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Privacy notice tenants
This Privacy Notice also known as Fair Processing Notice explains what information we collect, when we collect it and how we use it.
During 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. The purpose of this notice is to make you aware of how we will handle your information.
Who are we?
Albyn Housing Society Ltd a Scottish Charity (Scottish Charity Number SC027123), a registered society under the Co-operative and Community Benefit Societies Act 2014 with Registered Number SP1776RS and having their Registered Office at 98-104 High Street, Invergordon, IV18 0DL (“we” or “us”) take the issue of security and the data protection Act 2018 (“the 2018Act”) and the General Data Protection Regulation (EU) 2016/679 (“GDPR”) together with any domestic laws subsequently enacted seriously.
We are registered as a Data Controller with the Office of the Information Commissioner (ICO) under registration number Z641878X and we are the Data Controller of any personal data that you provide to us.
Our Acting Data Protection Officer is Maureen McDonald-Cooke, Maureen.firstname.lastname@example.org Any questions relating to this notice and our privacy practices should be sent to email@example.com
The information we require from you, under the terms of your Tenancy Agreement, includes:
- Your full name (and proof of your identity/photo ID)
- Your date of birth
- Your contact details (phone, email and correspondence address)
- Your National Insurance Number
- Basic details (name and date of birth) of all household residents including any children
- Your banking details if you pay by Direct Debit
- Proof of housing eligibility, any interest or equity in other property from 2019
- Other personal information that will vary on a case by case basis to help us resolve breach of tenancy, alleged anti-social behaviour or fraud, rent arrears, etc.
- Next of kin details and employment details.
- Equality, disabilities or vulnerabilities. We use this information to tailor our service to better meet your particular circumstances and needs. We may use this information for safeguarding of staff
- Financial information. We may use this to help customers make a decision around affordability and resolve any housing debt/arrears and provide welfare benefits, fuel and debt advice as a free service to help customers budget and pay bills. We may use this to apply for funding on a customer’s behalf
- Your complaints history, and;
- Health information- when we require this to make decisions on the property type customers may require and support funding for adaptations made to the property a customer is living in. More specific details are provided if you use this service
We collect your personal information from you via a variety of sources, including when you apply for one of our properties or services, complete one of our forms, when you call, write, email or meet with us or respond to a survey. We may collect information when you use our social media sites, websites or self-service portal or when you apply to become a member.
Our landline phone calls to our Customer Service Teams and to our Debt recovery Team are recorded for training and monitoring purposes and our recordings are usually held for a period of six months.
We operate a CCTV system at our office premises and at various locations within the vicinity of our properties for the detection and prevention of crime, to fulfil our legal obligations to keep our staff safe and in pursuit of or legitimate basis to keep our properties safe and secure. Our CCTV cameras operate continuously, and recordings are held for one month.
From time to time we may operate CCTV/sound recording and/or use photography to capture evidence of breach of tenancy, alleged anti-social behaviour or crime.
If you are in a property that operates a key fob door entry system, we may monitor use of any key fobs provided in order to keep our properties safe and secure. This information is retained for four weeks.
We may also take photographs and video footage at events we organise or take part in, and all properties in our communities to use for general marketing and publicity. However, photographs of individuals will only be used for those purposes with your consent. We may receive information about you from third parties including but not restricted to:
- Your local council or benefits office relating to your entitlements to benefits
- Reports as to the conduct or condition of your tenancy, including references from previous tenancies, and complaints of anti-social behaviour from prior landlords or agencies when you pply for housing.
- Complaints or other communications regarding behaviour or other alleged breaches of the terms of your contract with us, including from Police Scotland, your GP/health workers and welfare or support organisations dealing with you
- Any communications from Solicitors, Councillors, MP’s other representations acting on your behalf/instruction
- Financial institutions when you apply for our services
We need to collect your personal information to undertake and perform our obligations and duties to you in accordance with the terms of our contract with you. This may include:
- Receiving rent and service charges including arrears
- Providing a repairs and maintenance service
- Resolving anti-social behaviour disputes and investigating complaints
- Processing requests from third parties for example Council Tax
- Monitoring and reporting performance to regulatory bodied
- To comply with any legal obligations, we are subject to
- Providing factoring services, if applicable
- For any other purpose consistent with the proper performance of your Tenancy Agreement
- Deliver our Investment Programme
- Pursue any debts owed to us
- Offer welfare benefits advice
- Offer support services to you and those living with you; provide education, employment and training advice, and opportunities
- Target customers impacted by welfare reform
- Issue communications to you regarding Housing Services, including letters, newsletters, emails and texts
- Offer you access to our content’s insurance scheme
- Undertake research and statistical analysis to help improve our business processes and the services offered to our customers, as well as to evaluate our performance against other benchmarks. Where possible, statistical information is anonymised or pseudonymised
- Carry out customer segmentation research to allow us to better understand our customers characteristics and prioritise, tailor and target services in order to gauge satisfaction and make improvements based on feedback. To comply with equality monitoring systems
We offer a number of additional voluntary services to our tenants including organising community events, for safety visits, providing debt advice and adapting the property you live in.
For these voluntary services, where your personal information is needed, we will always notify you about the service being offered, explain the service and obtain your consent to proceed, usually by way of a sign up/consent form for that service. For the additional voluntary services, much of the information contained in our privacy notice is still relevant, such as details about the Data Controller and the rights you have under the legislation, including the right to withdraw your consent and the right to complain.
We may ask you if we can process your personal information for additional purposes. For example, we may share your information with a language translation service if it is necessary to translate any information into or from a foreign language for you. Where we do so, we will provide you with an additional privacy notice with information on how we will use your information for these additional purposes.
We may disclose your information to other third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:
- To carry out emergency, responsive or planned repairs
- To provide a language translation service if it is necessary to translate any information into or from a foreign language for you
- To carry out research, survey and segmentation on our behalf to help us to improve the services we offer to you
- With our professional and legal advisors for the purposes of taking advice
- If we enter a joint venture with or merged with another business entity, your information may be disclosed to our new business partners or owners
- If we are investigating a complaint, information may be disclosed to Police Scotland, Local Authority departments, Scottish Fire & Rescue Service and others involved in any complaint, whether investigating the complaint or otherwise
- If we are updating tenancy details, your information may be disclosed to third parties (such as utility companies and the Local Authority)
- If we are investigating payments made or otherwise, your information may be disclosed to payment processors, Local Authority and the Department for Work and Pensions.
- If we are conducting a survey of our products and/or service, your information may be disclosed to third parties assisting in the compilation and analysis of the survey results
- We may be required to share personal information with statutory or regulatory authorities and organisations to comply with statutory obligations. Such organisations include Health and Social Care Partnerships, Homelessness Services, Health Services or Care and Support Organisations that we work with, Local Authorities, Government Departments and Agencies, with our Regulator and Auditors, with Utility Companies or with other Organisations and Agencies.
Our contractors are required to comply with data protection law and our own Data Sharing Agreements/Third Party Assurance Statements or data processing clauses within our contracts to ensure data is managed appropriately and for specified purposes. Unless we have a lawful basis for disclosure, we will not otherwise share, sell or distribute any of the information you provide to us without your consent. Your information will only be stored within the UK and EEA.
If information is transferred outside the UK or EEA we will ensure that there are adequate safeguards in place to protect information in accordance with this notice.
When you give us information, we take steps to make sure that your personal information is kept safe and secure. Your personal information is stored on our paper and IT filing systems which may be copied for testing, back up, archiving and disaster recovery purposes. Access to your information is limited to those who require it to provide services to you. All data is held within the UK and EEA.
If any of your personal information is transferred outwith the European Union or the European Economic Area by any of our contractors, we will ensure that there are adequate safeguards in place to protect personal information in accordance with the General Data Protection regulations and applicable UK Data Protection Legislation.
We will only keep your personal information for as long as necessary to provide you with housing and/or related services and to safeguard Albyn Housing Society Ltd in the event of any claims, complaints, litigation, enquiries or investigations during or following the termination of your tenancy. Unless you ask us not to, we will review and possibly delete your personal information where your tenancy has been terminated for seven years. We will keep certain personal information of members for longer in order to confirm how long you were a tenant. We need to do this in the event of a claim against Albyn Housing Society Ltd.
We have a data retention policy that sets out the periods for all information we hold about your tenancy. You can request a copy by contacting firstname.lastname@example.org
You have the right at any time:
- To request access to the personal information that we hold about you by making a Subject Access Request
If you believe that any of your personal information is inaccurate or incomplete, to request that we correct or complete your personal information:
- To request that we restrict the processing of your personal information for specific purposes
- To request that we delete your personal information
- Data portability
- Related to automated decision-making including profiling
To object to receiving any marketing communication from us on email@example.com
You should note that your rights under GDPR and 2018 Act are not absolute and are subject to qualification.
Our Privacy Notice is regularly kept up to date and this version was updated on 17th February 2020
If you remain unsatisfied after your complaint has been processed by us, you also have the right to complain to the Information Commissioner’s Office in relation to our use of your information. The Information Commissioner’s contact details are noted below:
The Information Commissioner’s office- Scotland
45 Melville Street, Edinburgh, EH3 7HL
Telephone 0303 123 1115
The accuracy of your information is important to us - please help us keep our records updated by informing us of any changes to your personal and contact details.