Tenant Privacy Notice
Our contact details
Controller: Westfield Europe Limited (WEL)
4th Floor
1 Ariel Way
London
W12 7SL
Last updated: 12 January 2024
How we use your personal data?
WEL is legally required to complete anti money laundering (AML) checks on all tenants. To complete this process, we have partnered with First AML, a leading provider in the sector. First AML will securely collect your identification documents, and any other relevant personal data from you, in order to verify your identity.
You can consult the First AML privacy notice here
Personal data included in the AML checks undertaken by First AML will also be stored securely on WEL’s internal systems.
We may share your personal data with auditors and with the AML regulator (HMRC) to enable them to check our compliance with anti money laundering regulations.
Your information will only be used for the purposes set out above. Your information will remain confidential and will not be shared outside of WEL without your consent.
Lawful basis
Our lawful basis under the UK General Data Protection Regulation for processing your personal data to undertake AML checks and to provide information to the AML regulator is that it is necessary for compliance with a legal obligation (Article 6(1)(c)).
Our lawful basis for processing your personal data for auditing purposes to check our compliance with AML obligations is legitimate interests (Article 6(1)(f)). It is in our legitimate interests to carry out checks from time to time to ensure that we are meeting our legal obligations.
How do we protect your data?
First AML is an ISO 27001 accredited provider and processes its data on AWS servers located in Dublin. Data processed on the First AML platform is end-to-end encrypted, both in transit and at rest.
Access to your data held on WEL systems is restricted to authorised employees and is held on a secure internal platform.
Your data protection rights
Your right of access - You have the right to ask us for copies of your personal information.
Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances, including where our lawful basis for processing is legitimate interests.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at dpo@urw.com complete the My Rights form if you wish to make a request in relation to any of the above rights.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at dpo@urw.com
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
