1. The General Data Protection Regulations (GDPR)
Teign Housing fully complies with the principles set out by 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.
2. Use of Personal Information
As a social housing landlord, 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, 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
- Gender, disabilities, ethnicity, cultural or religious beliefs, sexual orientation, trade union membership
- Medical conditions/history
- 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 companies and third parties to provide services on our behalf if necessary, such as with our repairs and maintenance subsidiary company and our emergency out of hours service provider, for example. We may also share certain data with utility companies for example, if it is in the legitimate interests of the resident.
Only personal information necessary to deliver the service will be provided to these companies. We will inform them that they are prohibited from using that 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.
Teign Housing may disclose personal information if required to do so by law, in an emergency or in the good faith belief that such action is necessary with agencies such as the Police and Local Authority if it is regarded to be in the Public Interest or Vital interest of the Data Subject, or in the legitimate interests of Teign Housing.
No personal information is shared or transferred outside of the European Union in accordance with EU data protection laws.
3. 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 (tenancy reference or statements details for example) cannot be read as it travels over the Internet.
4. Your Consent
In using our web site and social media pages, you consent to the collection and use of any information you supply by both ourselves and our authorised business partners in the ways described above.
Under the ‘GDPR’, 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.
5. Your 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 firstname.lastname@example.org. Please note that Teign Housing has up to 40 calendar days to respond to/process any requests for the above, and we will require proof of your identity before disclosing any personal information.
6. External Links
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. Teign Housing has a robust data breach reporting procedure in place, and will notify any affected customers and the necessary regulatory body if we are legally required to do so.
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.
9. Online Job Applications
Any personal or sensitive information supplied via our website for the purpose of completing an online job application will be used solely by Teign Housing for the purposes of assessing suitability for the role and for arranging any subsequent interviews. If the sharing of any information is required by law, or for the purposes of progressing an application (such as to obtain references), then the candidate will be notified beforehand to obtain their consent. Personal information supplied through the website for recruitment purposes will be held securely by Teign Housing for a maximum of 12 months in accordance with our Data Retention Policy.
CCTV surveillance systems are in use across some of Teign Housing’s schemes and communal areas in the interest of resident safety 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.
11. 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.
12. 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 and processing 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 firstname.lastname@example.org. Any serious complaints, data breaches or queries will be reported to Teign Housing’s Data Protection Officer for further investigation if deemed appropriate.
13. Updates to Privacy Information
For any other information please contact us through our ‘Contact’ section of this website. For more details on data protection law and the ‘GDPR’, please visit the ICO’s website https://ico.org.uk/.
15. Google Analytics
16. ‘See My Data’
Our tenant portal ‘See MyData’ 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.