Privacy Policy Freedom Homes Ltd.

Introduction

Freedom Homes Ltd (“we”, “our”, “us”) is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and protect your personal data when you interact with us through our website, services, phone lines, or other channels.

1. Who We Are

Freedom Homes Ltd is a property management company that collects and processes personal data to provide our services.

We act as the Data Controller under the UK General Data Protection Regulation (UK GDPR) for the personal data we collect and process in connection with our services. This includes the personal data of tenants, applicants, guarantors, landlords, contractors, and enquirers.

In most circumstances, landlords whose properties we manage are separate data controllers for personal data relating to their property. We and the landlord each determine our own purposes and means of processing. In limited cases where we act solely on a landlord’s instructions, we act as a Data Processor and will make this clear.

2. Contact Information

Data Controller: Amy Shearing
Email: amy@freedomhomesltd.com

Data Protection Officer: Sam Bertram, Managing Director
Email: sam.bertram@freedomhomesltd.com

3. What Data We Collect

We may collect and process the following categories of personal data, depending on your relationship with us (tenant/applicant/guarantor/landlord/contractor/enquirer/website visitor/caller):

Core Contact & Identity

Full Names, Phone Numbers, Email Addresses, Date of Birth
Tenants/Applicants/Guarantors
Employment Information (including Job Title and Salary)
Next of Kin Details
Guarantor Information (if required)
CCJs or Adverse Credit Information
Enquiry & Booking Details (e.g., property viewing requests)
Communication Records

Landlords

Contact Details and Proof of Identity (where required for AML/KYC)
Property Ownership & Compliance Information (e.g., EPC, Gas & Electrical certificates, HMO licences)
Bank Details for payment remittance
Insurance details and related claims information
Tenancy and financial information relating to properties under management

Website & Telephony

Technical data (cookies/analytics, as applicable)
Call Recordings and Call Metadata (see Section 12)

4. How We Collect Your Data

When you make an enquiry through our website, phone, or email
When you book a property viewing
When you interact with us via social media platforms (e.g., Facebook, SpareRoom, Rightmove, Zoopla)
When you fill out forms on our website
From referencing agencies and publicly available sources (e.g., Land Registry, Companies House) where lawful

5. How We Use Your Data

Communication & Service Delivery

To contact you regarding enquiries, tenancy matters, property management, and related services
Tenant Referencing
To assess suitability for a property, including affordability checks via third-party referencing companies

Landlord Services

To set up and manage properties, arrange maintenance, ensure legal compliance, collect and remit rents, and manage accounts/statements

Booking & Operations

To manage appointments, viewings, inspections, and contractor visits

Compliance & Security

To fulfil legal/regulatory obligations (e.g., licensing, safety certifications, AML/KYC), and to cooperate with lawful requests from authorities

Quality, Training & Dispute Resolution

To maintain service standards, resolve disputes, and prevent fraud (including use of call recordings – see Section 11A)

6. Lawful Basis for Processing Your Data

Contractual Necessity: Performing tenancy agreements, landlord management agreements, and related pre-contract steps
Legal Obligation: Meeting statutory duties (e.g., licensing, safety checks, AML/KYC, tax/recordkeeping)
Legitimate Interests: Operating and improving our business, ensuring service quality, safeguarding property/assets, fraud prevention, and managing disputes; balanced against your rights and freedoms

Where we rely on legitimate interests (e.g., for call recording, quality assurance, and dispute resolution), we conduct a balancing assessment.

7. Data Sharing and Third Parties

We may share data with:

Referencing Companies (separate controllers) to validate tenant suitability/affordability
Virtual Assistants (separate controllers) to manage enquiries and bookings
Landlords and Their Professional Advisers (controllers) where necessary for property management and compliance
Governance & Public Bodies: Local authorities, deposit schemes, law enforcement, courts, HMRC (where legally required)
Payment & Telephony Providers / IT Vendors (processors) who host systems (including call recordings) under our instructions and safeguards
Contractors & Utility Providers (typically separate controllers) for maintenance and service provisioning

All processors are bound by contracts with appropriate data protection measures.

8. Data Retention

We retain personal data only for as long as necessary for the purposes collected or as required by law.

Tenants: Personal data is retained in line with legal obligations and limitation periods, then archived; certain records may be kept longer where legally required or for potential legal claims.
Enquiries: Data that does not progress to a tenancy is retained per our schedule and then securely deleted.
Landlords: Data related to property management and compliance is retained for the duration of our management plus relevant legal/limitation periods.
Call Recordings: See Section 12 (retention specifics).

9. Your Rights Under UK GDPR

You have the right to access, rectification, erasure, restriction, and data portability, and to object to processing based on legitimate interests (including call recording).
To exercise your rights, contact Amy Shearing at amy@freedomhomesltd.com. We will respond within one month.

10. Data Security

We implement appropriate technical and organisational measures to protect your data, including:

Encryption in transit and at rest
Access Controls restricted to authorised personnel
Regular Audits for GDPR compliance and risk management

11. Data Breach Notification

If a breach poses a risk to your rights and freedoms, we will notify the ICO within 72 hours of becoming aware and inform affected individuals without undue delay where there is likely a high risk.

12. Telephone Call Recording

We operate phone systems that record inbound and outbound calls.

What we record

Audio of the conversation and call metadata (time, duration, numbers involved).
We will notify you at the start of calls (or via published notices on our channels) that calls may be recorded.

Why we record (purposes)

Quality monitoring and staff training
Evidence for enquiries, tenancy/management discussions, complaints, and dispute resolution
Fraud and abuse prevention, and to ensure accurate records of instructions/agreements

Lawful basis

Legitimate interests (Article 6(1)(f) UK GDPR) for the purposes above. We have assessed that recording is proportionate and that your rights are respected.

Can recording be paused?

Recording cannot be paused mid-call. If you do not wish to be recorded, you can end the call and request to continue via a new call without recording or via another channel (e.g., email). We will accommodate reasonable requests for a non-recorded call or alternative communication.

Retention

Call recordings are retained no longer than necessary for the purposes above typically up to 12 months, unless required longer for an ongoing complaint, dispute, legal obligation, or claim. They are then securely deleted.

Access & sharing

Access is strictly limited to authorised personnel with a business need (e.g., senior staff handling complaints/training).
Recordings may be shared with relevant third parties only where necessary and lawful, e.g., our telephony provider (as a processor), legal advisers, law enforcement, regulators, or courts.

Your choices and rights

You may object to call recording at any time. If you do, we will offer to end the call and arrange a new, non-recorded call or an alternative channel.
You may request access to call recordings related to you, subject to legal exemptions and identification requirements.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or UK GDPR requirements. Updates will be posted on this page and, where appropriate, notified by email.

14. Contact Us

For questions about this Privacy Policy or how we handle your personal data, please contact:

Amy Shearing: amy@freedomhomesltd.com

Sam Bertram: sam.bertram@freedomhomesltd.com