and provide a professional and reliable service to all guests. This processing is necessary to: Manage and confirm bookings; Communicate essential information such as check-in instructions and safety procedures; Verify the identity of guests to prevent fraud and ensure the security of both guests and property; Process payments and meet financial or insurance obligations; Comply with health, safety, and record-keeping requirements; and Provide relevant updates or marketing information about our services where guests have a reasonable expectation of receiving them. Without processing this data, we would be unable to provide accommodation, meet contractual or legal obligations, or ensure the safety and security of our properties and guests. There are no less intrusive methods to achieve these aims. CCTV Monitoring In some of our properties, CCTV cameras are used in communal or external areas for the legitimate purpose of ensuring guest and property security, deterring crime, and protecting staff and visitors. Cameras are positioned only where necessary and do not monitor private areas such as bedrooms or bathrooms. Footage is securely stored for a limited period and only accessed when needed for security or legal purposes. Balancing Test – Benefits vs. Risks The benefits of this processing include: Maintaining a safe and secure environment for guests, staff, and property; Preventing and investigating incidents such as theft, vandalism, or unauthorised access; Delivering a smooth and professional booking experience; Allowing for effective communication before, during, and after stays; and Sharing relevant service updates or offers that guests may reasonably expect as part of their customer relationship. We recognise that processing personal information and using CCTV may present some privacy risks. To minimise these, we: Limit the amount of personal data collected and only keep it for as long as necessary; Protect data through encryption, secure systems, and restricted staff access; Clearly inform guests about data use through our privacy notice and signage where CCTV operates; and Provide simple ways for individuals to access, correct, or object to the processing of their data. With these safeguards in place, the potential impact on individuals’ privacy is limited and proportionate. The benefits — including guest safety, fraud prevention, and high-quality service delivery — clearly outweigh any minimal risks. We believe the processing represents a fair balance between our business needs and guests’ rights and expectations.

 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

  • Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

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Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

    • The processing of personal information is legitimate because it enables us to operate our serviced accommodation business effectively, securely, and in line with legal and industry standards. We collect and use guests’ personal data — such as names, contact details, payment information, booking history, and identity verification documents — to manage reservations, confirm identities, process payments, ensure safety, and provide a professional and reliable service to all guests. This processing is necessary to: Manage and confirm bookings; Communicate essential information such as check-in instructions and safety procedures; Verify the identity of guests to prevent fraud and ensure the security of both guests and property; Process payments and meet financial or insurance obligations; Comply with health, safety, and record-keeping requirements; and Provide relevant updates or marketing information about our services where guests have a reasonable expectation of receiving them. Without processing this data, we would be unable to provide accommodation, meet contractual or legal obligations, or ensure the safety and security of our properties and guests. There are no less intrusive methods to achieve these aims. CCTV Monitoring In some of our properties, CCTV cameras are used in communal or external areas for the legitimate purpose of ensuring guest and property security, deterring crime, and protecting staff and visitors. Cameras are positioned only where necessary and do not monitor private areas such as bedrooms or bathrooms. Footage is securely stored for a limited period and only accessed when needed for security or legal purposes. Balancing Test – Benefits vs. Risks The benefits of this processing include: Maintaining a safe and secure environment for guests, staff, and property; Preventing and investigating incidents such as theft, vandalism, or unauthorised access; Delivering a smooth and professional booking experience; Allowing for effective communication before, during, and after stays; and Sharing relevant service updates or offers that guests may reasonably expect as part of their customer relationship. We recognise that processing personal information and using CCTV may present some privacy risks. To minimise these, we: Limit the amount of personal data collected and only keep it for as long as necessary; Protect data through encryption, secure systems, and restricted staff access; Clearly inform guests about data use through our privacy notice and signage where CCTV operates; and Provide simple ways for individuals to access, correct, or object to the processing of their data. With these safeguards in place, the potential impact on individuals’ privacy is limited and proportionate. The benefits — including guest safety, fraud prevention, and high-quality service delivery — clearly outweigh any minimal risks. We believe the processing represents a fair balance between our business needs and guests’ rights and expectations.

 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

  • Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

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Where we get personal information from

  • Directly from you

  • Suppliers and service providers

 

How long we keep information

 

Purpose

This retention policy outlines how Onest Property Management Ltd manages personal information collected from clients, employees, and other stakeholders. The policy ensures compliance with data protection regulations and promotes transparency.

 

Retention Schedule

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Booking Information

  • Types of Information: Names, contact details, payment information, stay history.

  • Retention Period: 6 years after the last booking.

  • Reason: Compliance with tax regulations and to resolve any potential disputes.

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Customer Feedback and Complaints

  • Types of Information: Survey responses, complaints records.

  • Retention Period: 2 years.

  • Reason: To improve service quality and monitor ongoing issues.

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Marketing Data

  • Types of Information: Email addresses for newsletters, promotional materials.

  • Retention Period: Until consent is withdrawn or 2 years from the last engagement.

  • Reason: To maintain accurate marketing lists and comply with data protection regulations.

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CCTV Footage

  • Types of Information: Video recordings for security purposes.

  • Retention Period: 30 days.

  • Reason: For security and safety compliance.

 

Contractual Agreements

  1. Types of Information: Terms of service, rental agreements.

  2. Retention Period: 6 years after the contract ends.

  3. Reason: To address any legal claims that may arise.

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Legal Documents

  • Types of Information: Incident reports, legal claims.

  • Retention Period: 6 years after resolution.

  • Reason: Compliance with legal obligations.

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Employee Information (if applicable)

  • Types of Information: Personal details, payroll information.

  • Retention Period: 6 years after employment ends.

  • Reason: Compliance with employment law and potential disputes.

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Review and Deletion

Onest Property Management Ltd will regularly review its retention schedule to ensure compliance with legal requirements. Personal information that is no longer necessary will be securely deleted or anonymized.

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Data Security

All retained information will be stored securely, with access limited to authorized personnel only. Appropriate technical and organizational measures will be implemented to protect personal data.

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Policy Review

This retention policy will be reviewed annually or as necessary to accommodate changes in legal requirements or business practices.

 

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

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Who we share information with

Others we share personal information with

  • Insurance companies, brokers or other intermediaries

  • Professional or legal advisors

  • Regulatory authorities

  • Organisations we’re legally obliged to share personal information with

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How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice. If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

 

The ICO’s address:

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

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Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

 

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