- The General Data Protection Regulations (GDPR) and the Data Protection Act 2018
Teign Housing complies with the principles set out by the governing body The Information Commissioners Office (ICO) with regards to the ‘GDPR’ in relation to the personal data that you provide to us. These principles place greater restrictions on the powers of Data Controllers such as Teign Housing over how they collect, process, manage and share personal data, and empowers the public with more control and access rights to their own personal information.
The UK Data Protection Act 2018 has also been introduced to replace the former Data Protection Act 1998, and specifies how the principles of the ‘GDPR’ apply in practise specifically to businesses across the UK. This specifies that any data collection must be done lawfully, be proportionate to its intended purpose, be transparent and be processed and destroyed securely.
- Use of Personal Information
Teign Housing collects processes and shares personal information about tenants, 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. 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/history and disabilities
- Criminal convictions/history
- Employment status and welfare benefit entitlements
- Financial details (bank details, debt history etc)
- Responses to customer satisfaction surveys
- Tenancy ID number
The amount of personal information you are required to supply will normally be limited to that which is necessary to supply the service or carry out the transaction you have requested. The personal information we collect from you will be used by Teign Housing to provide the service or carry out the transaction you have authorised.
We do not sell trade or share your personal information to others unless we are required to do so by law. We do however; use other authorised companies and third parties to provide services on our behalf if necessary, such as with our repairs and maintenance subsidiary company (Templer HomeBuild Ltd) and our emergency out of hours service provider (Appello), for example. We may also share certain personal data with utility companies, debt recovery agencies or emergency services (such as Police, Ambulance or Fire services) if it is in the legitimate or vital interests of the resident. We will inform them that they are prohibited from using this information for any other purpose, and will obtain assurances from them that they have suitable measures in place to protect your data before any information is disclosed to them.
Under the updated data protection regulations Teign Housing need to provide a valid legal basis for using personal information; we also set out below the legal basis which we will be relying upon. 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
No personal information is shared or transferred outside of the European Union in accordance with EU data protection laws.
- Security of Personal Information
When sensitive personal information is supplied via the website, we will try to ensure that it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol. This is designed to ensure that your information cannot be read as it travels over the Internet. 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 may include the following examples:
– Access control passwords
– Secure servers
– Firewalls, antivirus and intrusion detection systems.
- Your Consent
The GDPR specifies that as an organisation 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 consent before we can collect process or share any 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.
- Your Individual Rights
The ‘GDPR’ now gives our customers and tenants much greater choice, control and rights over how we handle personal sensitive data. With this in mind, Teign Housing must offer total transparency around our data processing activities and must provide easy ways for 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 wanting to do so, 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. 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.
- 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 firstname.lastname@example.org.
- 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.
CCTV surveillance systems are in use across some of Teign Housing’s schemes 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 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.
- Calls to our Business Support Hub
Please be aware that calls made to our Business Support Team may be recorded for training and monitoring purposes. When contacting us, some personal information may be required for the purpose of processing an enquiry.
- Google Analytics
- ‘See My Data’
Our online tenant portal ‘See My Data’ is a secure platform that allows our 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 if it is incorrect. 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.
- 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 for processing 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 Templer HomeBuild in the first instance by contacting their helpdesk on 0800 197 9790, or by emailing your enquiry to email@example.com. Any serious complaints, data breaches or queries will be reported to Teign Housing’s Data Protection Officer for further investigation if deemed appropriate.
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 made. 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 legitimate or 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.
- Data Retention
Teign Housing has an obligation to ensure that all personal data and records are kept up to date, secure and removed or destroyed appropriately in relation to data retention guidelines published by our regulator The National Housing Federation. Teign Housing has a Document Retention Policy that is regularly reviewed and details the periods of time that each data record or document should be retained and when it should be destroyed. 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.
- 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 and legitimate 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.
‘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
For any other information please contact us through our ‘Contact’ section of this website, or email email@example.com. For more details on data protection law and the ‘GDPR’, please visit the ICO’s website https://ico.org.uk/.
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