Privacy notice.

Gena Property Management Limited (company number 07311491), First Floor, 128 Balham High Road, London, SW12 9AA, is the data controller for the personal information described in this notice, under the UK GDPR and the Data Protection Act 2018. Email info@genapm.com with anything about it. We are registered with the Information Commissioner's Office under registration ZA145113.

Where your information comes from

Most of what we hold about residents did not come from them. It reaches us:

• from you — when you write, call, use the Gena Online portal or the Gena Go app, or complete one of our forms;
• from the managing agent, freeholder or management company we take over from, when we are appointed to your building;
• from your solicitor or the seller's solicitor when you buy, and from HM Land Registry;
• from your landlord or letting agent, if you rent;
• from contractors, surveyors and insurers who attend the building;
• from the directors of your residents' or management company.

What we hold

• Contact details — name, correspondence address, flat, email addresses and phone numbers, including mobile.
• Your account — lease details, service charge and ground rent account, payments, arrears, and any recovery action.
• Correspondence — letters, emails, text messages, app messages, live chat, form submissions and notes of calls.
• Building and safety information — occupancy, keys and fobs held, alterations, and whether anyone in the flat would need help to evacuate.
• CCTV, at buildings that have it.
• Website and app data — basic technical information, and the IP address a form was submitted from, which we keep for 90 days to prevent and investigate abuse of the forms.

Evacuation and mobility information

If you tell us that someone in your household would need help to leave the building in an emergency, that is information about health, which data protection law treats as a special category and protects more strictly. We ask because the building's fire strategy and the fire service need to know, and we use it only to plan for and respond to an emergency — including preparing a Personal Emergency Evacuation Plan and, where the fire strategy requires it, telling the fire and rescue service that assistance is needed at a particular flat.

Answering is voluntary, and every question of this kind offers “prefer not to say”.

What we use it for, and why we are allowed to

• Managing the building — repairs, maintenance, compliance, insurance, instructing contractors. Our contract, and our legitimate interest in managing the building properly.
• Service charge and ground rent accounting — budgets, demands, statements, year-end accounts. Contract and legal obligation.
• Recovering arrears — reminders, and where necessary instructing solicitors. Contract, and our legitimate interest in collecting what the building is owed.
• Keeping you informed about works, interruptions and anything affecting your flat or the building. Legitimate interests.
• Fire and building safety duties, including the building's safety case. Legal obligation.
• Statutory duties — section 20 consultation, statutory accounts, leasehold property enquiries, HMRC. Legal obligation.
• Emergencies affecting somebody's safety. Vital interests, and legal obligation.
• Answering enquiries and complaints. Contract and legitimate interests.
• Preventing fraud and abuse of our website forms. Legitimate interests.
• Marketing our services to prospective clients. Consent, or legitimate interests where the law allows — and you can stop it at any time.
• Sending you new blog articles, if you asked us to. Consent — given by ticking the box on the subscribe form, and withdrawn by unsubscribing.

Where we rely on legitimate interests you have the right to object, and we will stop unless we have compelling grounds not to.

Your phone number, and text messages

We use your phone number to run the building, not to sell to you.

• What we send. Service messages about your building and your account — a water shut-off, a lift out of service, scaffolding, an alarm test, a failed access attempt, an overdue service charge. Nothing promotional is attached to them.
• Our basis. Our legitimate interest in keeping you informed about the building you live in, and our contract for account matters. Because these are service messages rather than marketing, we do not need your consent to send them — but you can still tell us to stop.
• Telling us how you would rather be reached. You can ask us to use email or post instead, at any time, and we will.
• Safety messages are the exception. If something is happening that affects your safety or your ability to use your home — an evacuation, a fire, a gas escape, a total loss of water or power, someone trapped in a lift — we may text every mobile number we hold for your flat, including where you had asked to be contacted another way. We would sooner reach you and be wrong about the channel.
• Stopping altogether. If you ask us to stop texting you, we will, and that applies to safety messages too. We will reach you by post and email instead, which is slower.
• Replying STOP will not work. Our messages are sent from a name — “Gena PM” — rather than a phone number, so nothing you send back reaches us. To stop, or to change how we contact you, email info@genapm.com or use the link in any “update your details” message we send you.
• Who delivers them. We use Twilio, a messaging provider, who handle the number and the message on our instructions and for no purpose of their own. Our account is hosted in Ireland, so the messages and their delivery records stay within the European Economic Area.
• We never sell or rent your number, and we do not give it to contractors for marketing. A contractor gets it only to arrange access to your flat for a specific job.

Subscribing to the blog

If you ask us to email you new articles, we hold your email address, your first name if you gave us one, the page you subscribed from, and the date — so we can show, if we are ever asked, what you agreed to and when.

We use it for that and nothing else. It is not added to any other list, it is not used to sell you anything, and it is never passed to anyone else. Subscribing tells us nothing about which building you live in, and has no effect on anything to do with your flat.

Every email carries an unsubscribe link, and you can also just reply and ask us to stop, or email info@genapm.com. We remove you and keep no record of you beyond a note that the address asked not to be contacted — which is the only way of making sure it is not added again.

Who we share it with

• the freeholder, and the directors of your residents' or management company;
• contractors and surveyors attending the building, with what they need for the job;
• insurers and insurance brokers;
• accountants and auditors preparing the building's accounts;
• solicitors, where a debt is being recovered or a lease term enforced;
• your solicitor, and your buyer's solicitor, when you sell;
• the emergency services;
• our software and service providers, who run our systems on our instructions;
• HMRC, local authorities, the building safety regulator and other regulators, where the law requires it;
• the incoming managing agent, if we stop managing your building.

We do not sell your personal data, and we do not share it for anyone else's marketing.

Where it is held

In the United Kingdom and the European Economic Area. Our email is hosted on Microsoft 365 and our text messaging on Twilio's Irish infrastructure. Where any provider processes information outside the UK, we rely on the UK's adequacy regulations or on the International Data Transfer Agreement or Addendum, so it keeps essentially the same protection it has here.

How long we keep it

• Service charge and account records — six years after the end of the financial year they relate to.
• Correspondence — six years.
• Fire and building safety records — for as long as the building stands.
• CCTV — normally 30 days, unless it is needed for an incident or a claim.
• Form submission IP addresses — 90 days.
• Blog subscriptions — until you unsubscribe, and then only a suppression record so we do not add you back.

When we stop managing your building we hand the records to the incoming agent, and keep only what we need for our own legal obligations.

Your rights

You can ask us for a copy of the information we hold about you; ask us to correct it, delete it, or restrict what we do with it; object to processing we base on legitimate interests; ask for it in a portable form; and withdraw any consent you have given. You can object to direct marketing at any time and we will always stop.

Email info@genapm.com. It is free, and we will normally answer within one month.

Decisions about you

We do not make decisions about you by automated means alone. We use software to help sort, summarise and draft correspondence, but a member of our staff reads it and decides.

Cookies

This website uses only the minimal cookies needed for it to function. We don't use advertising trackers.

Complaints

Tell us first — info@genapm.com, or through our complaints procedure. If you are still unhappy you can complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113. You may also be able to take a complaint about our service to The Property Ombudsman.

Changes to this notice

We review this notice at least once a year, and whenever we change how we handle personal information. The date at the top is when it last changed, and we will tell residents directly about anything significant.