Miller Inventory Services Ltd, Policies and Procedures
- Miller Inventory Services Ltd (MISL) is a firm carrying out inventory work in the residential lettings business.
- The Information Commissioner’s Office (ICO) has said that since such firms are engaged or commissioned by others to carry out agreed work, they are not controllers of personal data but processors.
- The deliverable items from the work are reports that are submitted to the other interested parties. The reports are the copyright of MISL.
- The other interested parties are landlords, agents, tenants, and relocation agents.
- Inventory clerks (clerks) carrying out the work may be employees, sub-contracted self employed sole traders, or other sub-contracted inventory firms.
- Sole traders appear not to be referred to in the legislation.
- MISL and the clerks are not a party to tenancy agreements and do not have sight of them.
- Names and contact details are data required by MISL and the clerks to carry out the work and produce the reports.
- No personal data are collected from or even available from the MISL web site that is hosted by a third party.
- MISL shall comply with the General Data Protection Regulation legislation.
- A member of MISL staff shall be designated the Data Protection Officer (DPO). The DPO shall report data protection breaches to the ICO as specified in the legislation.
- The DPO shall, from time to time, but not less than annually, carry out an audit of data protection throughout MISL and its sub-contractors. The audit can be done as a rolling programme.
- The policies and procedures shall be reviewed every 3 years or when the legislation is changed, whichever is earlier.
- Sub-contract clerks or inventory firms, or MISL employees and the web hosting firm must comply at all times with the policies and procedures in force at any given time.
- MISL has and will maintain a contact form on the web site in order to receive messages, requests, or other information from interested parties. Information received in this way will be used for the purpose of carrying out business, and for no other purpose.
- MISL will not, for the time being, collect other personal data from visitors to the web site. Should the policy be changed this document will be amended accordingly.
- Similarly, messages, requests, or other information received by telephone, E-mail, or post will be used for the purpose of carrying out the business, and for no other purpose.
- Job requests, bookings, and background documents supplied by interested parties shall be stored safely and securely. Dropbox is currently used.
- Documents shared with clerks shall be held securely in a similar fashion and the means of protection be auditable.
- Reports will be held or archived in a similar secure manner, indefinitely. The are the property of MISL, and they may be required far into the future in the case of disputes between other parties, or the loss of documents previously submitted to them.
- If an individual (usually a tenant or former tenant but excluding former employees or sub-contract clerks) unreasonably demands sight of all documents where their name or contact details appear they can, under GDPR be refused or charged for the service.
- If an individual (except former employees or sub-contract clerks) requires that all records and reports where their name or contact details appear they will be refused in order to maintain policy 11 above.
- MISL shall maintain data held on employees and sub-contract clerks securely according to the legislation.
- MISL will release data held on individuals in compliance with the needs of public bodies investigating potential criminal or other unlawful activity.
- Any enquiry or request for quotation or request for service from an agreed price list shall be entered on a booking or quotation system.
- The information needs to include where, when, gaining access how, and meeting who (if anyone).
- Necessary contact information on anyone being met at the property shall be entered.
- Acknowledgement or a quotation shall be sent to the party requesting the service with the information provided in the quotation/booking form which will be attached to an E-mail in PDF format.
- The selected clerk will receive the same information with associated background documents where appropriate.
- A back-up copy of the form shall be stored on Dropbox.
- At the time of carrying out the work, the clerk will ask a tenant (if present) for a signature, and confirmation of contact details including forwarding postal address if the tenant is being checked out. The tenant may refuse, and the fact will be noted.
- Once proof read and complete, the report will be circulated according to instructions. This will most commonly be to an agent or landlord who then controls who else receives it.
- The report shall be stored on Dropbox.
- On conversion of the quotation/booking form to an invoice it will be automatically deleted.
- Clerks shall not contact tenants or landlords directly by phone, text, or E-mail.
- Clerks may contact agents if it is thought likely that keys may not be available (eg out with another contractor), or if tenants do not show up for the appointment. Communication via MISL is preferred, and in any case the MISL office must be informed.
- Communication with any of the interested parties must be via MISL, even if the clerk is somewhat late or early.
- The phone number and name of a clerk may have to be given to an agent when collecting keys or if funds have not yet cleared, but may clear, to allow possession of a property by an incoming tenant. For other purposes a clerk must advise an interested party to communicate via MISL.