Privacy Policy

1. Ethical Maintenance appreciates your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our homeowners and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

2. This Privacy Information explains how we use your personal data, how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data. The sections in this policy are:

1 ….. What Does This Policy Cover?
1 ….. Information About Us Ethical Maintenance.
1 ….. What is Personal Data?
2 ….. What Are My Rights?
2 ….. What Personal Data is Collected?
2 ….. How is My Personal Data Used?
3 ….. How Long Will You Keep My Personal Data?
3 ….. How and Where Is My Personal Data Stored?
3 ….. Do You Share My Personal Data?
4 ….. How Can I Access My Personal Data?
4 ….. How Do I Contact You?
4 ….. Changes to this Privacy Notice

Information About Us Ethical Maintenance.

3. Ethical Maintenance is a Community Interest Company registered in Scotland:

Company number SC319519.
Property Factor no PF000158.
Registered address: Ethical Maintenance C.I.C., Johnstone House, 52-54 Rose Street, Aberdeen AB10 1HA.
Trading addresses are e-centre, Cooperage Way, Alloa FK10 3LP
2 Poynernook Road, Aberdeen AB11 5RW
Email address: mail@ethicalmaintenance.org
Telephone no: 01786 342006
Company Data Protection Officer: Jane Peck

We are regulated by The Property Factors (Scotland) Act 2011 and The Community Interest Company Regulations 2005, and their subsequent amendments.

What is Personal Data?

4. Personal data is information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. Since Brexit, UK GDPR legislation follows the EU legislation and in addition since 2025 the Data Use and access Act 2025. It defines how personal data as any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.

5. The personal data that we use is set out in paragraph 9 below.

What Are My Rights?

6. You have the following rights, which we will always work to uphold:

a. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in paragraph 23.
b. The right to access the personal data we hold about you. Paragraphs 19 – 22 will tell you how to do this.
c. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in paragraph 23 to find out more.
d. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in paragraph 23 to find out more.
e. The right to restrict the processing of your personal data or to object to us using your personal data for purposes other than those uses required by our factoring services.
f. The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
g. Rights relating to automated decision-making. Paragraph 10 – 12 explains more about how we use your personal data, including automated decision-making.

7. For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in paragraph 23. Further information about your rights can also be obtained from the Information Commissioner’s Office or from the Citizens Advice Bureau.

8. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

What Personal Data is Collected?

9. In order to provide the factoring service, we may collect some or all of the following personal data:

Name, Telephone numbers, Title, Correspondence with you, Gender Payment information, Address, Account balances, Email address

How is My Personal Data Used?

10. We must always have a lawful basis for using your personal data. The principal reason is we are contracted to provide property factoring services to you. The other main reason is that you are expecting us to reply to a communication from you and as such have consented to our use of your personal data. Your personal data will be used for the following purposes:

 a. Providing the property factoring service associated with your home;
 b. Managing your account;
 c. Communicating with you, including responding to calls and emails from you;
 d. Supplying you with information by our Online Homeowners Platform, email, phone, text or post.

11. We may use your personal data to advise you about our services, which may include contacting you by e-mail, telephone, text message and post. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the UK GDPR legislation alongside the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out of e-mails, telephone calls and text messages.

12. We do not use any automated systems for carrying out decision-making. If we start to use automated systems we will up-date this policy and then if you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), then you have the right to do so. Please contact us to find out more using the details in paragraph 23.

How Long Will You Keep My Personal Data?

13. We only keep your personal data to enable us to deliver our factoring services. Once you no longer receive these services, for example if you move house, we keep your data for up to six months once your account has been settled, just in case something comes up.

How and Where Is My Personal Data Stored?

14. Your personal data is kept securely on Microsoft Office 365 cloud and on OtagoTech’s servers.

15. The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• Using firewalls to protect unauthorised access to our systems;
• Two factor authentication password protected access to our systems;
• Encryption of data stored; and
• A clear desk policy in our offices.

Do You Share My Personal Data?

16. We share your data only where necessary with those companies that deliver a part of the factoring service that we provide for you. The companies that we share it with are:

a. Royal Bank of Scotland in processing payments;
b. World Pay so that we may take payments over the phone;
c. Xero – host of our accounting system
d. Microsoft Office cloud;
e. OtagoTech Ltd, Glasgow who host our Homeowner Portal
f. Our reception service, MyRuby Ltd;
g. Solicitors directly involved in the purchase and or sale of your property;
h. Our insurance broker and underwriter; if there is an insurance claim, and
i. Those associated with collected outstanding payments including Alex M. Adamson LLP Debt Collection Services, Sheriff Officers and the Courts.

17. With these companies we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law. They may occasionally contract with third parties that are located outside of the European Economic Area. If any personal data is transferred to a third party outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the UK GDPR, as explained above in paragraph 14.

18. We do not share any of your personal data with any third parties for marketing purposes. We will also share your data with the authorities if we are legally obliged to do so, such as with legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

How Can I Access My Personal Data?

19. If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it. This is known as a “subject access request”.

20. All subject access requests should be made in writing and sent to the email or postal addresses shown in paragraph 23. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

21. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

22. We will respond to your subject access request within 30 days. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

How Do I Contact You?

23. To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details ‘For the attention of Ms Jane Peck, Company Data Protection Office’:

Email address: mail@ethicalmaintenance.org
Telephone no: 01786 342006
Postal Address: Ethical Maintenance cic, e-centre, Cooperage Way, Alloa FK10 3LP

Changes to this Privacy Notice

24. We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

25. This policy is version 25.01 Any changes will be made available on our website at www.ethicalmaintenance.org.

Jane Peck
Company Data Protection Office
Ethical Maintenance cic
17 February 2025