- The General Data Protection Regulations (GDPR) and the Data Protection Act 2018
Teign Housing complies with the principles set out by the data governing body for the UK, ‘The Information Commissioners Office’ (ICO) in relation to the personal data that you provide to us. These principles place greater restrictions and accountability on ‘Data Controllers’ over how they collect, process, manage and share personal data, and empowers the public (‘Data Subjects’) with more control and access rights to their own personal information. The term “Data Controller” is a legal phrase used to describe a person or entity that controls the way personal data is used and processed.
2. How We Use Your Personal Data
Teign Housing collects processes and shares personal information about our tenants, employees, customers and suppliers on a daily basis for a range of different business purposes such as: to comply with the law, in the legitimate interests of both Teign Housing and our customers, and to fulfil the purposes of a contract such as a Tenancy Agreement. We may process personal data for the purposes of allocating properties, for the ongoing management of tenancies, for the purposes of rent and welfare payments and for recruitment purposes. When interacting with Teign Housing you may be asked to supply information that personally identifies you, for example (but not exclusively):
- Current address and previous address history
- Date of birth
- Contact details (telephone number and email address) including contact details for Next of Kin/emergency contacts
- Medical conditions and disabilities
- Criminal convictions
- Employment status and welfare benefit entitlements
- Financial details (bank details, debt history etc)
- Responses to customer satisfaction surveys
- Tenancy ID number
Occasionally, where appropriate, we may also collect ‘sensitive’ personal data including:
- Religious Beliefs
- Physical or Mental Health Conditions
- Sexual Orientation
- Criminal Convictions
- Biometric/Genetic Data
The amount of personal information you are required to supply will be limited to that which is necessary to supply the service or carry out the transaction you have requested. Data is not currently processed or shared outside of the European Economic Area (EEA).
We do not sell trade or share your personal information to any other third parties unless we are required to do so by law. We do use authorised companies and third parties to provide services on our behalf, such as with our repairs subsidiary company (Templer HomeBuild Ltd) and with our emergency out of hours service provider (Appello), for example. We may also share personal data with the local authority for rent and welfare entitlement calculations, with utility and debt recovery agencies in the event that you default on your payments, or emergency services (such as Police, Ambulance or Fire services) if it is in the legitimate or vital interests of the resident. Teign Housing also uses ‘Mobysoft RentSense’ software to enable us to effectively predict and manage future rent arrear trends. This software uses personal customer data, and is done so under the Legitimate Interests of both Teign Housing and our tenants to reduce and prevent rent arrears.
We will inform any third party processors that they are prohibited from using this information for any other purpose, and will obtain assurances from them by way of a Data Sharing Agreement, that they have suitable measures in place to protect your data. Under the updated data protection regulations Teign Housing need to provide a valid legal basis for using personal information. We will use the personal information we hold about you for the following reasons:
– To enforce our contract with you and our clients and inform you of any changes
– To provide you with information to process your enquiry
– To provide you with information 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 customer
– For the prevention of crime and antisocial behaviour
3. Keeping your Data Safe
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
4. Your Individual Rights
The updated legislation now 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
– The right of access (Subject Access Request)
– The right to rectification
– The right to erasure (right to be forgotten)
– The right to restrict processing
– The right to data portability
– The right to object
– Rights in relation to automated decision making and profiling
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).
5. Our Wholly Owned 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.
6. Data Retention
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. Teign Housing has an ‘Information Asset & Data Retention Schedule’ that is regularly reviewed and lists how long we will keep certain records for before destroying them. Physical documents are kept to a minimum where possible, but will be shredded and professionally disposed of when no longer needed. For more information about our Data Retention policy, please email firstname.lastname@example.org.
CCTV surveillance systems are 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 clearly 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.
8. 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.
9. Your Consent
The GDPR specifies we must be transparent and offer our customers genuine choice and control over the use of their personal data. In using our web site and social media pages, you consent to the collection and use of any information you supply by both us and our authorised business partners in the ways described above. We will be required to obtain your prior explicit consent before we can collect process or share any sensitive personal information to ensure that you are fully in control of your own personal data. This will usually be provided in the form of a Privacy Notice or an ‘opt-in’ box for you to tick to confirm your consent to any data collection. You can revoke your consent to certain data collection activities at any time by contacting us. We may occasionally publish photographs on our website and social media pages that include and identify individuals from events for the purposes of marketing and publicity. Wherever possible we will aim to obtain prior consent from the individuals involved before publishing, however where this is not possible, individuals can contact our Business Support Team to request to have the photo removed.
10. External Links
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 email@example.com.
12. 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.
13. Google Analytics
14. ‘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. All new tenants with valid email addresses will be emailed a secure log-in which will allow them to create an account if they wish to do so. Customers can deactivate their accounts at any time.
15. TeignCare Service
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 us7. 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.
16. The Processing of Children’s Data
Teign Housing does not hold or 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.
17. ‘CORE’ Data
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.
For any other information please contact us through our ‘Contact’ section of this website, or email our Data Protection Officer Craig Manley at: firstname.lastname@example.org. Alternatively, you can contact our Business Support Team by calling 01626 322722.
Teign Housing is registered as a ‘Data Controller’ with the Information Commissioners Office under registration number: Z8460281. For more information about the Data Protection Act 2018 and the General Data Protection Regulations, please visit the ICO’s website https://ico.org.uk/.
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