The General Data Protection Regulation (GDPR) is in force from 25th May 2018 and covers the processing and controlling of the collection, storage and use of personal data.
Metropolis Property Research Limited is a specialist property research company providing corporate occupier and property business sales and marketing leads relating to office fit-out and developments. These leads are produced from original research and market knowledge.
Metropolis Property Research Limited does not carry out any direct marketing to business contacts but does supply information on appropriate contacts for corporate bodies, property firms, development teams, and facility managers, to a small ‘club’ of client companies focused on the facility management and interior fit-out sector.
This information (business leads) is available as an online database which is securely password protected for use by individual named users within the client business. The client email details held are only used as part of our business service to clients and are held securely.
Metropolis Property Research Limited respects GDPR and its principles in relation to the privacy of our clients, in the operation of our business, and those interested in our products and services. We will continue to review our policy in the light of any further advice on the use of data for Business to Business (B2B) purposes from the Information Commissioner’s Office (ICO).
Metropolis Property Research Limited only collects and processes personal data where we have a ‘legitimate interest’ (specialist corporate research); a contract (where processing is necessary for the performance of a contract (to deliver the Metropolis leads as required); and consent (consent to use data in our leads service). Where we rely on consent to process personal data individuals have the right to withdraw or decline consent at any time and where we rely on legitimate interests, there is a right to object.
It is in our legitimate interest to undertake research on facility management, property development, and real estate contacts to help us provide services to our clients and to enhance or verify the information that we hold or collect.
We mostly obtain publicly available professional information about contacts in the property industry. The personal data collected is Name, Job Title, Company Name, Company email address, and Company telephone number. Our research focus is only on corporate bodies relocating and this has minimal impact on privacy and is proportionate.
In those cases where we contact companies directly we verify contact names with the industry professionals employed by corporate bodies, or the person representing the company, and fully explain our purpose in asking questions on contacts, and request the appropriate named contact and email.
Direct marketing is covered under GDPR’s legitimate interest compliance, and clients should be able to contact the business contacts included on the leads as the majority of the contact names are derived from public sources, such as site and project boards, marketing material and press releases, newspapers and journals, corporate websites, and internet searches. As such processing relating to personal data ‘manifestly made public by the data subject’ is given as an exception under GDPR.
In practice, this means that we will continue to process personal information as part of such research and gain consent from industry professionals employed by corporate bodies, or the person representing the company, and to process corporate email addresses as part of our business leads reports to our clients.
Clients of Metropolis Property Research Limited can use our ‘Metropolis leads’ to support sales and marketing activities but must also adhere to GDPR regarding the collection, storage and use of personal data within your business. Using personal data for the purposes of electronic marketing communications continues to be covered by the Privacy and Electronic Communications Regulations 2003. You may need to take independent advice to ensure that you comply.
We have reviewed our research processes to be compliant with GDPR and will continue to monitor these and institute an on-going training programme for our research team. The data that we supplied prior to 25th May 2018 adhered to the Data Protection Act (DPA) and future data collection and research will confirm to GDPR.
If an individual has requested to be removed from the Metropolis leads database then that individual will no longer appear. We advise all of our clients to extract and use the Metropolis leads data as soon as possible. If you have added our data into your CRM it will be your responsibility to update the records you hold.
The data we supply to you remains the same. If you have processed our data and imported it into your CRM database or equivalent, under GDPR this means that you become the data controller. It is therefore your responsibility to comply with GDPR with regards to the data that you already hold.
Consent gained before 25th May 2018 has been obtained under the Data Protection Act 1998 and we will be refreshing our consent with those industry professionals employed by corporate bodies named in Metropolis leads as an ongoing process.
Most of the personal data we process about you as a client comes directly from you, for example
When we provide you with the Metropolis service
When you enquire about the Metropolis service through our website, by email or by phone.
As we manage our business relationship with you.
When we process your payment
We will contact you through email, mobile phone, websites notices, and other ways through our services. We will send you messages about the availability of our Services, security, or other service-related issues.
Metropolis Property Research Limited keeps its direct marketing to a reasonable level and we will only send you emails which are relevant to our service or which we believe will be of interest to you. You can request us to stop sending you emails at any time.
You are not bound by any contractual or statutory obligation to provide personal data to us. However, if you choose to enter into a contract with us then we will need certain information for the purposes of entering into and performing that contract (which may include personal data) and we may not be able to conclude a contract with you without that information.
• require Metropolis Property Research to change incorrect or incomplete data.
• require Metropolis Property Research to delete or stop processing your data.
• object to the processing of your data where Metropolis Property Research is relying on its legitimate interests as the legal ground for processing.
• access and obtain a copy of your data on request.
As a data subject, you have the following rights: