1. Who we are
This privacy notice applies to the following separate businesses, where they collect or use personal information in
connection with their services or through this website:

• Clearwater Block Management Limited (company number 17510464): residential block management.

Registered office: 40 Foregate Street, Worcester, Worcestershire, WR1 1EE.

• Clearwater Property Partners Limited (company number 11635961): property investment, development and related property services.

Registered office: 40 Foregate Street, Worcester, Worcestershire, WR1 1EE.

• Clearwater Social Homes Limited (company number 16582936): housing and property services, including arrangements
with housing providers and support organisations.

Registered office: 40 Foregate Street, Worcester, Worcestershire, WR11EE.

Each company is a separate legal entity and is responsible as a data controller for personal information it determines how
and why to use. In some circumstances, a company may act as a processor on behalf of another controller, such as a
Right to Manage (RTM) company or a housing client. Where information is shared between the Clearwater companies, this
will be limited to appropriate purposes and supported by a lawful basis and relevant safeguards. The company you deal
with, and the circumstances of your interaction, determine which entity is responsible for your data.

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2. Our data protection contact
Faye Semon is the Data Protection Lead and contact for privacy and data protection enquiries relating to the Clearwater companies covered by this notice.

Email: hello@clearwaterblockmanagement.co.uk
Telephone: 0333 335 5204
Postal address for privacy enquiries:

FAO Faye Semon, Data Protection Lead, Clearwater Block Management Limited, 40 Foregate Street, Worcester, WR1 1EE.
Please mark correspondence for the attention of Faye Semon, Data Protection.

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3. Personal information we collect
Depending on your relationship with the relevant Clearwater company, we may collect names, contact details, postal and property addresses, correspondence, ownership and tenancy information, service-charge and payment records, maintenance and repair requests, contractor and supplier information, and details required for property investment, development, lettings, housing management and related services. We may also process information relevant to applications, eligibility, housing arrangements or resident support needs where necessary and lawful.

 

We may receive information from you, RTM directors, landlords, tenants, leaseholders, housing associations, charities, care or support providers, contractors, professional advisers and other relevant parties. Website enquiries may include information submitted through forms or email, as well as technical information necessary to operate the website.

 

We do not seek sensitive or special-category information unless necessary for a specific lawful purpose. Where health, disability, accessibility or support-related information is required for housing or safety arrangements, we will use an appropriate UK GDPR lawful basis and any additional condition required for special-category data, restrict access and avoid unnecessary disclosure.

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4. How and why we use information

Depending on the services provided by the relevant company, we use personal information to respond to enquiries; assess and manage property and housing arrangements; manage lettings, developments, buildings and communal facilities; administer service charges, payments and accounts; arrange repairs, inspections and compliance work; communicate with residents, tenants, leaseholders, clients, directors and suppliers; handle complaints; safeguard people and property; and meet legal and regulatory obligations.

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Our lawful bases depend on the purpose and may include performing a contract, complying with legal obligations and legitimate interests. Where consent is required, such as for certain optional marketing activities or non-essential cookies, we will request it. Where special-category information is used, an additional UK GDPR condition must apply. The relevant company will provide further information where a particular service requires it.

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5. Who we share information with

We share information where necessary and lawful with relevant Clearwater companies; RTM companies and directors; landlords, housing associations, charities and support providers; accountants, banks, insurers, legal advisers, surveyors, contractors, IT and website suppliers; and public authorities where required. Information is shared only to the extent appropriate to the purpose, with suitable contractual and security safeguards where applicable. We do not sell personal information.

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6. How long we keep information
We retain information only as long as reasonably necessary for management, accounting, legal, safety and dispute-resolution purposes. Different records have different retention periods, which depend on applicable law, contracts and the nature of the information. We securely delete or anonymise records when they are no longer needed.

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7. Security and international transfers
We use appropriate organisational and technical safeguards to protect personal information, including access controls and secure record-handling procedures. If information is transferred outside the UK, we will ensure that a lawful transfer mechanism and appropriate safeguards are in place where required.

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8. Your data protection rights
Depending on the circumstances, you may have rights to access your information, correct inaccuracies, request erasure, restrict or object to certain processing, receive portable data, and withdraw consent where consent is the lawful basis. Some rights are subject to legal exceptions.

 

To exercise a right, contact Faye Semon using the details above and, if possible, identify which Clearwater company or service your request relates to. We may need to verify your identity before responding.

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9. Website cookies and third-party services
The website may use essential cookies or similar technologies to function. If optional analytics, advertising or other non-essential cookies are used, visitors will be given clear information and asked for consent where required before those cookies are set.
Links to third-party websites are governed by those sites’ own privacy notices.

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10. Complaints and updates
Please contact us first if you have concerns about our handling of personal information. You also have the right to complain to the Information Commissioner’s Office (ICO): www.ico.org.uk, telephone 0303 123 1113.
We may update this notice when our services, legal requirements or data practices change.

The current version will be published on our website.

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