Hunters Hall Housing Co-op
GDPR Fair Processing Notice
(How we use your personal information)
This notice explains what information we collect, when we collect it and how we use this. During the course of our activities we will process personal data (which may be held on paper, electronically, or otherwise) about you and we recognise the need to treat it in an appropriate and lawful manner. The purpose of this notice is to make you aware of how we will handle your information.
Who are we?
Hunters Hall Housing Co-op is a registered society under the Co-operative and Community Benefit Societies Act 2014 with Registered Number 2271R(S) and has their Registered Office at 77 Niddrie House Drive, Edinburgh, EH16 4TR. We take the issue of security and data protection very seriously and strictly adhere to guidelines published in the [Data Protection Act of 1998] and the General Data Protection Regulation (EU) 2016/679 which is applicable from the 25th May 2018, together with any domestic laws subsequently enacted.
We are notified as a Data Controller with the Office of the Information Commissioner under registration number Z9141752 and we are the data controller of any personal data that you provide to us.
Our named contact in respect of data protection is Stuart Orr, Project Officer, Hunters Hall Housing Co-op. (e - mail: firstname.lastname@example.org ; Tel 0131 657 3379).
The legal basis for using your information
Personal data is collected which is a combination of contractual, legal and legitimate interest to enable the Co-op undertake its roles and responsibilities as a landlord.
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information where it is necessary to:
• To enter into or perform the contract (tenancy agreement or factoring agreement) we have entered into with you ( e.g. repairing your property);
• For our legitimate interests; and
• To meet our legal responsibilities (e.g. health and safety responsibilities)
There will be situations where we will seek your written consent such as when you ask us to provide you with welfare rights advice.
We may also use your information in the following, less common circumstances:
• To protect the vital interest of an individual ( a life of death situation); and
• To perform a specific task in the public interest
Our legitimate interests include:
• Analysing the information we collect so we can administer, support and improve and develop our business and the services we offer;
• To contact you for your views on our products and services;
• Adapting the way in which we communicate with you to meet your needs and preferences;
• To provide you with or signpost you to additional support services;
• To monitor and review equality of opportunity;
• To promote our organisation and services;
• To contact you in order ot notify you of any changes that may affect you;
• Managing payments for accounting purposes including issuing invoices;
• Ensuring rent is affordable and up to date
• The prevention and detection of crime; and
• Facilitate any necessary legal proceedings and adhere to statutory regulations
How we collect information from you and what information we collect
We collect information about you:
• When you apply for housing with us, become a tenant, request services / repairs, enter in to a factoring agreement with ourselves howsoever arising or otherwise provide us with your personal details
• When you apply to become a member;
• From your use of our online services, whether to report any tenancy related issues, make a complaint or otherwise;
• From your arrangements to make payment to us (such as bank details, payment card numbers, employment details, benefit entitlement and any other income and expenditure related information).
We collect the following information about you:
• Telephone number;
• E-mail address;
• National Insurance Number;
• Next of Kin;
• Other third party contact details;
• Household details;
• Employment details;
• Ethnicity, disability and gender;
• LGBT information;
• Date of birth;
• Nationality, Asylum or Immigration Status;
• Photographic identification
• Medical or health information – for adaptations to your home, to assess your transfer application, or to provide appropriate housing or services to sustain your tenancy
We receive the following information from third parties:
• Benefits information, including awards of Housing Benefit/ Universal Credit
• Payments made by you to us;
• Complaints or other communications regarding behaviour or other alleged breaches of the terms of your contract with us, including information obtained from Police Scotland;
• Reports as to the conduct or condition of your tenancy, including references from previous tenancies, and complaints of anti-social behaviour
Why we need this information about you and how it will be used
We need your information and will use your information:
• to undertake and perform our obligations and duties to you in accordance with the terms of our contract with you
• to enable us to supply you with the services and information which you have requested;
• to enable us to respond to your repair request, housing application and complaints made;
• to analyse the information we collect so that we can administer, support and improve and develop our business and the services we offer;
• to contact you in order to send you details of any changes to our or supplies which may affect you;
• for all other purposes consistent with the proper performance of our operations and business; and
• to contact you for your views on our products and services.
Sharing of Your Information
The information you provide to us will be treated by us as confidential /[and will be processed only by our employees within the UK/EEA. We may disclose your information to other third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:
• If we enter into a joint venture with or merge with another business entity, your information may be disclosed to our new business partners or owners;
• If we instruct repair or maintenance works, your information may be disclosed to any contractor;
• If we are investigating a complaint, information may be disclosed to Police Scotland, Local Authority departments, Scottish Fire & Rescue Service and others involved in any complaint, whether investigating the complaint or otherwise;
• If we are updating tenancy details, your information may be disclosed to third parties (such as utility companies and Local Authority);
• If we are investigating payments made or otherwise, your information may be disclosed to payment processors, Local Authority and the Department of Work & Pensions;
• If we are conducting a survey of our products and/ or service, your information may be disclosed to third parties assisting in the compilation and analysis of the survey results;
• If we are taking action against you, your information may be disclosed to our legal representatives;
• Your information may be disclosed to any contractor responsible for monitoring the personal safety of our staff;
• We may disclose your information to employees of other organisations who are providing a service on behalf of the Co-op, such as welfare rights or energy advice.
Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.
Transfers outside the UK and Europe
Your information will only be stored within the UK and EEA.
Were information to be transferred outside the UK or EEA we will ensure that there are adequate safeguards in place to protect your information in accordance with this notice.
When you give us information we take steps to make sure that your personal information is kept secure and safe.
• All electronic files are password protected and may only be accessed by authorised staff in the performance of their duties.
• Paper files are retained in locked cabinets and only accessed by authorised staff
• Information transferred to contractors (name, address and contact details) is securely managed and we ensure contractors are GDPR compliant
How long we will keep your information
We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you.
We will generally keep your information for the following minimum periods:
• 5 years for membership records
• 5 years for Management Committee documents after cessation of membership
• 5 years for applications for accommodation while application live
• Housing Benefit notifications for the duration of the tenancy
• Tenancy files for the duration of the tenancy
• 5 years for Former tenants’ files (key info)
• Third party documents for the duration of the tenancy
• Records re offenders for the duration of the tenancy
• 5 years after lease termination for lease documents
• 5 years from the end of legal action for ASB cases
• 3 years after cessation of fieldwork for tenant satisfaction files
While you are a tenant of the Co-op, we will keep the following information:
• Application for housing;
• Most recent notification of entitlement to housing benefit;
• Rent payment records;
• Details of complaints or harassment cases;
• Documentation and correspondence provided by other agencies in relation to your specific needs;
• Records relating to offenders, ex-offenders and persons subject to cautions;
• Repair history at your address;
• Photographic identification
after which this will be destroyed if it is no longer required for the reasons it was obtained.
When you end your tenancy, we will dispose of your information, but will retain a copy of your tenancy agreement and a summary of your tenancy details.
You have the right at any time to:
• ask for a copy of the information about you held by us in our records;
• require us to correct any inaccuracies in your information;
• make a request to us to delete what personal data of your we hold; and
• object to receiving any marketing communications from us.
If you would like to exercise any of your rights above, you can complete a Subject Access Request form
As of 11 November 2019, Hunters Hall is deemed to be a Public Authority under the Freedom of Information (Scotland) Act 2002 and is, therefore, required to appoint a Data Protection Officer.
We have engaged RGDP LLP (www.rgdp.co.uk) to act as our Data Protection Officer.
To contact them, please email email@example.com Please also copy us in at: firstname.lastname@example.org