Privacy policy

  1. About this document:
    1. Island Development Limited (a non-cellular company limited by shares with Guernsey registration number 545) (“IDL”, “we”, “us”, “our”) provides rented accommodation to its tenants.
    2. During the course of our activities we will process personal data (which may be held on paper, electronically, or otherwise) about you and we recognise the need to treat it in an appropriate and lawful manner in accordance with the DP Law.
    3. For the purposes of the DP Law, we are the data controller in respect of the personal information (as defined under paragraph 2.1 below) we process in accordance with the terms of the Lease. We will share your personal information with our Affiliate, Tudor Estates Limited (Guernsey Registered number: 538) (“TEL”), who will process your personal information on our behalf in its capacity as a joint data controller.
    4. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.
    5. Unless otherwise defined, capitalised terms used in this Privacy Statement shall have the same meaning given to them under the Lease.
    6. This Privacy Statement does not form part of the Lease and we may amend it at any time in accordance with paragraph 11 herein.
  2. What personal information do we collect?
    1. For the purposes of this Lease, and as set out in this Privacy Statement, “personal information” includes the following categories of personal data:
      1. name, gender, date of birth, contact details (including telephone numbers, address and email address where applicable) (“Contact Details”) of each of the Tenants;
      2. name and Contact Details of each Tenant’s next of kin;
      3. name and Contact Details of each of Tenant’s referees;
      4. job status (including title and salary) and employment history;
      5. right to work/housing licence details;
      6. certain bank identification details (e.g. bank account number); and
      7. referee opinions/statements on the character of the Tenant.
    2. In certain limited situations we may be required to process personal information which constitutes “sensitive personal data” for the purposes of the DP Law, including personal information relating to the following categories:
      1. health (including any physical or mental health);
      2. racial or ethnic origin;
      3. political opinions;
      4. religious or other beliefs of a similarly nature;
      5. any proceedings for any offence committed or alleged to have been committed by the Tenant; and
      6. to the extent that this falls within the scope of “sensitive personal data”, any information relating to the commission or alleged commission of an offence (including criminal records or police charge which might affect a Tenant’s ability to stay in the property), (together referred to as “sensitive personal data”).
    3. We may collect personal information either direct from you, from third parties or publicly accessible sources (where relevant), and may capture video imagery as part of our protection and security of the Mon Plaisir site.
    4. By giving your personal information to us, you confirm that all information provided is, at any time, true, accurate and complete. Data that is inaccurate or out of date will be destroyed. Please notify us if your personal details change or if you become aware of any inaccuracies in the personal information we hold about you.
    5. You must not provide personal information about anyone else unless you have their permission to do so.
  3. Lawful Basis:
    1. We will ensure that the personal information fairly and lawfully processed in accordance with the DP Law, where the processing is necessary for the performance of the Lease (contractual necessity), or for the pursuance of IDL’s legitimate interests in order to properly provide the rented accommodation in accordance with the terms of the Lease.
    2. Subject to clause paragraph 2.2 above, in such circumstances, the Landlord shall ensure that it processes Sensitive Data on the basis of one or more of the following legal grounds:
      1. the Tenant has given his explicit consent to the processing of the personal information – such consent to be evidenced by way of a separate Consent Form; or
      2. one of the other purposes set out in Schedule 3 of the DP Law (as relevant).
  4. Specific Purpose:
    1. The processing of such personal information by us and/or the third parties set out in paragraph 5.2 (below) will be reasonably necessary for personnel, administrative, financial, regulatory, insurance, and other purposes related to or ancillary to the Lease and to ensure that you, as the Tenant, receives appropriate support by us to continue to enjoy the property throughout the duration of the Lease or as otherwise notified to you.
    2. To the extent that we process any personal information which exceeds the specified purposes set out in the Lease, we will seek your consent.
  5. Who will we share or disclose your personal information to?
    1. Save for the following paragraph 4.2, we will not disclose your personal information to a third party unless we are satisfied that they are legally entitled to the data or if it is required for the performance of the Lease. Where we do disclose your personal information to a third party, we will have regard to the data protection principles contained in the DP Law.
    2. Subject to paragraph 4.1 above, we may share your personal information to the following third parties:
      1. any Affiliate of the Landlord and their employees;
      2. professional advisors of the Landlord;
      3. any person or entity providing services to the Landlord and the Affiliates such as utility providers, domestic contractors, letting agents, credit or reference agencies, debt collection agencies or tracing agents and third party cloud service providers;
      4. the Guernsey Income Tax Office or other governmental or regulatory authority; and/or
      5. prospective purchasers of all or any part of the Landlord’s business.
  6. How long will we retain your personal information for?
    1. We will keep your personal information for as long as it is needed to conduct our business and meet our legislative requirements, or to answer requests for information from ongoing or impending statutory inquiries. This means that your personal information will be destroyed or erased from our systems when it is no longer required.
    2. For guidance on how long certain data is likely to be kept before being destroyed, please contact any officer of Island Development Ltd or Tudor Estates Ltd.
  7. Where do we store your personal information?
    1. The data that we collect from you may be transferred to, and stored at, a destination outside of the Bailiwick of Guernsey or the European Economic Area (“EEA”) for example the USA. It may also be processed by staff operating outside the EEA who work for us or for one of our agents.
    2. By submitting your personal information, you agree to this transfer, storing or processing of your personal information in such a jurisdiction. We will take all steps reasonably necessary to ensure that such territories provide an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of such data and that your personal information is treated securely in accordance with this Privacy Statement.
  8. Security
    1. We will ensure that appropriate measures are taken against unlawful or unauthorised processing of personal data and against the accidental loss of, or damage to, personal data.
    2. We have in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. We will only transfer personal data to a third party if he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself.
    3. Maintaining data security means guaranteeing the confidentiality, integrity and availability (for authorised purposes) of the personal data.
  9. What are your rights?
    1. You have the right to:
      1. request access to any personal data we hold about you;
      2. prevent the processing of your data for direct-marketing purposes;
      3. ask to have inaccurate data held about you amended;
      4. prevent processing that is likely to cause unwarranted substantial damage or distress to you or anyone else; and
      5. object to any decision that significantly affects you being taken solely by a computer or other automated process.
    2. If you wish to know what personal information we hold about you, you must make the request in writing.
    3. You can also exercise the right at any time by contacting any officer of Island Development Ltd or Tudor Estates Ltd. at
  10. How do you contact us?
    1. Questions, comments and requests regarding this privacy statement should be addressed to any officer of Island Development Ltd or Tudor Estates Ltd. at
    2. If you consider that the data protection principles have not been followed in respect of personal information about yourself or others please do not hesitate to get in touch using the details provided above. Any breach of the DP Law will be taken seriously.
    3. Alternatively, you may contact the Office of the Data Protection Commissioner in Guernsey at: By telephone: +44 (0) 1481 742074 By email: By post: The Office of the Data Protection Commissioner, Guernsey Information Centre North Esplanade, St Peter Port, Guernsey, GY1 2LQ.
  11. Changes to our Privacy Statement Any changes we make to our Privacy Statement in the future may be communicated to you by email or by post.

Privacy Statement last updated on 13/09/2023.