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Privacy Notice

 Solon South West Housing Association: Privacy Notice for residents

Your contact with Solon generates records including personal information, some of which may be sensitive and all of which is subject to the Data Protection Act 2017.  We respect residents’ privacy. This privacy notice sets out Solon’s approach to data protection and privacy as your data controller.


 

How we collect personal information

Solon collects information in a variety of ways including application forms and questionnaires, telephone conversations, the website, contracts, through ongoing contact and correspondence with you and with other support agencies which relate to you, occasionally from the police or other authorities and also from people associated with you such as family, friends and neighbours. We may also have CCTV cameras in public areas in some properties to record events in order to prevent anti-social behaviour.

 It is paramount that you tell us if any of the personal information you have given to us changes so that we can keep this up to date or discuss it with you as it may affect your tenancy if you withhold any changes from us.

If you provide us with personal information relating to members of your family or your associates we will assume that you do so with their knowledge and consent.

Sensitive and Non-sensitive Personal Data: Information we hold on you is split into two categories; sensitive (or special categories of personal data) and non-sensitive. Sensitive data is anything that relates to Race or Ethnicity, Political Opinions, Religious Beliefs, Trade Union Membership, Physical/Mental Health, Sexual Life. Non-Sensitive information is anything else we hold on you, including (but not limited to) Name, Date of Birth, Phone number, E-mail Address and National Insurance Number. Bank Details (and similar info) are not classified as sensitive data however they are treated with the same amount of security and confidentiality as all other sensitive information. The Commission or Allegation of an Offense and the proceedings or sentencing of the offense are also not classed as sensitive personal data but are subject to even tighter controls.

What information we may collect, hold and use

·    Your name and contact details for use across the organisation and by our suppliers and partners.

·        Detailed personal information such as photo identification, age, sex, date of birth, ethnicity, income, National Insurance number, private expenditure data, employment status, contact details (telephone numbers and email addresses), relationship status, address history, any disabilities, religion, sexual orientation, nationality, caring responsibilities, details of your next of kin (address and contact details) access to financial services such as banks and credit unions, bank details, benefits, council tax, affordability information, eligibility for UK residency, details of those who you want us to communicate with on your behalf, how you prefer us to contact you, whether you have any literacy problems, your ability to speak English and language preferences, requirements for different communication formats, your preferences for getting involved and the service areas that are of most interest to you.

·    Simple Details on other occupants of your home such as their name, date of birth, sex, ethnicities, any health issues we may need to know about and their religion.

·  Tenancy reference checks/references from other housing providers/private landlords.

·         Your particular needs or preferences so that we can understand them better and offer care or support based on these needs.

·         Details of Support Services you may use.

·   References/information from your mortgage lender (if you own/have owned your own home), When you apply to us for housing, we request information so we can understand your housing needs and assess your application. This may include references from other landlords, your mortgage lender (if you own/have owned your own home), the police and probation services, support workers, social workers, mental health workers and credit reference agencies. 

·    Medical and health information so that we can prioritise and assess a housing application.

·       Your support needs so we know how we can support and assist you before and during your tenancy.

·      Details of any harassment or abuse in order to support or protect you.

·     Details of any complaints made against you or any anti-social behaviour.

·         Details relating to the repair and maintenance of your home.

·  Information that you provide to your relevant housing officer, maintenance or other dedicated team, including all emails and other forms of communication.

·     Feedback from our contractors about their appointments with you.

·         Information about allegations of anti-social behaviour.

·    Voice and image (CCTV) recordings for safety, crime prevention and quality management which is used in accordance with our CCTV policies and procedures.

·      We may collect information about individuals where they pose a substantial threat to our staff or contractor, such as criminal records or alleged offences.

·     We may take pictures at residents’ parties, meetings and other events, and these may be used in newsletters, annual reports, brochures or on the website or Facebook and they may appear in local newspapers.  Whenever we take pictures we will always ask you for your written permission and give you the choice whether or not to be included in a photograph.

·      We may also record calls to our customer service staff and some other departments. This is to help us identify how to provide you with a better service. These calls will be kept securely for 12 months then destroyed, unless they are part of a dispute – in which case we reserve the right to keep them for dispute resolution purposes.

How Long Do we hold your data for

In most cases we hold the majority of your tenancy data for up to 6 years after your tenancy ceases. However some data we may get rid of during your tenancy if we no longer have a purpose for keeping it. For full details on how long we keep your personal data you can contact us and ask to see our full retention policy.

Who the personal information relates to

We collect and hold personal information about: 

Residents - This includes current, former and potential residents who live in our properties or access our support and other services, together with members of their families and people associated with them. 

Visitors - Visitors to our offices  

Anyone - who makes an enquiry to Solon.

Anyone - who makes a complaint to Solon.       

 

How we use our records

We keep records to enable us to: 

·    Assess applications for housing and then allocate housing and provide tenancies.

·  Manage housing and tenancies including collecting the rent and any service charges.

·     Provide a repairs and maintenance service.

·         Offer support, advice and help with debts and benefits.

·  Provide support services where needed by residents including vulnerable residents.

·         Keep in contact with residents, invite you to events etc

·         Prevent and detect crime and resolve disputes.

·         Prevent and detect fraud and money laundering.

·     Promote safety and the quiet enjoyment of houses and estates.

·         Tackling Anti-social behaviour.

·       Discuss services with residents to identify improvements.

·         Provide information about services requested by you.

·   Promote equal opportunities and fair treatment for all residents.

·    Develop new products and services to meet the future needs of our communities.

·         Meet our legal obligations to our regulators and funders.

·         To fulfil our obligations to you as laid out in your tenancy agreement

The GDPR and Data Protection Act requires us to minimise our holding and use of sensitive categories of personal information. This means that we will only collect and use it when it is necessary to provide special services, or to deal with special circumstances. Examples include when we receive applications from people with disabilities or with problems such as substance abuse, when there are anti-social behaviour issues involving actual or alleged criminal activity or when residents need access to care services.

Direct marketing

We may occasionally wish to provide you with information about events, services and other information which may be useful to you.  We will send this by post, email or contact you by telephone. You can let us know at any time how you prefer to be contacted or if you do not want us to contact you with this information.

We will never provide any of your personal information to other companies for their marketing purposes. 

 

Protecting and sharing information

Your personal information will be kept secure and confidential as per our data protection policy. Our staff only have access to your personal information when and if they need to have it to provide the service to you.  We may share information with contractors, or agencies we work with, such as local authorities, social services, police, other social landlords and others when we think it is in your interest or in the public’s interest to do so. We will also disclose information as required by law. 

In particular, please be aware that: 

·    Current or forwarding addresses may be shared with utility companies and Council Tax offices to ensure billing details are correct.

·  If you default on any tenancy or licence conditions, information about you may be provided to authorised debt recovery agencies, to enable them to recover the debt. This may affect future applications for tenancies, credit and insurance.

·         We may discuss your financial situation, rent payments (including any arrears) and any claims made for welfare benefits with an external debt advice agency, welfare rights advisor, a council’s housing benefit department or housing advice and homeless prevention team to ensure that benefits are paid correctly.

·    We may pass data about your rent payment record to credit reference agencies. This will enable them to assist other organisations to assess your financial standing if you apply for products and services.

·       We may pass your information to support services if we feel it is in your interests to do so or if you ask us to do so.

·         We may pass your contact information to a third party to conduct surveys and research on our behalf which allow us to gather feedback and improve the services we offer you. The third party will always be bound to strict terms and conditions outlined by us and will not share your data with other organisations. Should you choose not to participate in the surveys the third party will securely destroy your data.

·       We may share your National Insurance number to verify your Universal Credit application and manage these payments.

·     We may also share your National Insurance number in order to prevent - and investigate - tenancy and right to buy applications fraud.

National Fraud initiative

Solon may occasionally participate in the National Fraud Initiative (NFI) data matching exercise carried out by the Government. Our participation in NFI assists in the prevention and detection of fraud against Solon and other public sector organisations.

Data matching involves comparing computer records held by one organisation with records held by another to see how far they match. This is usually personal information.  Data matching allows fraudulent claims and payments to be identified. Where a match is found it may indicate that there is an inconsistency which requires further investigation. No assumption can be made as to whether there is fraud, error or any other explanation until an investigation is carried out.

The use of data in this way is carried out with statutory authority and therefore does not require the consent of the individuals concerned under the Data Protection Act 2017.

 

Your rights under the Data Protection Act

Right to Be Informed: We must provide you with a privacy notice to tell you how we are using your personal data.

 

Right of access: You have the right to obtain access to your own personal data at any time so you are aware of and can verify the lawfulness of processing. Information will be supplied within one month of receipt of the request.  This can be extended by a further two months where requests are complex or numerous. This will be provided free of charge unless you ask for multiple copies or the request is manifestly unfounded or excessive. We can also refuse your request if it adversely affect the rights and freedoms of others or is manifestly unfounded or excessive. You can make a subject access request by contacting anyone at Solon, preferably someone on our corporate services team.

Right of rectification:  You have the right to have your personal data rectified if it is inaccurate or incomplete.  If we have disclosed this to third parties, we will tell you if this is appropriate and we will inform them of the rectification where possible.  

We must respond within one month, extendable by two months where the request for rectification is complex.

Right of erasure: You have the right to request the deletion of personal data where there is no compelling reason for its continued processing or if we are processing it in an unlawful manner – for example if we are using it for a different purpose than originally stated. 

Right to restrict data processing:  Under certain circumstances, you have a right to ‘block’ or suppress processing of personal data. When processing is restricted, we are permitted to store the personal data, but not further process it. We can retain just enough information about you to ensure that the restriction is respected in future.

Right to data portability:  You can obtain and reuse your personal data for your own purposes across different services. This right applies where the processing is based on your consent or for the performance of a contract; and when processing is carried out by automated means.

Right to object:  You have the right to object to: 

·         Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);

·         Direct marketing (including profiling); and

·         Processing for purposes of scientific/historical research and statistics.

If we process personal data for the performance of a legal task or our organisation’s legitimate interests, you must have an objection on “grounds relating to you particular situation”  

We must stop processing the personal data unless: 

·         We can demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or

·    The processing is for the establishment, exercise or defense of legal claims.

·         The Personal Data is essential to the continuation of the tenancy or is in the ‘vital interests’ of the tenant. 

Right to Complain: You have the right to complain to the supervisory body Information Commissioner's Office (ICO) if you feel we have failed to meet our duties or obligations to you under the DPA in relation to your personal data.

You Maintain the Right to Withdraw Consent at any Time: You may contact Solon to request this. Although we may not be able to accept your request for certain types of data, please contact us if you wish to discuss this further.

Contacting Us

Please contact our Corporate Services Team or Data Protection Assistant to make any requests in relation to your data rights, or if you have any other queries about the Data Protection Act or Solon’s Data Protection Policy:

E-mail: james_naish@solonswha.co.uk      or        solon@solonswha.co.uk.

 

Phone: 0117 924 4071 or 0117 916 7795 (Direct Line)

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