Land referencing privacy notice
Heathrow West takes your privacy seriously where we deal with your personal information.
Heathrow West is aiming to submit an application for a new terminal at Heathrow. This privacy notice (“Notice”) describes how Heathrow West will collect, store and use your information for the purposes of carrying out land referencing activities for the purposes of submitting an application for a new terminal.
References to “Heathrow West” “us”, “we“, “our” in this Notice mean Heathrow West Limited who is data controller of information processed under this Notice, a company registered in England and Wales with company no. 11826881. Our registered office is at World Business Centre 3 Newall Road, London Heathrow Airport, Hounslow, Greater London, United Kingdom, TW6 2TA.
You have the right to object to us using, sharing or carrying out processing of your information in certain circumstances, including using your information for direct marketing. Please contact us at any time using the contact details provided below for more details and to exercise this right where applicable.
What is land referencing?
What information does heathrow west process?
What are the sources of the information heathrow west collects?
How does heathrow west use my information?
Does heathrow west share my information?
How long does heathrow west keep my information?
Does heathrow west transfer my information abroad?
What are my privacy rights?
What is land referencing?
Land referencing is where we carry out the process of identifying people and organisations who own, occupy or have an interest in property or land that may be affected by our proposed development and identifying the nature of their interest.
The information collected will be provided as part of our application in a document called the ‘Book of Reference’ which sets out our understanding of the people and organisations whose property or land may be affected by our proposed development.
What information does heathrow west process?
We collect the following information about you:
- Identity details (including your name (which can include, if applicable, your previous names and/or alternative names), gender, date of birth and address);
- Contact details (including your telephone number, email address, and postal address (which can include any of your previous addresses, alternative addresses and/or additional addresses));
- Details of your property (including your interests in land (including but not limited to details of tenants, details of occupiers, details of mortgages and/or other charges, details of easements, details of manorial rights, and/or details of rent charges)).
What are the sources of the information Heathrow West collects
We collect your information from the following sources:
Information you give us directly
- You (or your staff/agents on your behalf) give us information about you when you complete or confirm your details in a land interest questionnaire, in any other forms we may ask you to complete and in any other communications or correspondence with us.
Information we collect from other parties
- We collect information about you from publicly available sources of information, such as HM Land Registry, public search databases (including Trace IQ and Google), social media sites (such as Facebook, LinkedIn and Twitter), Companies House, directory websites (such as 192.com and the BT directory), public notices (such as planning notices, notices on public notice boards, and/or notices posted in the Gazette) and credit reference agencies.
- We collect information from third parties who have an interest in the land (such as mortgage lenders).
- Our service providers/consultants who assist or advise us in relation to our expansion project may also create or obtain for us personal information about you.
How does Heathrow West use my information?
We may use your information for the following purposes:
Where we have a legal obligation
- To identify if you or an organisation you represent have an interest (legal or equitable) in houses, flats and any other properties or land that may be affected by our proposed development.
- To contact you where we have not been able to confirm whether you have an interest in a property or land that may be affected by our proposed development or where we need to clarify information relating to you provided by you or collected from another party.
- To include you and details of your interests concerning the proposed development in the Book of Reference which we are required to submit with our application for a new terminal.
- To make decisions regarding the relevance and suitability of your interest in land for the purposes of our proposed development and to prepare and manage our application for a new terminal.
Please note that it is not compulsory to provide any information to us, however providing this information allows you make the best of the consultation process and have your views taken into account.
Does Heathrow West share my information?
We share your information in the following circumstances:
- We include your information in the Book of Reference, if we consider that your legal interest in property or land may be affected by our proposed expansion plans. Please note that this Book of Reference is made public revealing your name and details of your interest. The Book of Reference is a statutory document which is required to be submitted as part of our application for our proposed development.
- We share your information with other group companies listed below for internal reasons, primarily for business and operational purposes, and we ensure your information is used in line with this Policy:
- Grove Developments Limited (registered in England and Wales under company registration number 07459482); and
- Arora Management Services Limited (registered in England and Wales under company registration number 05636920).We share your information with third parties who perform services on our behalf, such as consultants, service providers, professional advisors and IT service providers and those that carry out consultation and community engagement processes on our behalf.
- We share your information where you give us express permission to share your information in the course of your relationship with us from time to time.
- We share your information if we are under a duty to do so, in order to comply with (and/or where we reasonably believe we are under a duty to comply with) any legal obligation; or in order to enforce any agreement we have in place with you; or to protect the rights, property, safety, or security of Heathrow West, third parties, users of our services or the public.
- As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us your information will be disclosed to such entity.
We do not sell or otherwise disclose information we collect about you, except as described herein or otherwise disclosed to you at the time the data is collected.
How long does Heathrow West keep my information?
Information that we collect will be retained only for as long as is necessary to fulfil the purposes outlined above. This will generally be until the completion of our application and proposed development and may be either longer or shorter depending on the factors set out below. When determining the relevant retention periods for your information, we will take into account factors including:
- our contractual obligations and rights in relation to the information involved;
- our legal obligation(s) under applicable law to retain data for a certain period of time;
- statute of limitations under applicable law(s);
- (potential) disputes; and
- guidelines issued by relevant data protection authorities.
We will securely erase your information where we do not have a legitimate reason for keeping it.
Does Heathrow West transfer my information abroad?
Your information is generally stored and processed in the UK, however in certain circumstances we transfer your information to the US. Where we transfer your information to the US, we rely on the EU-US Privacy Shield Framework. This framework is approved by the European Commission as providing a level of protection equivalent to that in the EU in relation to data protection. Further information on the Privacy Shield Framework can be found at https://www.privacyshield.gov/welcome.
If we intend to transfer your information to any additional countries, we will update this Notice to reflect such overseas transfer.
What are my privacy rights?
By law, you have a number of rights (subject to certain conditions) when it comes to your information. You can exercise any of these rights by contacting us through our details in the contact section below.
|Rights||What does this mean?|
|The right to object to processing||You have the right to object to certain types of processing, including processing that relies on legitimate interest as a lawful basis, processing for direct marketing purposes (i.e. if you no longer want to receive direct marketing newsletters and updates from us).|
|The right to be informed||You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Notice.|
|The right of access||You have the right to obtain access to your information (if we are processing it), and certain other information (like the information provided in this Notice).
This is so you are aware and can check that we are using your information in accordance with data protection law.
|The right to rectification||You are entitled to have your information corrected if it is inaccurate or incomplete.|
|The right to erasure||This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.|
|The right to restrict processing||You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.|
|The right to data portability||You have the right to receive your information in a structured, commonly used and machine readable format and to request that this data is transmitted to another entity where this is technically feasible. This right only applies to information you have provided to us yourself (not any other information), that we process by automated means based on your consent or for the performance of a contract with you.|
|The right to lodge a complaint||You have the right to lodge a complaint about the way we handle or process your information with your relevant national data protection regulator. See details of the UK data protection regulator in the contact section below.|
|The right to withdraw consent||If you have given your consent to anything we do with your information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your information with your consent up to that point is unlawful). This includes the right to withdraw consent to us using your information for marketing purposes.|
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know.
We may periodically make changes to this Notice. We will notify you of any significant changes where we have a relationship with you and otherwise post updated versions on our website at http://heathrow-westconsultation.com/privacy-notices/. We recommend that you revisit this Notice regularly.
If you have any queries or requests concerning this Notice or how we handle your information more generally, please get in touch with us using the following details:
- Email: GDPR@thearoragroup.com
- Post: World Business Centre 3 Newall Road, London Heathrow Airport, Hounslow, Greater London, United Kingdom, TW6 2TA
If you are not satisfied with our response to a complaint you have made, or think we are not complying with data protection law, you can make a complaint to the UK data protection regulator who can be contacted as set out below:
Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Phone number: 0303 123 1113