Updated: September 2020
During the current COVID-19 pandemic, you may be asked to inform us if you, or anyone in your household are experiencing symptoms associated with the Coronavirus (i.e. high temperature, persistent cough). This data will be collected in the interests of the health and safety of both our staff and our customers. Data will be temporarily stored on your tenancy file and will be regularly reviewed. This data will be removed from our systems when it is considered safe to do so. This data may be shared with relevant authorities if necessary, to enable us to fulfil our public duty as a social housing provider, to stop the spread of the virus and to keep everyone safe. If you are expecting a home visit by any of our staff, they will call ahead of the appointment to check that you are feeling well and that you’re are not quarantining.
If you contact us to exercise your personal rights as a Data Subject, please be aware that our response times may be delayed during what is a busy period for our staff, however we will always endeavour to provide requests for information within usual timescales wherever possible. We are only able to respond to such requests digitally at present whilst our staff are working remotely.
- How we use personal data
Teign Housing collects ‘Personal’ and ‘Sensitive’ data for many different purposes to enable us to deliver on our core mission ‘to raise the standards of housing services in Teignbridge’. We collect data from our tenants, prospective tenants, Teign Care customers, employees, Board members, volunteers, customer Next of Kin and other stakeholders such as suppliers.
The Data Protection Act 2018 specifies six key principles to compliant data processing, which we will abide by. These principles state that data must be:
- Used lawfully, fairly and in a transparent way
- Be collected only for valid purposes
- Be relevant to the purposes we have told you about
- Be kept only for as long as necessary
- Be kept securely
When interacting with us, you may be asked to provide personal information such as (but not exclusively):
- Full Name(s)
- Address (including previous and forwarding addresses)
- Contact Details (including telephone number and E-mail address)
- Date of Birth
- Financial Information (including bank details, National Insurance Number, welfare/benefit details)
- Employment Status
- Details for references
- Training and qualifications (for job applicants)
- Criminal Conviction History
- Medial Information
- Photograph of yourself (for the prevention of fraud at tenancy sign ups, and for staff ID badges)
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. For job applicants, data will be sourced from your application form and from your references/previous employers. We also collect your personal data from: telephone calls, letters, emails, contracts, forms and documents, photographs and face-to-face.
Providing this personal data is necessary to allow us to:
- Respond to your enquiry
- To process your application for housing
- To process Shared Ownership and Right to Buy sales
- To process your application for our Teign Care service
- To process rent and welfare benefit payments
- To manage your ongoing tenancy/employment
- To deal with your complaint
- To provide help, advice and guidance
We do not routinely collect some categories of ‘sensitive’ data such as:
- Religious Beliefs
- Marital Status
- Biometric Data (Fingerprint and facial recognition)
- Trade Union Membership (staff members)
Providing us with the above information is entirely optional if you feel it may help us to better support your tenancy or employment with us, and we will only collect such data with your prior consent. This data will help us to 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 collect sensitive data that is relevant and proportionate to your tenancy or employment.
Teign Housing does not routinely 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.
- Lawful Basis for Processing
Under data protection law, we will only collect, process and share personal information if it satisfies one of the following lawful basis’:
- Consent – where we have obtained your prior explicit consent (for ‘sensitive’ personal data)
- To satisfy the performance of a contract – Tenancy Agreements allow us to collect, process and share personal data to enable us to fulfil our duties as a landlord
- Legitimate Interest – we can process personal data if it is in the mutual interests of both Teign Housing and our customers or staff members
- Vital Interest – in emergency situations or in the interests of health and safety (for example, with the emergency services)
- Legal Purposes – if it is required by law (if requested by the Police or the Courts)
More information about lawful basis’s for data processing can be found here: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/
- Data Sharing
Teign Housing shares personal data for a variety of purposes. We will only share data when we have a lawful basis for doing so, and when we have assurances by way of a Data Sharing Agreement with the third party. If we need to share personal data with a third party, we will conduct a Data Protection Impact Assessment (DPIA) to make sure that the data sharing is safe, risks are minimised, and the sharing is carried out in accordance with legislation.
Most commonly, in order to deliver our services, we may share your personal data with:
- The emergency services (Police, Ambulance, Fire)
- Other landlords and registered providers
- Legal advisors, courts, consultants and our insurers
- Health professionals
- Contractors including our repairs subsidiary Templer HomeBuild
- Utility companies
- Local authorities, government regulators and agencies (e.g. DWP)
- Credit checking and debt recovery agencies
- Charities and other support agencies
- Appello Careline
There may be instances where we may be required under the terms of the Tenancy Agreement to share your personal data, these include:
- with utility companies and council tax departments to ensure accurate billing, or if you terminate your tenancy whilst in arrears with your utility providers
- with debt recovery and tracing agencies if you breach your tenancy agreement and accumulate high rent arrears
- with government agencies, local authorities and debt advice agencies such as the Department for Work and Pensions (DWP) to engage with residents in rent arrears to ensure that benefits and rent are paid correctly and to avoid legal action and evictions
- with 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.
- with external agencies if there are welfare and safeguarding concerns in the interests of safety and security
- we may share your National Insurance number 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
- 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
- with ‘Help the Move’ to ensure utility suppliers are provided with up to date information on your tenancy and to assist in setting up the most appropriate utilities. More information can be found in their Privacy Notice: https://helpthemove.co.uk/privacy-policy/
We do not currently process or share personal data outside of the European Union or for marketing purposes.
- The protection and retention of personal data
Teign Housing are ‘Cyber Essentials Plus’ certified, meaning that our databases, servers and networks have adequate security measures in place to prevent the loss, misuse or alteration of information under our control. All staff have regular data protection training, and we have a comprehensive data protection policy and data breach procedure in place.
Your personal data will be securely held by Teign Housing in accordance with our Data Retention Policy inline with 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.
- Data Profiling
Occasionally, we may use personal data for the purposes of profiling, research or automated decision making. We will always inform you first if we plan to use your data in this way, and you will be given the option to opt-out of this data processing. Sometimes, we may anonymise personal data to assist us with our data analytics. Where personal data has been anonymised, we are not legally required to obtain your explicit consent. 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.
- Templer HomeBuild
Templer HomeBuild are a wholly-owned subsidiary of Teign Housing and provide the responsive repairs and maintenance services on our behalf. Under the Tenancy Agreement, we will be required to share some personal data with the subsidiary such as: name, address and contact details to enable the subsidiary to carry out their day-to-day repair’s duties and for the booking of repair appointments. This will also include the sharing of data with sub-contractors procured by Templer HomeBuild. For data protection purposes, Teign Housing are the Data Controller for all data activities conducted by Templer HomeBuild.
- 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.
TeignCare provides a service to both our residents and private customers in the form of emergency pull cords and personal alarms for those who need additional support to live independently. This service is governed by the same data protection principles and safeguards as the rest of our services.
Some personal data will be required when signing up to this service including medial information and contact details for Next of Kin. This data will be shared where necessary, with our emergency out of hours contact centre, which is managed by Appello Careline.
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.
- 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 copies of the personal data we hold about you (certain exemptions apply).
- 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. 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. We may need to process certain information for legal purposes.
- The right to object to processing – You have the right to object to the processing of your personal data, under certain conditions. We may need to process certain information for legal purposes.
- The right to data portability – You have the right to request that Teign Housing transfers your personal data 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, or you can object to its processing in this way.
Please note, if you submit any of the above requests to us under the Data Protection Act 2018, we have up to one month to respond and to supply the information requested. In certain circumstances if the request is particularly large in nature, we may apply for an extension to this deadline.
You will also be asked to provide proof of identification before we take any action on your request – usually in the form of a valid Passport or Driving License.
More information about your personal data rights can be found here: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
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 firstname.lastname@example.org
- Use of Technology
Teign Housing uses technology in a variety of ways to process personal data, to enable us to provide our services in the most effective ways. Below are examples of how we do this:
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.
- ‘MyTeign’ 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.
- Mobysoft Rentsense
- Google Analytics and Cookies
- ‘In Touch’ Customer E-Zine & ‘QuidsIn’ Magazine
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/ . Customers consent to receiving this publication, however 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 .
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 Contact Centre
Please note 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.
- Live Webchat
We use live chat software on our website, this is provided by Click4Assistance, a 3rd party UK based Software Company. If you use our live webchat service, you will be asked to provide some identifying information to be able to process your query. Information regarding how the data is processed and stored can be viewed at https://www.click4assistance.co.uk/click4assistance-web-chat-software-cookie-policy
- The Noise App
To help investigate complaints of anti-social behaviour such as noise nuisance, residents can download the Noise App onto their personal mobile devices. Teign Housing can access recordings that have been uploaded to the secure Noise App website by a resident, and these recordings may be used in the investigation of anti-social behaviour. For more information, please visit: https://sso.rheglobal.com/services/1/licences/tos
- External Links
- Queries and Complaints
For any questions or queries regarding our data protection policies, or if you would like to exercise one of your personal Data Subject rights under the legislation, please contact:
Craig Manley – Data Protection Officer
Or email: dataprotection@Teignhousing.co.uk
If we are unable to deal with your enquiry, you can contact the data governance regulatory body, The Information Commissioners Office (ICO) by contacting:
Tel: 0303 123 1113