Data Protection Principles
The ‘GDPR’ and the Data Protection Act 2018 specifies six key principles to compliant data processing, which Teign Housing will abide by. These principles state that data must be:
• Used lawfully, fairly and in a transparent way.
• Be collected only for valid purposes and not used in any way that is incompatible with those purposes.
• Be relevant to the purposes we have told you about and limited only to those purposes.
• Be accurate and kept up to date.
• Be kept only for as long as necessary
• Be kept securely
The data we collect
When interacting with Teign Housing, you will be asked to provide personal information in order for us to:
– Respond to your enquiry
– Process your application for housing
– Process rent and welfare benefit payments
– Manage your ongoing tenancy
– Process your application for employment
– Deal with your complaint
As a business and Data Controller, Teign Housing collects, processes and shares personal data on a daily basis for many different reasons. The personal data that you are likely to be asked to provide to us will include (but not exclusively):
• Full name(s)
• Address and previous address history
• Date of Birth
• Contact Details (including for any Next of Kin) such as telephone numbers and email addresses
• National Insurance Number
• Responses to Customer Satisfaction Surveys
• Employment Status
• Financial Information (Bank Account Details, Details of any Welfare/Benefit Entitlements)
• Cookies on our website
On occasion, if appropriate, we may collect personal data that is considered to be ‘Sensitive’ or ‘Special Category’ including:
• Religious Beliefs
• Medical Information
• Criminal Convictions
• Biometric Data
We will never collect, process or share your sensitive personal data without your prior explicit consent, and will only collect it if you feel that it will help us to better sustain your tenancy or employment with us. This data will enable us to assess our compliance to the Equalities Act 2010, and will allow us to better tailor our products and services to you and our communities. The amount of personal information you are required to supply will be limited to only that which is necessary to supply the service or carry out the transaction you have requested.
Our lawful basis for data processing
Under the new data protection legislation, we must only collect and process personal data if it satisfies certain lawful purposes. Our lawful basis for processing personal data is:
• To Satisfy the Performance of a Contract – our Tenancy Agreements permit us to collect process and share personal information relating to our residents to enable us to fulfil our requirements as a landlord under our Tenancy Agreements. For example, we share and process data alongside our repairs and maintenance subsidiary company to ensure your home is kept in a good state of repair.
• Consent – if we require sensitive or special category data, or if we are using your personal information for a new purpose, we will always seek your explicit consent beforehand. This will be in the form of a tick-box that requires you to actively tick to agree to the data processing, or requires a signature to confirm your consent.
• In our Legitimate Interests – We can process personal data if it is genuinely in the interests of both Teign Housing and the Data Subject. For example, the use of CCTV surveillance in communal areas is in the interests of Teign Housing to protect our property and monitor anti-social behaviour. This is also in the best interest of our tenants to protect you from criminal activity.
• Vital Interests – Teign Housing can process and disclose personal data if it is in the interests of health and safety. For example, we may share personal data with the emergency services (ambulance, police, fire) if a tenant is in danger.
• Legal Purposes – Teign Housing can disclose personal data if it is required by law. For example, if requested by the Police, if it’s needed for Court proceedings, or to share data with government agencies or the DBS service.
The majority of our data is collected directly from you when signing up to a Teign Housing property. This data may be collated from your Devon Home Choice application and via your Pre-Tenancy Interview documentation. We may also collect your personal data from other external agencies such as the Local Authority or previous landlords.
The Sharing of Personal Data
Teign Housing shares customer personal data with a range of trusted third party processors for a range of different purposes such as:
• To enforce our contract with you and our clients and inform you of any changes
• To process your application for a job vacancy
• To obtain feedback from you and provide ongoing customer service
• To deal with any complaints
• For regulatory and legal purposes
• For the security, health and safety of tenants and customers
• For the prevention of crime and antisocial behaviour
In order for us to fulfil our duties under the Tenancy Agreement, we are required to share your personal data with other third party processors that we work with including:
– Templer HomeBuild Ltd (for repairs and maintenance services)
– The Local Authority (For Welfare & Benefit Payments)
– Emergency Services (with Police, Fire, Ambulance)
– Appello Careline (Our out of hours emergency hotline)
– Other Housing Associations (for references)
– With the DBS service (if applying to work for us)
– Utility Companies (for the recovery of debt)
We will not share your personal data with any other third parties unless required by law or without your prior explicit consent. We do not currently process or disclose any personal data outside of the European Economic Area (EEA). We will always seek to obtain data sharing agreements or assurances from our third party processors that they have suitable due diligence procedures in place to process your personal data securely.
The Protection and Retention of Personal Data
Databases in the Teign Housing network are password protected and we have security measures in place to prevent the loss, misuse or alteration of information under our control. These security measures include the following examples:
– Password Protection
– Secure IT Servers
– Encryption and Secure Socket Layers (SSL)
– Firewalls, Antivirus and Intrusion Detection Systems
Your personal data will be securely held by Teign Housing in accordance with our Data Retention Policy. This means that your data will not be stored for longer than is necessary, and we will make every effort to ensure the personal data we hold is kept accurate and relevant. Teign Housing has an obligation to ensure that all personal data and records are kept up to date, secure and destroyed appropriately in relation to data retention guidelines published by our regulator The National Housing Federation. Physical documents are kept to a minimum where possible, but will be shredded and professionally disposed of when no longer needed.
Your Data Protection Rights
The legislation gives our customers and tenants much greater choice, control and rights over how we handle personal sensitive data. Teign Housing must offer total transparency around our data processing activities and must provide easy ways for our customers to control their personal information. These rights include:
• The Right to be Informed – Teign Housing must offer total data transparency, and inform you by way of Privacy Notices, of the ways in which we are collecting and processing your personal data.
• The Right of Access – You can request to have access to the information that Teign Housing holds about you, this is known as a Subject Access Request.
• The Right to Rectification – If you notice that any of your personal data that is inaccurate or incorrect, you can ask us to correct it and update our systems.
• The Right to Erasure – Also known as the ‘Right to be Forgotten’, you can request that Teign Housing deletes and removes certain information from our systems if it is no longer relevant, inaccurate, or if it is likely to cause you problems or distress.
• The Right to Restrict Processing – You can request that Teign Housing stops processing certain data for a certain period of time, if you feel that the processing of this particular data is going to have negative implications on you.
• The Right to Data Portability – You can request that your personal data is collated and sent directly to a new Data Controller in an easily readable format.
• The Right to Object – You can object to the processing of certain data if you feel that the processing is unnecessary or has potential to impact on your individual rights and freedoms.
• Rights around Automated Decision Making and Profiling – If we intend on using personal data for research, analysis or statistical work for the purposes of profiling, we must inform you and obtain your explicit consent beforehand, unless the data used is anonymised. You can withdraw consent to profiling projects that involves your personal data, or you can object to its processing in this way.
If you would like to exercise any of the above rights and have a justifiable reason for doing so, please make your request in writing to: Craig Manley, Data Protection Officer, Teign Housing, Millwood House, Collet Way, Newton Abbot, TQ12 4PH or alternatively, email your request to email@example.com.
Please note that Teign Housing has up to one month to respond to/process any requests for the above, and we will require proof of your identity before disclosing any personal information. Teign Housing can refuse to comply with a data subject’s request if there is a legitimate or legal purpose for us to do so (i.e. the data is vital for us to sustain your tenancy).
Occasionally, Teign Housing may use personal data for profiling or automated decision making purposes – this may include research and statistical analysis using personal data. We will always inform you first if your personal data is likely to be used in this way, and we will seek to obtain your explicit consent to this data processing, unless the data is anonymised, in which case consent is not required. Data profiling activities are a useful business tool that enables us to gain a better understanding of our customer base, their needs and requirements and enables us to develop stronger communities.
Teign Housing currently uses ‘Mobysoft Rentsense’ software which uses algorithms in our data to help us predict and manage rent arrears. This data processing/profiling is conducted under the lawful basis of ‘Legitimate Interests’, as it is in Teign Housing’s interest to monitor our income through rents and to minimise rent arrears, it is also in our tenant’s interests to not fall behind on their rent payments. If you have any questions regarding this data processing and software, please email firstname.lastname@example.org.
Our Subsidiary – Templer HomeBuild
To fulfil the requirements of the ‘GDPR’, Teign Housing will act as the ‘Data Controller’ for all data processing activities conducted by the repairs and maintenance subsidiary company, Templer HomeBuild. As such, Teign Housing will share relevant personal tenant information with the subsidiary such as: name, address and contact details to enable the subsidiary to carry out their day-to-day duties such as contacting tenants to book repair appointments, for example.
This data sharing is necessary to enable us to deliver a contractual service of repairs and maintenance as set out in our Tenancy Agreements and is carried out through the lawful basis of ‘to fulfil the requirements of a contract’ under Article 6 of the ‘GDPR’. Teign Housing has obtained the necessary assurances from the subsidiary by way of a Data Sharing Agreement that they will handle personal tenant data as per their responsibilities set out by the ‘GDPR’. Any complaints or queries relating to the way that personal information has been handled by the subsidiary company should be reported directly to Teign Housing’s Data Protection Officer by emailing email@example.com.
CCTV surveillance is in use across some of Teign Housing’s estates and communal areas in the interest of resident safety, for the prevention of crime and for the protection of Teign Housing property. This is in the legitimate and vital interests of Teign Housing and our residents. Appropriate signage will be provided in all areas that are covered by CCTV surveillance to inform the public of its presence. Images captured by CCTV may be shared if required by law or if in the public interest with agencies including the Police and with solicitors for investigations into any criminal or anti-social activity carried out on Teign Housing property. CCTV images will be stored securely in accordance with Teign Housing’s Data Retention Policy.
Online Job Applications
Any personal information supplied via our website for the purpose of completing an online job application will be used solely for the purposes of assessing suitability for the role and for arranging any subsequent interviews. Some of this personal information may be shared with authorised third party processors if required by law for DBS checks or for the purposes of progressing your application through obtaining references. All unsuccessful job applications will be retained for 6 months and all successful applications will be retained for 12 months. By submitting a job application through this website, you accept the processing of this data as described above.
Teign Housing provides the TeignCare service offering pull cord and personal alarm services to those who require additional support with independent living. Customers of the Teign Care service will supply us with personal information in order for us to provide them with the service they have requested of us. This data will be shared with our out of hours emergency call centre, ‘Appello’, to enable them to process any emergency calls. Calls to the Appello helpline may be recorded for training and monitoring purposes. Personal data of Teign Care customers may also be shared in the event of an emergency with authorised care workers or emergency services such as: Police, Fire and Ambulance Services if it is deemed to be in the vital interests of the customer. Only personal information deemed necessary for the performance of the service will be disclosed to any of the above third parties.
‘My Teign Account’
Our online tenant portal ‘My Teign Account’ is a secure platform that allows tenants to easily access their own personal information that we hold at Teign Housing. The service allows tenants to pay their rent and book repairs, as well as being a mechanism for changing and updating personal information. Customers can deactivate their accounts at any time.
The Processing of Children’s Data
Teign Housing does not process children’s data apart from names and date of birth which are required for setting up a tenancy where children will be part of the household. This is required to ensure that families are allocated the correct property to suit their needs and requirements. Children’s data will only be disclosed if requested by law for police or social services investigations in the vital interests of the child. Under the Data Protection Act 2018, children over the age of 13 years are permitted to grant their own consent to data processing where deemed appropriate.
Google Analytics & Cookies
E-Newsletter ‘In Touch’
Teign Housing uses a third party provider, ‘Mailchimp’, to deliver our monthly e-zine Newsletters. We may gather statistics around email opening and clicks using industry standard technologies. For more information, please see https://mailchimp.com/legal/privacy/. If you would like to be removed from our newsletter mailing list, please call our Business Support Team on 01626 322722 or email firstname.lastname@example.org. Teign Housing does not carry out any other form of direct marketing.
Calls to our Business Support Hub
Please be aware that calls made to our Business Support Team are recorded for training and monitoring purposes. When contacting us, some personal information may be required for the purpose of processing an enquiry. Call recordings will be paused if you are ringing to
When new customers sign-up to a Teign Housing property, some personal data will be shared with the Government Ministry for Housing, Communities and Local Government for research and statistical analysis purposes known as ‘CORE’. For more information about what data is shared and the purposes for this disclosure, please http://www.teignhousing.co.uk/wp-content/uploads/2018/08/Annex-2-Core.pdf to read the Government’s full Privacy Notice. This data may be sensitive in nature, and will be securely stored by Teign Housing in accordance with our Data Retention Schedule.
Queries & Complaints
If you have already contacted our Data Protection Officer and we have been unable to deal with your query, you have the right to contact the Information Commissioner’s Office (ICO) if you still have a complaint or query:
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
www.ico.org.uk Tel: 0303 123 1113