The introduction of the General Data Protection Regulations (GDPR) has required us to look afresh at our privacy notices and to reaffirm our commitment to protecting your personal data.
Suffolk Housing Society is the Data Controller for the purposes of the GDPR
The contact details are:
5 Greenwood Court
Bury St Edmunds
T: 01284 767224
Your privacy is important to us so we will never sell or disclose your personal information without your consent unless the law allows or requires us to do so.
As a Social Housing provider, our normal activities can be summarised as;
- Providing social and other types of housing
- Property and grounds maintenance, repair and improvement.
- Managing your housing, tenancy and rent/ service charge account as your landlord.
We also provide additional optional services including:
- Organising and assisting community events
- Offering opportunities to be involved (co-regulation)
- Adaptations made to properties we manage
- Selling properties
Our legal basis for processing personal information is contractual (either as a requirement or as a necessity to enter into a contract)
For some of our work we may also rely on your consent – see Consent – section below.
WHO THE PERSONAL INFORMATION RELATES TO+
We collect and hold information about:
This includes our current, former and potential customers who live in our properties or have access to our services and includes members of their family and people associated with them.
This will also include any visitors to our website and offices, those who email, call and write to us, including anyone who makes a complaint or enquiry to Suffolk Housing Society.
EMPLOYEES, BOARD MEMBERS AND SHAREHOLDERS
This includes current and former employees, Board members and shareholders.
HOW DO WE COLLECT PERSONAL INFORMATION+
We collect information in a variety of ways.
You can give us personal data by filling in forms provided by us, for example at the tenancy sign-up, taking part in research on our website or other social media functions on our website, promotion or survey or by corresponding with us by phone or email.
We also collect information through our ongoing contact and correspondence with you and other agencies which relate to you and from people associated with you such as family, friends and neighbours.
At some schemes and offices we have CCTV cameras to record events in public areas.
If you provide us with personal information relating to members of your family we will assume that you do so with their consent and knowledge.
While we will do our best to keep information about you as accurate and up to date as possible, it would help us to do this if you notify us of any changes to your personal information as soon as possible so that we can contact you easily.
WHAT INFORMATION DO WE HOLD ABOUT OUR CUSTOMERS+
We collect information about you from your housing application which you complete to register with the choice based lettings scheme and when we meet with you to view a property. We will hold and process your personal data to complete an application to begin the process of letting one of our properties to you. This is to ensure your suitability as a tenant and to demonstrate you have a right to rent.
Information we collect includes:
- full name
- current address
- contact number
- any disability or vulnerability
We use this information to tailor our service to better meet your needs. This may also include health conditions that we may have to factor in to carry out adaptations to the property.
We do ask to see proof of income at the viewing stage. This is to verify the property is affordable for you. We do not take copies of these documents.
When you become a tenant we will use the information collected during your application and from third parties such as other housing providers / private landlords, the police, probation service, support works, mental health workers, social works and credit reference agencies where appropriate to help us assess your application.
We generally require the following information from tenants:
- Full name including proof of your identity / photo ID
- Date of birth
- Contact details, including telephone, email or contact address
- Details of anyone authorised to act on your behalf if applicable
- Personal details of all household residents
- Banking details where you make payments to us
Other information may be collected in order to help us resolve breaches of tenancy, alleged anti – social behaviour or suspected fraud.
We may also need additional information from you concerning:
- Disabilities or vulnerabilities – we use this information to tailor our service to better meet your needs. We may also use this information for safeguarding of staff.
- Health information – we may require this to enable us to support you in managing your tenancy, or in organising adaptations to your home.
- Financial information – it is important that in order to ensure that arrears payments are settle quickly and therefore we may collect information to help us to work out a payment plan with you.
We will keep a record of your contact with us, whether by phone, email, in writing or in person. This may include CCTV images and noting any action taken as a result of your contact with us.
WHAT INFORMATION DO WE HOLD ABOUT OUR EMPLOYEES+
The personal data we process may include, but may not be limited to, the following:
- data relating to your identity (including name, date of birth, gender, photographs to be used for an identification badge and circulation to staff before employment commences, passport, National Insurance number, immigration status, marital status, dependents),
- contact details (business and home address, telephone numbers, email addresses, emergency & next of kin contact details),
- employment details (position, office location, terms of employment, performance and disciplinary records, sickness and holidays),
- background information (CV, previous experience, qualifications and certifications, criminal records check (for vetting purposes, where permissible and in accordance with applicable law),
- financial information (bank details, tax information, salary, benefits, pension expenses, vehicle details, car MOT and insurance status, driving licence details),
- IT information – information related to your access to our systems (login details, IP addresses, log files, access/times/durations of use, location).
CCTV AND PHOTOGRAPHS+
Some of our locations and offices have CCTV cameras and you may be recorded when you visit them. CCTV is used to provide security and protect both our visitors and communities. CCTV will only be viewed when necessary (eg to detect or prevent crime) and footage is stored for a set period of time, after which it is recorded over. Notices are displayed so you know when CCTV is used.
We may take photographs at our events, at our properties and in our communities for use in general marketing and publicity. However, photographs of individuals will only be used for those purposes with your consent.
A photo of you will be taken at the viewing stage, if you are successful this image will be retained, images taken of unsuccessful applicants are deleted. We do this so we can confirm who the tenancy holder is, and reduce any fraudulent actions such as sub letting the property.
HOW WE USE YOUR INFORMATION+
The information is used to assess your housing requirements with a view to offering you a tenancy. We may discuss your application with the local authority who have provided your application to us (through the choice based lettings scheme) as well as any agencies you have listed that can speak on your behalf on your application. These can be Support Workers, Social Workers, Mental Health workers, the Police, the Probation Service or other Housing providers/private landlords.
If you provide us with personal information relating to members of your family or your associates we will assume that you do so with their knowledge and their consent to the collection and processing of the information.
We are required to provide anonymised data to the government for every letting we make and this information is collected on a CORE form. You will be required to view the privacy notice for this form prior to our completing and submitting this data.
The information we hold is used to manage any contract we have with you, including:
- Managing tenancies including collecting rent and service charges
- Ensuring compliance with the conditions of any agreement between us
- Providing repairs, maintenance, improvements and adaptations at our properties
- Provide support for elderly and vulnerable customers
- Managing your direct debit payment
Provide you with services and benefits in both our legitimate interests, including ensuring the proper management of your tenancy and giving you appropriate support:
- Signposting help with debts and benefits advice
- Keeping in touch with customers to understand your needs and preferences and invite you to events
- Provide information about home contents insurance schemes
- Engage with customers to make improvements to our products and services.
Comply with our legal and regulatory obligations, and acting in the public interest, such as:
- Prevent and detect crime and resolve disputes
- Prevent and detect fraud and money laundering
- Promote safety and the quiet enjoyment of our neighbourhoods and communities
- Promote equal opportunities and fair treatment for all our customers
- Meeting the obligations we owe to our funders and regulators
Under the data protection legislation certain personal information is classified as “sensitive” or “special category” personal data. This includes information relating to racial or ethnic origin, physical or mental health, sex life or sexual orientation, religious or philosophical beliefs, political opinions, membership of a Trade Union, allegations of criminal offences and criminal convictions and offences, along with biometric data such as fingerprints.
We minimise our holding and use of sensitive categories of personal information but, given the services we provide there are times when we use it to understand our customers and their needs better, for example when providing accommodation for disabled persons or those with problems around substance abuse, when resolving neighbourhood disputes involving alleged criminal activity or when helping someone to access care services. We will usually be processing this information to allow us to comply with our legal obligations, act in the substantial public interest in relation to the services we provide, or to deal with any legal action. There may be times when we need to ask you for your consent to use this type of personal information, in which case we will always notify you and make this clear.
We use your information to ensure your rent account is conducted in the correct manner as laid out in the tenancy agreement (ie rent paid on time),
We may request your National Insurance number. This is because if you fall into arrears and are in receipt of benefits we can request third party deductions to go towards paying these. Also if you become a Universal Credit (UC) claimant we may request direct payments of both rent and arrears.
If you are a resident in sheltered accommodation we will complete a Personal Independence Plan with you annually where we will ask for information that will help us to support you. We will also ask for details of those who can act on your behalf such as Power of Attorney or Executor. If any of your information changes in between reviews of your Personal Independence Plan, you should let us know so that this information remains up to date.
SHARING YOUR INFORMATION+
We share information with local authorities who lie within our housing stock area and with the Department of Work and Pensions in connection with any housing cost awards (this can include the local authorities housing options teams if you are facing eviction or need to downsize).
We also share information with other agencies that a tenant has told us they have requested assistance from (and given consent for this to happen) in order to maintain the tenancy.
Part or all of your information may be passed to:
- Our maintenance contractors
- TV Licensing Authority
- Centra – Out of hours alarm call centre
- Housing Proactive
- Social Services
- Health Professionals
- Care or Support Agencies
Part or all of your sensitive personal information may be passed to:
- Centra – Out of hours alarm call centre (Sheltered Housing Residents only)
- Housing Proactive (Sheltered Housing Residents only)
- Social Services
- Health Professionals
- Care or Support Agencies
If you leave your tenancy owing us money the debt may be passed to a debt collection agency (the agency we currently use is Debt Collection Services UK Ltd) as per our rent policy. We would then supply them with the following information where we know it:-
- Your name,
- The address of the property you lived in
- All telephone numbers we have
- Your National Insurance number
- Your date of birth
- All email addresses we have
- Your forwarding address
- Your last known employer
- The amount of the outstanding debt
- Copies of any court orders or of any official paperwork we have in connection with the rent debt (including rent statements)
- Copies of any unpaid re-charge invoices included in the debt
- Your tenancy sequence number (a unique number we hold for each tenant)Where the tenancy was held jointly with someone else this information will be provided for each tenant.
We process personal data relating to those we employ to work as, or are otherwise engaged to work as, part of our workforce. We do this for employment purposes, to assist in the running of the business and/or to enable individuals to be paid and receive benefits provided by Suffolk Housing and third parties.
The collection of this information will benefit us by:
- improving the management of workforce data across the business,
- enabling development of a comprehensive picture of the workforce and how it is deployed,
- informing the development of recruitment and retention policies,
- allowing better financial modelling and planning,
- ensuring compliance with our policies and procedures and our legal obligations,
- enabling monitoring of selected protected characteristics.
We will not share information about you with third parties without your consent unless the law allows or our benefit providers require us to do so.
Under the data protection legislation you have the right to:
- object to processing of personal data that is likely to cause, or is causing, damage or distress,
- prevent processing for the purpose of direct marketing,
- object to decisions being taken by automated means,
- in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed,
- claim compensation for damages caused by a breach of the data protection legislation.
HOW WE KEEP YOUR INFORMATION SECURE+
All our employees undertake data protection training as part of their induction training when they start their employment with Suffolk Housing. Annual data protection training is a mandatory requirement to reinforce our information security and sharing policies.
All personal information is stored and managed in a variety of IT software systems within the organisation. Only those employees who need to have access to this information can access it.
We may also copy that information for use in testing systems, back up, archiving and disaster recovery.
Most of our data is stored within the UK or the European Union. Some organisations which provide services to us may transfer data outside the European Economic Area but we will only allow this if your data is adequately protected.
HOW LONG DO WE KEEP YOUR INFORMATION+
We will only use and store your information for as long as it is required for the purposes for which it was collected. How long we store the information will depend on what is it being used for and in accordance with our retention policy. Sometimes we may need to keep information for statutory or regulatory purposes or to deal with any legal claims.
Images captured on CCTV are held for 30 days and automatically recorded over. Any data required as part of an investigation will be deleted once the issue has been fully resolved.
You have a number of rights relating to your personal data including:
- a right to access to information that we hold about you
- the right to have your personal information corrected, if it is inaccurate or incomplete
- the right to request the deletion or removal of personal data unless there is a compelling reason for the continued processing, such as if we are required to retain it for statutory purposes, or to protect our legal interests
- the right to restrict our use of your personal date (for example only allowing the storage of the data) although in some cases we will not be able to restrict our uses of your information, for example if we are required to process it for a statutory purpose or to protect our interests
- the right to object to certain ways in which we use your information
- the right to not be subject to decisions made automatically through the use of technology and with no human consideration where it produced a legal or similarly significant effect on you
- the right to request that we transfer your information directly to a new landlord or third party.
You can obtain further information about your data protection rights at the Information Commissioners website at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
We may sometimes process your data for specific purposes which require your consent. If we do this we will ask for your written consent. Where we are processing your personal data based on consent you will have the right to withdraw that consent at any time. This may affect the services that we can make available to you but this will be fully explained in the consent form
COMPLAINTS OR CONCERNS+
If you are unhappy with our use of your personal data, or anything in this notice, please talk to us directly so we can help to resolve any problem or query.
You also have the right to raise any concerns with the Information Commissioner’s Office (ICO). They can be contacted by post:
Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
By calling 0303 123 1113 or by email email@example.com
Their website is www.ico.org.uk