CORONAVIRUS & DATA PROTECTION – UPDATE
Please note that during the current COVID-19 health pandemic, you may be asked to inform us if you or anyone else in your household is experiencing (or has experienced recently), any symptoms of the Coronavirus i.e. high temperature, or a persistent cough. This information will be temporarily recorded on your tenancy file within our housing management system in the vital interests of our staff and repair operatives. This data will be reviewed regularly throughout the pandemic and will only be shared with relevant authorities or contractors working on behalf of Teign Housing/Templer HomeBuild if deemed necessary for us to fulfil our public duty as a landlord to stop the spread of this virus.
Please also be aware that if you contact us to exercise your individual rights as a Data Subject as per the Data Protection Act 2018, we are only able to process these requests digitally at present, due to office closure and staff working remotely. We will endeavour to respond to such requests within timeframe where possible, however we apologise in advance for any delays to this service during a particularly busy time for our staff. This means that any paper/hard copy data that we hold will not be processed until such time that the government advises that it is safe to return to the office. For further details about how we manage your personal data, please email your enquiry to: firstname.lastname@example.org
As a Data Controller, landlord and registered charity, Teign Housing is committed to providing all our residents, customers, employees and stakeholders with the highest standards of privacy and data security, in accordance with the EU General Data Protection Regulations (GDPR), and the UK Data Protection Act 2018.
The data we collect
Teign Housing collects information about our stakeholders for various purposes. We will collect and process data about:
- Our customers, their household members and their Next of Kin
- Employees and volunteers
- Board members
- Other stakeholders, suppliers and contractors
- Private Teign Care customers
When interacting with Teign Housing, you will be asked to provide personal information 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
The personal data that you are likely to be asked to provide to us will include (but not exclusively):
- Full name(s)
- Address (including previous and forwarding addresses)
- Date of Birth
- Contact Details (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)
- Criminal Convictions History
- Cookies on our website
- Photograph at tenancy sign-up (for the purpose of eliminating tenancy fraud)
- Information about your training and qualifications (for job applicants)
- Details for references (for job applicants)
On occasion, if appropriate, we may collect data that is ‘Sensitive’ or ‘Special Category’ including:
- Religious Beliefs
- Medical Information
- Biometric Data
We will only collect, process and share your sensitive personal data with your prior consent. We do not routinely collect data of this nature; however, you are welcome to disclose this to us if you feel it will help us to better manage your tenancy or employment with us. This data will help us to assess and monitor our compliance to the Equalities Act 2010 and will allow us to better tailor our services to you and our communities. We will only ever collect sensitive data that is relevant and proportionate to your tenancy or employment.
Our lawful basis for data processing
We will only collect and process personal data if it satisfies one of the lawful basis for processing set out in data protection law. Our lawful basis for processing personal data are:
- To Satisfy the Performance of a Contract – Tenancy Agreements permit us to collect process and share personal information to enable us to fulfil our requirements as a landlord
- Consent – if we require sensitive or special category data, or if we are using your information for a new purpose, we will seek your explicit consent beforehand. This will be in the form of a tick-box or 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.
- Vital Interests – Teign Housing can process and disclose personal data if it is in the interests of health and safety or if someone is in immediate danger.
- Legal Purposes – Teign Housing can disclose personal data if it is required by law. For example, if requested by the Police.
Most 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. 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:
- Police and the Emergency Services
- Other landlords
- Legal advisors, the courts, our insurers and auditors
- Health professionals
- Contractors including our Subsidiary company Templer HomeBuild
- Utility companies
- Local Authorities, government regulators and agencies (Department of Work and Pensions, Regulator of Social Housing or Homes England)
- Credit checking agencies and debt recovery company’s
- Charities and voluntary organisations
- Appello Careline
We will not share your personal data with any other third parties unless required by law or without your prior consent. We do not currently process or disclose any personal data outside of the European Economic Area (EEA). Please note the following occasions whereby your personal data will be disclosed to a third party:
- We may share your personal information with utility companies and council tax departments to ensure accurate billing, or if you terminate your tenancy whilst in arrears with your utility providers.
- We use debt recovery and tracing agencies if you breach your tenancy agreement terms and accumulate high rent arrears with us. Your information will be shared with these external agencies if required.
- We work with government agencies, local authorities and debt advice agencies such as the Department for Work and Pensions (DWP) to engage with residents in high level rent arrears to ensure that benefits and rent are paid correctly and to avoid legal action and evictions.
- We may pass your contact details to an external research company for the purpose of conducting satisfaction and census surveys on our behalf. You can opt out of this if you wish.
- We may share your information with external agencies if there are welfare and safeguarding concerns in the interests of safety and security.
- We may share your National Insurance number in order to investigate tenancy and Right to Buy fraud. We will also take a photograph of the Lead Tenants at tenancy sign-up meetings for the prevention of tenancy fraud
- 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’. Their Privacy Notice explains more: http://www.teignhousing.co.uk/wp-content/uploads/2018/08/Annex-2-Core.pdf
- We work in partnership with Help the Move to ensure utility suppliers are provided with up to date information on your tenancy and to assist you in setting up the most appropriate utilities. More information can be found in their Privacy Notice: https://helpthemove.co.uk/privacy-policy/
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. Your personal data will be securely held by Teign Housing in accordance with our Data Retention Policy and industry best practise. This means that your data will not be stored for longer than is necessary. 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.
Teign Housing may use personal data for profiling, research or automated decision-making purposes. We will always inform you first if your personal data is likely to be used in this way, unless the data is anonymised. Data profiling activities enables us to gain a better understanding of our customer base, their needs and requirements and enables us to develop stronger communities and better services for you.
Our Subsidiary – Templer HomeBuild
Teign Housing will act as the ‘Data Controller’ for all data processing activities conducted by the repairs and maintenance subsidiary company, Templer HomeBuild. Teign Housing will share relevant personal 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 will also include the sharing of your data with sub-contractors used by Templer HomeBuild for the purposes of repairs.
This data sharing is necessary to enable us to deliver a contractual service of repairs and maintenance as set out in our Tenancy Agreements. Teign Housing has obtained assurances from the subsidiary 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. Appropriate signage will be provided in areas that are covered by CCTV. 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. CCTV is also in use within the grounds and offices of our head office building for the same purposes as mentioned above.
Online Job Applications
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 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. 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 alarms to those who require additional support with independent living. Customers will supply us with personal information about themselves and their Next of Kin 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.
‘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. 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 offers tenants free subscriptions to the monthly financial inclusion Newsletter ‘Quids In!’. When subscribing to this publication via our website, you are consenting to the collection of your personal data such as your name, email address and subscription date, which we will store within a mailing list. You can unsubscribe to this at any time. When you subscribe, ‘Quids In!’ will be emailed to you alongside our own monthly ‘In Touch’ E-Zine. ‘Quids In!’ will be sent using ‘Mailchimp’ software.
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 make a rent payment. Our staff will only discuss information regarding your own tenancy, or those of close family if you can demonstrate the consent of the tenant or you have Power of Attorney status over their affairs. Rude, threatening or abusive behaviour towards our contact centre staff will not be tolerated.
We use live chat software on our website, this is provided by Click4Assistance, a 3rd party UK based Software Company. Information regarding how the data is processed and stored can be viewed at
Your Personal Data Rights
The data protection legislation gives our customers, tenants and staff much greater choice, control and rights over how we handle personal sensitive data. These rights include:
- The right to access – You have the right to request Teign Housing for copies of your personal data.
- The right to rectification – You have the right to request that Teign Housing correct any information you believe is inaccurate. You also have the right to request Teign Housing to complete the information you believe is incomplete.
- The right to erasure – You have the right to request that Teign Housing erase your personal data, under certain conditions. In some cases, we may need to retain certain information for legal purposes.
- The right to restrict processing – You have the right to request that Teign Housing restrict the processing of your personal data, under certain conditions. In some cases, we may need to process certain formation for legal purposes.
- The right to object to processing – You have the right to object to Teign Housing processing of your personal data, under certain conditions. In some cases, we may need to process certain information for legal purposes.
- The right to data portability – You have the right to request that Teign Housing transfer the data that we have collected to another organisation, or directly to you, under certain conditions, usually in a digital format.
- 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.
- 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 data, or you can object to its processing in this way.
If you make a request and have a justifiable reason for doing so, we have up to one month to respond to you. Please note, we will also require proof of your identity before disclosing any personal data. If you would like to exercise any of the above rights, please make your request in writing to:
Data Protection Officer
Teign Housing, Millwood House, Collet Way, Newton Abbot, TQ12 4PH
or alternatively, email your request to email@example.com
This Policy was last updated on 01.05.2020
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 regulatory body for data governance The Information Commissioner’s Office (ICO) if you still have a complaint or query:
Tel: 0303 123 1113
Teign Housing are registered with the ICO as a Data Controller under registration number: Z8460281