Who we are
Our website address is: https://www.norwich.co.ke.
What personal data we collect and why we collect it on the website
Comments
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Media
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Contact forms
Cookies
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Analytics
Who we share your data with
All data collected by the website is solely for internal organizational use and reports.
How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Where we send your data
Visitor comments may be checked through an automated spam detection service.
Your contact information
Data handling Policy
In accordance to the The Data Protection (Complaints Handling Procedure and Enforcement) Regulations, 2021, by signing and submitting this Lease: –
- The tenant consents to the landlord holding their information for the duration of this lease and in the period of possible review for renewal;
- The tenant consents to the landlord using and sharing their information with reference to clause 4 so as to effect actions of recovery of payables under this lease;
- The tenant consents to the landlord sharing their information with their attached service providers and relevant processes to the landlord with relevance to the execution and operation of this lease while using the allocated space as per the stated terms herein. This includes but is not limited to the landlord’s legal team, site personnel, property manager, auctioneers, and debt collectors;
- The tenant has a right to have their data entries filtered for sharing in order of relevance to the contractual obligations by the landlord;
- The tenant consents to the landlord periodically reviewing their data where relevant to ensure it is up to date and relevant to the contractual obligations;
- The tenant may raise concerns emanating from the handling of the information held for corrective measures in an agreed format where reasonable cause is identified. The landlord may implement these corrective measures;
- For client support, kindly emails info@norwich.co.ke; for complaints and concerns, kindly email transparency@norwich.co.ke
Whistle Blowing Policy
The landlord, is committed to promoting and maintaining good corporate governance. In this regard, a Whistle Blowing Policy is in place to provide for protection to individuals who report misconduct and other concerns without the fear of retaliation.
The policy enables the landlord to investigate misconduct by their Board members, managers, staff, or service providers where the tenant believes there: –
- Is a breach of, or failure to implement, or non-compliance with, the organization’s governing rules, procedures, policies, or established standards of practice e.g. accounting; procurement; human resources; or
- Is illegal or unlawful conduct (e.g. fraud, corruption); or
- Is unethical or inconsistent with the standards the landlord’s organization subscribes to; or
- Is, or will result, in a waste of the landlord’s resources or pose a risk to the landlord’s reputation and integrity; or
- Are dangerous practices likely to cause physical harm or damage to a person or to property of the landlord and tenant as per the terms of this lease; or
- Is abuse of power or authority for any unauthorized or ulterior purpose; or Represents a conflict of interest; or
- Is an attempt to cover up any of the above types of actions.
The tenant may: –
- Submit concerns to the landlord’s Whistle-blower email address: transparency@norwich.co.ke;
- Choose to identify themselves when reporting concerns to assist in the investigation of matters being raised; or
- Choose to remain anonymous. Anonymous reports, however, will require careful scrutiny as to whether or not they merit further action or escalation based on the evidence presented by the report and the seriousness of the allegation.
The landlord recognizes the right of the whistle-blower to have the issues raised be properly addressed and thus commits to: –
- Give feedback as is appropriate under the circumstances, and subject to legal constraints;
- Inform on the final outcome of the process.
- Respect, protect, and keep confidential the identities of individuals who make whistle-blower reports,
- Ensure that there is no retaliation against the whistle-blower.
- Treat violations of section i & ii as violations subject to disciplinary action set out by the landlord.If a situation arises where the matter cannot be resolved without revealing the whistle-blower’s identity, the landlord will first discuss with him/her whether, and how best, to proceed with due respect of their consent.
Client Data Privacy and Security Policy
At Norwich Union Properties Ltd, we take the privacy and security of our clients’ information very seriously. While we do not store actual client data on our website, we have implemented strict measures to ensure the safety of any client information we handle, whether it is digital or in hard-copy form.
1. Anonymized Digital Information
Our website does not store identifiable client data. Any information related to our clients that appears on our website is highly anonymized, meaning it cannot be traced back to individual clients. This ensures that even in the unlikely event of a data breach, your personal information remains secure and uncompromised.
2. Secure Handling of Hard-Copy Documents
We recognize that some client data is maintained in hard-copy form within our office. To protect this information, we have implemented robust physical security measures, including:
- Restricted Access: Only authorized personnel have access to areas where client documents are stored.
- Secure Storage: Hard-copy documents are stored in locked, fireproof cabinets within secure office spaces.
- Regular Audits: We conduct regular audits of our document storage procedures to ensure compliance with our security protocols.
3. Response to Physical Security Breach
In the unlikely event of a physical security breach that could compromise hard-copy client data, we will act swiftly to:
- Investigate the Incident: We will immediately investigate the breach to understand its scope and impact.
- Notify Affected Clients: We will promptly notify any clients whose information may have been compromised, providing details of the breach and any potential risks.
- Implement Corrective Actions: We will take all necessary steps to secure the affected data, prevent further breaches, and enhance our security measures.
- Provide Guidance and Support: We will offer guidance on steps clients can take to protect themselves, and provide support throughout the resolution process.
4. Regulatory Compliance and Transparency
We are committed to complying with all applicable data protection laws and regulations. In the event of a security breach, we will notify the relevant regulatory authorities as required. We believe in transparency and will keep our clients informed throughout the investigation and resolution process.
5. Ongoing Commitment to Security
The security of your information is our top priority. We continually review and update our data protection practices to adapt to evolving threats and ensure the highest standards of client data security.
Third-party data
The website receives from Meta and Google through their analytics and tracking platforms.
If you have any questions or concerns about how your information is handled, please do not hesitate to contact us at transparency@norwich.co.ke.
Norwich Union Properties Ltd is dedicated to safeguarding your privacy and ensuring the security of your personal information, whether in digital or physical form.