Privacy Policy

This Notice supersedes any previous privacy notice or information previously provided, whether written or unwritten, and is the Association’s current statement of how it uses personal data.

About This Notice

This Notice explains how Branksome Towers Flatowners’ Association Limited (“BTFA”, “the Association”, “we”, “us”) collects and uses personal data in the course of managing Blocks A & B, Branksome Towers, Westminster Road, Poole, Dorset BH13 6JU. It covers our CCTV system, the resident area of our website, the forms and cookies on our website, correspondence and contact details, and, at a high level, the financial administration carried out on our behalf by our managing agent and accountants.

This Notice is for residents, visitors, contractors, and anyone else whose personal data we may process in connection with the site.

Who We Are

BTFA is the data controller for the personal data described in this Notice, meaning we decide how and why it is used. If you have any questions about this Notice, or about how we use your personal data, please contact the Directors at directors@branksometowersfa.co.uk or via branksometowersfa.co.uk/contact.

Information We Collect and How We Use It

We collect and use personal data in a small number of specific ways, described below.

CCTV Footage

The CCTV system captures video images of individuals moving through the shared external areas of the site: the pedestrian entrance from the public highway, the car park, the garages, and the entrances to Blocks A & B. No camera is directed at, or captures footage from within, any private dwelling, and the system does not record audio. We use these images to prevent and detect crime, and to protect the safety of residents and visitors and the security of the Association’s property. Full detail is set out in the Association’s CCTV Policy.

The Resident Area of Our Website

Residents may register for the resident area of our website, which gives access to Board notices, shared documents, and posts from other residents. To register, we (or our website administrator on our behalf) collect your name, email address, and flat number, and verify that you are a resident before granting access, so that the resident area remains restricted to permitted residents only. If you post a comment on the website, the system also logs the IP address associated with that comment. Content in the resident area, including other residents’ posts and comments, is visible only to residents who have been granted access, not to the public.

Registration requests are reviewed individually to confirm that the email address given belongs to a genuine, identifiable resident before access is granted; a request that cannot be verified in this way is not approved. Where we already hold a resident’s email address for essential communication, the Directors may also create the resident area account on that resident’s behalf, using the name and email address we hold, so that the resident receives Board notices by email and can log in whenever they wish.

The Directors may also withhold from publication, or remove, any comment or post submitted to the resident area, for any reasonable cause, including concerns about its validity, accuracy, or appropriate content, or any other reason the Directors consider relevant at the time. This discretion is applied fairly and without prejudice to any individual resident, and is used to protect the interests of the Association and of its subscribed residents generally.

Correspondence and Contact Details

We hold contact details, such as email addresses and telephone numbers, that residents and others provide to us for essential communication about the building, for example Board notices, compliance matters, and responses to queries. We use these details only for Association business, and do not use them for marketing or share them other than as described in this Notice. Where a resident tells us how often they would like to receive our email updates, we record that choice, together with their name, email address, and flat number, and use it only to send updates in the way they have chosen.

Financial and Service Charge Administration

Service charge accounts and related financial administration are handled on the Association’s behalf by our managing agent and our accountants, who process leaseholders’ financial and contact information for that purpose. As part of this, our managing agent also independently holds residents’ contact details for its own service charge and correspondence administration. This Notice describes this only at a high level; if you have a specific question about how your service charge data is handled, contact the Directors using the details in the Who We Are section above.

Directors’ Resident Register

The Directors maintain a private register of resident and flat contact information for essential communication, safety, and building management purposes. Where more than one person is associated with a flat, for example a partner or an additional keyholder, the register may hold contact details for each of them. It also records keyholder and access arrangements, and whether a resident is subscribed to the resident area of our website. For context only, it may also note whether a resident takes part in an independent, resident-run group chat covering informal local matters, which the Association does not operate, control, or take any responsibility for. Where the register includes information about a resident’s support or evacuation needs, this is recorded only with that resident’s consent, as described below in Information About Health, Disability and Support Needs. The register is held in a password and two-factor-authentication protected OneDrive/SharePoint folder, and access is restricted to the Directors.

Website Forms

Our website has enquiry, maintenance reporting, and consent request forms. When you submit one, we collect the details you enter, which may include your name, email address, telephone number, flat number, the content of your message, and any photographs or documents you choose to attach. We use these details to respond to your enquiry, to investigate and progress maintenance reports, and to assess and respond to consent requests. Where needed to progress your request, we may share maintenance or consent request details with our managing agent and with contractors engaged to carry out the work.

Cookies

Our website uses only the strictly necessary cookies needed for its core functionality and to keep you logged in to the resident area. We do not use analytics, tracking, or advertising cookies.

Information About Health, Disability and Support Needs

In a small number of cases, we may hold information about a resident’s health, disability, or support needs. This may include a request for a reasonable adjustment, information a resident chooses to give us about their support needs, and personal emergency evacuation information, including the consent-to-share section of the Association’s evacuation information form.

We use this information to make adjustments under the Association’s Equality and Fair Treatment Policy, and to agree evacuation arrangements with the resident concerned under our fire safety duties.

This is special category data under Article 9 UK GDPR, so it requires additional safeguards. We process it on the basis of your explicit consent (Article 9(2)(a) UK GDPR), alongside our legitimate interests under Article 6(1)(f) UK GDPR in making appropriate adjustments and planning safely for an emergency. Only where a resident is unable to give consent in an emergency, for example because they are incapacitated at the time, do we rely instead on the vital interests basis at Article 9(2)(c) UK GDPR, and only to the extent necessary to protect that resident’s life or physical safety. Because we rely on explicit consent, or on vital interests in that limited circumstance, rather than any of the specific conditions listed in Schedule 1 to the Data Protection Act 2018, an Appropriate Policy Document is not required for this processing.

This information is seen by the Directors, and by the managing agent only where the managing agent needs it to help arrange an adjustment or evacuation measure. It is shared with the fire and rescue service only with the resident’s consent, for example as part of arrangements made in advance of an emergency.

We keep this information for as long as it remains relevant, review it at least annually, and delete it once it is no longer needed or the resident concerned leaves.

You can withdraw your consent at any time by telling the Directors. This does not affect anything we have already done on the basis of your consent before you withdrew it.

Aside from what is described in this section, the Association does not otherwise collect information about protected characteristics.

Cameras and Video Doorbells Installed by Residents

This Notice, and the CCTV Policy it summarises, cover only the CCTV system operated by the Association. They do not cover, and the Association takes no responsibility for, any camera, video doorbell, or other image-capturing device that a resident installs themselves.

If you are a resident considering installing such a device, you should be aware that fixing it to the exterior of your flat, an external wall, a communal entrance door, or any other part of the building’s exterior requires the Board’s prior written consent, in the same way as any other alteration to the external appearance of the building. Contact the Directors at directors@branksometowersfa.co.uk before installation. If you already have such a device installed, please contact the Directors in the same way, so that it can be reviewed and approved under this policy in the same way as a new installation.

If your device captures images of a communal area, another flat, or the approach to another flat’s front door, and does so as more than an incidental consequence of protecting your own entrance, you become the data controller for those images in your own right, with your own obligations under UK GDPR. This is separate from, and is not met by, this Notice or any of the Association’s other data protection documentation, and the Board’s consent to the physical installation of your device is not confirmation that your use of it complies with data protection law.

Our Legal Basis

For CCTV, we rely on our legitimate interests under Article 6(1)(f) UK GDPR in preventing and detecting crime and protecting the safety of residents, visitors, and the Association’s property; further detail, including our assessment of this basis, is set out in the Association’s CCTV Policy.

For the resident area of our website, for our website forms, and for general correspondence, we rely on our legitimate interests in managing the site effectively and keeping residents informed, and, where relevant, on the performance of our functions as the management company for the building under the lease.

For the Directors’ resident register, we rely on our legitimate interests in being able to contact residents and keyholders promptly, including in an emergency, and in managing access to the building effectively and safely. Where the register holds information about a resident’s health, disability, or support needs, we instead rely on the basis set out above, in Information About Health, Disability and Support Needs.

For financial and service charge administration, our managing agent and accountants process personal data on the basis that this is necessary to perform our obligations, and leaseholders’ obligations, under the lease, and to comply with our legal obligations as a management company.

How Long We Keep Information

We keep CCTV footage on a rolling basis as described in the Association’s CCTV Policy. Website resident area accounts are kept for as long as you remain a resident and wish to use the resident area, and are removed on request or when a flat changes ownership or occupancy. Correspondence and contact details are kept for as long as necessary to deal with the matter concerned and for our ordinary record-keeping purposes. Information submitted through our website forms is kept for as long as necessary to deal with the matter concerned, and afterwards where needed for our legal, insurance, or governance obligations. A resident’s chosen email update frequency is kept for as long as they receive updates from us. The Directors’ resident register is kept up to date and reviewed when we are told of a change of occupancy, keyholder, or contact details. Financial and service charge records are kept in line with our managing agent’s and accountants’ standard retention practices, including the periods required by law.

Who We Share Information With

We share CCTV footage as described in the Association’s CCTV Policy: principally with the police in connection with the investigation of a crime, and with individuals exercising their right of access. We share website resident area and correspondence data only with our website administrator and IT providers as necessary to run the site, and do not share it for marketing purposes. Maintenance report and consent request details submitted through our website forms may also be shared with our managing agent, and with contractors, as necessary to progress the request. Financial and service charge information, and residents’ contact details for that purpose, are shared with our managing agent and accountants as necessary to administer the service charge, and, where required, with other professional advisers such as auditors. The Directors’ resident register is not shared outside the Directors, except where necessary to deal with a building access or safety issue, for example with a contractor or the emergency services.

Your Rights

Wherever we hold your personal data, you have the right to ask what we hold and to have a copy of it, to ask us to correct inaccurate details, to ask us to erase your data where applicable, and to object to processing where you believe it is not justified. To make a request, or to ask any question about this Notice, contact the Directors at directors@branksometowersfa.co.uk or via branksometowersfa.co.uk/contact. Requests concerning CCTV footage are handled under the Association’s Subject Access Request Procedure and will normally be responded to within one calendar month of your request being received and your identity confirmed.

You also have the right to raise a concern directly with the Information Commissioner’s Office (ICO) if you believe your personal data has been processed unlawfully, without needing to raise it with us first. The ICO can be contacted at ico.org.uk.

On-Site Signage

Signage is displayed at the entrances to the monitored areas, so that individuals approaching the site have the opportunity to become aware of the system. The details the Board has adopted for that signage are set out below.

This scheme is controlled by: Branksome Towers Flatowners’ Association Limited
For the purpose of: Prevention and detection of crime; protection of residents, visitors, and property
For further information contact: branksometowersfa.co.uk/contact

Signage on site is kept aligned with the details set out above as signs are put up, replaced, or completed. This Notice remains the Association’s accurate and effective statement of its position regardless of the exact wording displayed on any individual sign at a given time.

Review

This Notice will be reviewed by the Board at least annually, alongside the Association’s CCTV Policy, and sooner if our processing activities change materially, or if there is a material change in relevant law or ICO guidance.

This Notice should be read alongside the Association’s CCTV Policy, DPIA Screening Record, and Subject Access Request Procedure.

Approval

This Notice was approved by the Board of Directors of Branksome Towers Flatowners’ Association Limited in September 2026, and takes effect from that date. A copy of this Notice, as formally adopted by the Board, is also available for residents to download from the resident area of this website.