Radcliffe Housing Society Ltd is a Registered Social Landlord and is registered with the Information Commissioner’s Office as a Data Controller under the General Data Protection Regulations 2018.
We take privacy seriously
Radcliffe Housing Society (RHS) complies with the General Data Protection Regulation (GDPR) 2018 in relation to personal information that you give us to ensure that it is not misused. The regulation defines a set of rules and guidelines we must follow when handling your information.
Why do we collect and store personal information?
RHS needs to collect, process and store personal information about you and other household members (when you provide information about household members we assume that you do so with their full knowledge and consent) in order to operate as a registered provider of housing and deliver efficient and effective services.
Basis for processing your personal information
Our main legal basis for processing personal data is where it is necessary for the purposes of the legitimate interests pursued by RHS or by a third party to process your information. We can do that so long as we do not interfere with your fundamental rights or freedoms.
Information we may hold about you and how we use it
The information we hold on our records concerns our relationship with you. For example:
- We hold names and dates of birth, photographic ID and information about your previous housing circumstances to assess housing applications and help prevent tenancy fraud;
- Your up to date contact details (telephone number and email address) are required so we can get in touch with you to discuss issues regarding your tenancy or lease, for example the collection of rent or other sums, receipt of benefits, essential servicing, access for maintenance and repairs and other service delivery. We may need to provide your contact details and relevant associated information to our contractors who may be undertaking work on your property on our behalf. We hold contact details for you so we can communicate with you by your preferred means and facilitate repairs to your home;
- We record information about your needs (for example, if you have a carer or social worker; if you need adaptations in your home) to ensure that we take account of any support needs in our interactions with you and to improve our communications with you;
- We record information to enable us to provide a variety of housing management services. For example we record reports of anti social behaviour; complaints; change in circumstances (for example when your employment status changes) and information about housing options (eg if you have a medical need which means you need to move);
- We keep financial records about the amount of money you have paid us; any amount(s) outstanding and action taken to recover money you owe.
- We may hold information about you if you are engaged with any additional guidance and support services;
- We may record or monitor your telephone calls to our office for training and monitoring purposes to ensure we are delivering a good service;
- We may capture your image on our CCTV system if you live at or visit a property covered by this facility. Any CCTV records will be held safely and securely before being erased;
- We record the findings of surveys and other research to help us improve our service to tenants. The information you provide will be anonymous unless you agree that we can use your details;
- We keep details of complaints received to help us monitor responses and resolutions to any issues raised. The information you provide may need to be passed to third parties such as our repairs and maintenance contractors.
Some of the organisations that we may share personal information with include, but are not restricted to:
- Legal advisers;
- Emergency services;
- Government departments including local authorities;
- Welfare advisers;
- Medical professionals;
- Other housing associations;
- Utility providers.
This list is not exhaustive. Generally the information we hold will have been provided by you (on application or when we communicate with you), but we may also hold information provided by third parties where this is relevant to your housing circumstances eg from social workers and health professionals (such as doctors and occupational therapists).
We will only ask for personal information that is appropriate to enable us to deliver our services. In some cases you can refuse to provide your details if you deem a request to be inappropriate. However, you should note that this may impact on our ability to provide some services to you if you refuse to provide information that stops us from doing so.
How we manage your personal information
We will process your personal information in accordance with the principles of GDPR.
We will treat your personal information fairly and lawfully and we will ensure that information is:
- Processed for limited purposes;
- Kept up to date, accurate, relevant and not excessive;
- Not kept longer than is necessary;
- Kept secure.
We are committed to keeping your personal details up to date and encourage you to inform us about any changes needed to ensure your details are accurate. To help us ensure confidentiality of your personal information we may ask you security questions to confirm your identity when you call us.
Right to be forgotten
We hold a variety of data types, which have different requirements for how long we need to keep it. We have a data retention schedule that describes the type of data we hold and their retention timescales. We follow legal requirements and best practice in this area. We will securely destroy / delete personal data when we no longer need it or no longer have a legitimate interest in keeping it.
The right of access
You have the right to ask to see the personal information we hold about you and ordinarily the right to have a copy provided to you or someone else on your behalf. A request to see this information is known as a “subject access request” (“SAR”).
SARs can be requested either verbally or in writing. If your request is verbal, we will need to ask you some verification questions to confirm your identity. Requests in writing to this office need to be accompanied with proof of your address and identity. If you require specific information, it is helpful if this is clear in your request, for example, information from a particular time period or about a specific correspondence. Your request will be responded to within 30 calendar days.
RHS will provide a copy of the information requested free of charge, however we can charge a “reasonable fee” when a request is manifestly unfounded or excessive, particularly if it is repetitive.
The right to rectification
You can ask us to correct your personal data if it is inaccurate or incomplete. Please help us to keep our records accurate by informing us if your details change.
The right to object
As we are generally relying on our “legitimate interests” as a reason for processing your personal data you can inform us if you object to our processing of your personal data. We can override this object in certain circumstances. RHS can refuse a request if it is considered to be manifestly unfounded or excessive. For further guidance please go to – https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-restrict-processing/
Rights in relation to automated decision making and profiling
There are some occasions where automated decisions are made about you using pre-programmed criteria on our systems, for example, eligibility for mutual exchange. You have the right to challenge the validity of any decisions made in this way and ask us to review this. You may also ask us not to process your information in this way.
Changes to this Privacy Notice
This privacy notice will be kept under review and updated as required. We recommend that you keep up to date via our website and tenant portal. We will let you know if we make any major changes to this Notice. The current version was first published in 2018.
Your right to lodge a complaint with a supervisory authority
If you are not satisfied with our response to any query about your personal information that you raise with us, or if you believe that we are processing your personal information in a way which is inconsistent with the law, you can complain to the Information Commissioner’s Office (“ICO”).
Please also contact the ICO if you require general advice on privacy and any data protection issues.
The Information Commissioner’s Office
0303 123 1113