Our Policies

Access Accommodation is an Aparthotel that offers extended stay studio rooms and we process the personal data of our guests.

This policy sets out our commitment to ensuring that any personal data which we process is carried out in compliance with Data Protection Law (Data Protection Act 1998, the General Data Protection Regulation 2016/679 and all relative European Union and Member State data protection legislation in force and as amended or replaced from time to time). We are committed to ensuring that good data protection practice is embedded in the culture of our staff and our organisation. Access Accommodation’s other policies and procedures are listed below:

• Data Retention Policy
• Data Subject Rights Policy
• Breach Notification Policy
• Data Protection Impact Assessment Policy

This policy applies to all personal data processed by us and is part of our approach to compliance with Data Protection Law. All of our staff are expected to comply with this policy.

Access Accommodation confirms that it complies with the following data protection principles and undertakes to ensure that when it processes personal data:

• it is processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
• it is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; (‘purpose limitation’)
• It is all adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed; (‘data minimisation’)
• it is all accurate and, where necessary, kept up to date and that reasonable steps will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’)
• it is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; (‘storage limitation’)
• it is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

Access Accommodation is committed to facilitating and complying with any request from a data subject who wishes to exercise their rights under Data Protection Law in a transparent manner and without undue delay.

We will not transfer any personal data to a country outside the EU or an international organisation without ensuring the level of protection provided by Data Protection Law is not undermined.

We will:

• only collect and process personal data that it is necessary for the purpose or purposes that we have identified in advance;
• ensure that the legal basis for processing personal data is identified in advance;
• ensure that as far as possible the personal data we hold is accurate;
• only process your data for as long as is it required for our purposes and then we will

securely dispose of, or delete your personal data after you check out of our property;

• not do anything with your data that you would not expect given the content of this policy and our privacy notice; and
• ensure that appropriate security arrangements are in place in relation to the personal data it holds.

We will ensure that all staff who handle personal data are aware of their responsibilities under this policy and other relevant data protection and information security policies and that they are adequately trained, supervised and monitored.

Access Accommodation will ensure that it has procedures in place to allow data subjects to exercise the following data subject rights under the GDPR. For further information please see our Data Subject Rights Policy:

Subject access: the right to request information about how personal data is being processed including whether personal data is being processed and the right to be allowed access to that data and to be provided with a copy of that data along with the right to obtain the following information:

• the purpose of the processing;
• the categories of personal data;
• the recipients to whom data has been disclosed or which will be disclosed;
• the retention period;
• the right to lodge a complaint with the ICO;
• the source of the information if not collected direct from the subject; and
• the existence of any automated decision making.

Rectification: the right to have us rectify inaccurate personal data concerning you without undue delay.

Erasure: the right to have data erased in certain circumstances, and to have confirmation of erasure, but only where:

• the data is no longer necessary in relation to the purpose for which it was collected;
• where consent is withdrawn;
• where there is no legal basis for the processing; or
• there is a legal obligation to delete data.

Restriction of processing: the right to ask for certain processing to be restricted in the following circumstances:

• if you contest the accuracy of your personal data;
• if our processing is unlawful but you do not want it to be erased;
• if we no longer need the data for the purpose of the processing but it is required by you

for the establishment, exercise or defence of legal claims; or

• if you have objected to the processing, pending verification of that objection.

Data portability: you have the right to receive a copy of the personal data you have provided to us and certain information generated by us, if our processing is carried by automated means, which will allow you to transfer it to another data controller. This only applies if our legal basis for processing is consent or under a contract.

Object to processing:

you have the right to object, on grounds relating to your particular situation, to the following:

• processing carried out in the public interest or in the exercise of official authority; or
• processing relying on the legitimate interests processing condition unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal

claims.

You have an absolute right to object to any direct marketing that we are sending to you and there are no exemptions to this which would allow you to refuse to comply.

Object to automated decision making: if we are making decisions about you based on automated processing which have a legal or similar effect on you, then in some circumstances you have the right to object to this decision being made solely on the basis of automated processing. This includes any profiling of you that we carry out.

You cannot exercise this right in the following circumstances when the processing is:

• necessary for entering into or the performance of a contract;
• authorised by law; or
• based on explicit consent.

Access Accommodation maintains a register of data breaches and all personal data breaches are recorded in this register which will be monitored. Action will be taken in relation to any issues identified in this register, particularly if any pattern of breaches is identified.

We will report personal data breaches which are likely to result in a risk to the rights and freedoms of the data subject to the Information Commissioner’s Office in compliance with our breach notification policy.

Access Accommodation will also communicate any personal data breach which is highly likely to result in a risk to the rights and freedoms of the data subject to the data subject or subjects involved in compliance with our Breach Notification Policy.

If you have any concerns or wish to exercise any of your rights under the GDPR then you can contact our data protection lead in the following ways:

WhatsApp: +44 1382 450772
Email: admin@accessaccommodation.online

Fire alarm for the building is tested every Friday at round 9am, you will hear a siren which goes off after few seconds, it is a testing sound for our alarm panel so no action will be needed. Any alarm sound you hear beyond this time, or it continues to sound, please close the door to the affected room if possible, operate the nearest break glass point and leave the building by the nearest exit point and go to the assembling into car park and inform us via our business WhatsApp +44 1382 450772 and call 999 for fire service. Please do NOT return to your room to collect your personal belongings. Please inform us at the date of check in if you require our assistance during evacuation in case of fire.

During your stay with us, although we carry out regular checks on fire exits and fire doors, as a fire safety measure, we require our guests to ensure at ANY time that all fire exits are kept clear and free from clutter and hazards, and fire doors are not wedged open or obstructed.

Please note there is a strictly no smoking ( including electric cigarettes ) policy in the entire building. There is a fine of up to £250 for violating this policy. Please ensure if you have to spray aerosols it is pointed downwards and away from the smoke detectors and strictly no candles in your rooms.

Please do not use portable plug-in electric heaters at any time as they are strictly not allowed. There is a fine of up to £250 for violating this policy. Strictly no use of cooking equipment other than our own equipment provided within your room. There is a fine of up to £250 for violating this policy. During and after cooking please make sure nothing is covering the hob when it is still hot. Please NEVER leave the hob on unattended whilst cooking.

You are responsible for ensuring that your usernames, passwords and login details for any internet service or equipment remain confidential so that the network cannot be used by any unauthorised person including, but not limited to, those controlling access to;

(a) any computer hardware systems or networks
(b) any computer software or applications
(c) any other services accessed by you in the use of either of the above.

You shall not disclose these credentials to any third party or use the same for any purpose connected with the improper use of the network including accessing or attempting to access other parts of the services for which you do not have access rights.

You are responsible for taking all reasonable steps necessary to prevent a third party obtaining access to the network. You must immediately advise us if you become aware of any violation or suspected violation of these security provisions. You are responsible for all uses made of the internet through your account (whether authorised or unauthorised) and for any breach of this policy whether an unacceptable use occurs or is attempted, whether you knew or should have known about it, whether or not you carried out or attempted the unacceptable use alone, contributed to or acted with others or allowed any unacceptable use to occur by omission.

You agree that neither Access Accommodation nor the broadband provider are responsible for any of your activities in using our network. Although the internet is designed to appeal to a broad audience, it’s your responsibility to determine whether any of the content accessed via the broadband service is appropriate to view or use.

1. Granting access to your broadband service to others not specifically authorised by you.

2. Activities that invade another’s privacy, cause annoyance, inconvenience or needless anxiety to any person.

3. Sending, receiving, publishing, posting, distributing, disseminating, encouraging the receipt of, uploading, downloading, recording, reviewing, streaming or using any material which is offensive, abusive, defamatory, indecent, obscene, unlawful, harassing or menacing or a breach of the copyright, trademark, intellectual property, confidence, privacy or any other rights of any person. Unlawful, fraudulent, criminal or otherwise illegal activities.

4. Knowingly or negligently transmitting or uploading any electronic material (including, without limit, files that contain viruses, corrupted files, or any other similar software or programmes) which is known or likely to cause, interrupt, damage, destroy or limit the functionality of any computer software, hardware or telecommunications equipment owned by Bills Paid Ltd and/or the utility provider or any other internet user or person.

5. Anything that may disrupt or interfere with the network or services or cause a host or the network to crash.

6. Launching “denial of service” attacks; “mail bombing” attacks; or “flooding” attacks against a host or network.

7. Circumventing the user authentication or security process of a host or network.

8. Creating, transmitting, storing or publishing any virus, Trojan, corrupting programme or

corrupted data.

9. Activities that are in breach of any other third party’s rights, including downloading, installation or distribution of pirated software or other inappropriately licensed software, deletion of any author attributions, legal notices or proprietary designations or labels in any file that is uploaded, falsification of the origin or source of any software or other material.

1. We do not recommend in particular the use if any websites (or other internet related services) (“internet services”) and your use of Internet Services is carried out entirely at your own risk.

2. We have no responsibility for, or control over, the Internet Services you access and do not guarantee that any services are error or virus free,

3. We have no responsibility for, or control over, the information you transmit or receive via the Service.

4. Save for the purpose of the network diagnostics we do examine the use to which you put the Service but do not examine the nature of the information you send of receive.

1. The availability of the Service;

2. The speed at which information may be transmitted or received via the Service; or

3. That the Service will be compatible with equipment or any software which you use.

4. Whilst we take responsible steps to ensure the security of the Service and to prevent

unlawful access to information transmitted or received using the Service, we do not guarantee the security of the information which you may transmit or receive using the Service or located on any equipment utilizing the Service and you accept that it is your responsibility to protect your information and have adequate security (in terms of equipment and procedures) to ensure the security, integrity and confidentiality of your information and data.

5. We reserve the right at all times to withdraw the Service, change the specifications or manner of use of the Service, to change access codes, usernames, passwords or other security information necessary to access the service.

You must not use the Service to access Internet Services, or send or receive e-mails, which;

1. Are defamatory, threatening, intimidatory or which could be classed as harassment;

2. Contain obscene, profane or abusive language or material;

3. Contain pornographic material (that is text, pictures, films, video clips of a sexually explicit or arousing nature);

4. Contain offensive or derogatory images regarding sex, race, religion, colour, origin, age, physical or mental disability, medical condition or sexual orientation;

5. Contain material which infringe third party’s rights (including intellectual property rights);

6. In our reasonable opinion may adversely affect the manner in which we carry out our

business; or

7. Are otherwise unlawful or inappropriate;

8. Music, video, pictures, text and other content on the internet are copyright works and

you should not download, alter, e-mail or otherwise use such content unless certain that

the owner of such works has authorized its use by you.

9. We may terminate or temporarily suspend the Service if we reasonably believe that you

are in breach of any provisions of this agreement including but not limited to the clauses above

10. We recommend that you do not use the service to transmit or receive any confidential information or data and should you choose to do so you do so at your own risk.

11. The Service is intended for consumer use only.

1. You must not use the Service to engage in any activity which constitutes or is capable of constituting a criminal offence, either in the United Kingdom or in ant state throughout the world.

2. You agree and acknowledge that we may be required to provide assistance and information to law enforcement, governmental agencies and other authorities.

3. You agree and acknowledge that we may keep a log of the internet Protocol (‘IP’)address of any devices which access the Service, the times when they have accessed the Service and the activity associated with that IP address.

4. You further agree we are entitled to cooperate with law enforcement authorized and rights-holders in the investigation of ant suspected of alleged illegal activity by you which may include, but is not limited to, disclosure of such information as we have (whether pursuant to clause 3.3 or otherwise), and are entitled to provide by law, to law enforcement authorities or rights-holders.

Our prices do include include utility bills under fair and reasonable usage. We do apply the fair usage policy which takes effect from the day you check in with us. This is to ensure that the energy usage is not excessive and kept within reasonable limits.

Our Fair Usage Policy is based around an average contribution per week per guest for gas and electricity being used within the property. The allowances is currently set at £40 per guest per week. We calculate each week’s usage based on average usage each guest for that week, with sensible usage, you are unlikely to exceed these. We reserve the right to apply a charge to cover the amount by which exceed the allowances. There is no additional administration charges.

We kindly ask you to turn off any electrical appliance when not in use and turn off the heating if and when you leave your studio for a length of time.