Clifford Sinclair Ltd. GDPR Privacy Notice

At Clifford Sinclair Limited (Clifford Sinclair), we are committed to protecting the privacy and security of your personal information. Our privacy policy, together with our terms and conditions of use, explains our commitment to data protection and the use of your information in providing you with the services and information you require. For the purposes of the Personal Data (Privacy) Ordinance of Hong Kong (the “Ordinance”) and or the EU’s General Data Protection Regulations (The “Acts”) (both as amended from time to time) our data controller can be contacted at

It applies to all tenants, applicants for tenancy and former tenants renting property from Clifford Sinclair.

Clifford Sinclair is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under the GDPR to notify you of the information contained in this privacy notice.

In general, we use your personal information to comply with the law, carry out our obligations to you and to ensure you are and remain a suitable tenant able to fulfil your obligations to us.

It is important that you read this notice so that you are aware of how and why we are using such information.


We will comply with data protection law. This says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.

  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

  3. Relevant to the purposes we have told you about and limited only to those purposes.

  4. Accurate and kept up to date.

  5. Kept only as long as necessary for the purposes we have told you about.

  6. Kept securely.


Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We will collect, store, copy and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.

  • Passport details and date of birth.

  • Gender.

  • Marital status, number and age of dependants.

  • Next of kin and emergency contact information.

  • Bank account details, financial history, credit history, CCJs against you.

  • Salary, National Insurance number or equivalent

  • Employment status, visa or other proof of right to reside in the UK, and employer reference

  • Location of employment or workplace.

  • Previous tenancy details and landlord reference

  • Educational details if you are a student and student card

  • Photographs / Video and CCTV footage obtained through electronic means when on our premises.


We collect personal information about tenants and applicants through the application and contracting process, directly from tenants and applicants of indirectly from background check/reference provider.

We may collect additional personal information in the course of your tenancy.


We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  1. Where we need to perform the contract we have entered into with you.

  2. Where we need to comply with a legal obligation.

  3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

  1. Where we need to protect your interests (or someone else’s interests).

  2. Where it is needed in the public interest or for official purposes.


We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with our legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

  • Assessing your suitability and deciding about your application.

  • Determining the terms on which you rent from us.

  • Checking you are legally entitled to reside in the UK to comply with UK legislation including the Government’s “Right to Rent” guide

  • Receiving your rent and deposit.

  • Administering the contract we have entered into with you.

  • Business management and planning, including accounting and auditing.

  • Making decisions about your continuing as a tenant when your tenancy expires.

  • Making arrangements for the termination of your tenancy.

  • Dealing with legal disputes involving you, including accidents at your leased premises.

  • Complying with health and safety obligations.

  • To prevent fraud.

  • To conduct data analytics studies to review and better understand tenancy retention and attrition rates.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.


If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you or we may be prevented from complying with our legal obligations (such as to ensure your right to reside in the UK.


We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law.

We do not anticipate transferring your personal information outside the EEA. If we do, it will be done in line with the GDPR.


We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. “Third parties” includes third-party service providers and other bodies such as utility companies or agents, local authorities and deposit protection companies.


All our third-party service providers are either requested to take appropriate security measures in line with our policies or have their own obligations to protect your personal information. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.


We may need to share your personal information with a regulator or to otherwise comply with the law.


We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties are asked to only process your personal information on our instructions, to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.



We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.


We will retain your data for up to 30 days from our notifying you that your application has been unsuccessful. We will securely destroy all your personal information to comply with the GDPR.


Except as explained below, once you are no longer a tenant we will keep your personal information for 6 years to comply with statutory retention requirements then we will securely destroy your personal information to comply with the GDPR.

However, if you are a former tenant whose details remain on an existing lease we will keep your contact information for longer than 6 years while the lease in which you had entered into remains in place between us and replacement tenant(s). Once the lease of which you were a tenant expires we will securely destroy your contact information to comply with the GDPR.



It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during our relationship.


Under certain circumstances, by law, you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.

  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.

  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data or request that we transfer a copy of your personal information to another party, please email the


You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.


We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.


In the limited circumstances where you may have previously provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another lawful basis for doing so.

IP addresses and cookies:

Clifford Sinclair wants to provide online services that are easy to use, useful and reliable. This can involve placing small amounts of information on your computer or mobile phone or other device. These include small files known as cookies, Clifford Sinclair may also collect the following information where available, information about your computer, your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers.

Cookies and the information we collect cannot be used to identify you personally.

These pieces of information are used to improve services for you through, for example:

  1. Enabling a service to recognise your device so you don’t have to give the same information several times during one task;

  2. Measuring how many people are using services, so they can be made easier to use and there’s enough capacity to ensure they are fast; and

  3. Analysing data to help us understand how you use our services so we can improve them.

Google Analytics:

By understanding how people use, Clifford Sinclair can improve the information provided. This also ensures that the service is available when you want it and fast. Clifford Sinclair use Google Analytics for gathering this data, here is a breakdown of what these cookies are:

Name: _utma

Typical content: randomly generated number

Expires: 2 years

Name: _utmb

Typical content: randomly generated number

Expires: 30 minutes

Name: _utmc

Typical content: randomly generated number

Expires: when user exits browser

Name: _utmz

Typical content: randomly generated number and information about how the page was reached (eg directly or via a link, organic search or paid search)

Expires: 6 months

Name: __utmmobile

Typical content: randomly generated number

Expires: 2 years

For further details on the cookies set by Google Analytics, see the link below.

Cookies set by Google Analytics

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to


Prasun Bhaumik, Company Information Officer, will oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the or Prasun Bhaumik.


We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact the legal team ( or the Company Information Officer, Prasun Bhaumik.