PROTECTING YOUR PRIVACY
Connect Housing Association is committed to protecting the rights to privacy of its tenants and clients. We appreciate the importance and confidentiality of the personal information that you disclose to us. This includes when accessing the Association’s services, signing a tenancy agreement or visiting our website, we will always take great care to fulfil our responsibilities under current Data Protection legislation.
Connect Housing Association is a Data Controller with its registered address at
205 Roundhay Road, Harehills, Leeds, LS8 4HS, United Kingdom; telephone number 0300 5000 600. As a data controller, this means that Connect Housing Association determines how the personal data that you provide to us will be used to carry out the business of the organisation.
WHAT PERSONAL DATA DO WE HOLD?
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.
We hold your contact details so we can communicate with you, and to keep you informed about other services we offer which may be useful to you.
We record information about your needs and requirements to ensure our services are accessible; that we take account of any support needs in our dealings with you; and to improve our communications with you. For example, if you are involved with a carer or social worker, if you need adaptations in your home, if you need large print or translated text.
We record information to help us to deliver housing management services including reports of anti-social behaviour, in order to investigate complaints, change in circumstances e.g. 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 associated recovery action. Depending on your chosen method of payment, we may hold your bank account details.
We may hold information about you if you are engaged with our additional guidance and support services. For example, in connection with access to training and employment we may hold information about your job history and skills and experience, or if we support you to improve your financial circumstances, we may hold information about your household income and expenditure.We may capture your image on our CCTV systems if you visit an estate, office or community facility which is covered by this facility.We may carry out insight and satisfaction surveys to help us to monitor our performance and to improve our services to our customers.Call recordings and CCTV recordings will be held in accordance with our Information Security and Data Protection Policy before being erased.
We may capture your image on our CCTV systems if you visit an estate, office or community facility which is covered by this facility.
We may carry out insight and satisfaction surveys to help us to monitor our performance and to improve our services to our customers.
Call recordings and CCTV recordings will be held in accordance with our Information Security and Data Protection Policy before being erased.
This list is not exhaustive, as we hold records of most contacts we have with you, or about you, and we process this information, so we can deliver services to you. Generally, the information we hold will have been provided by you (on application or enquiry forms or when we communicate with you), but we may also hold information provided by third parties where this is relevant to your housing circumstances e.g. from social workers and health professionals (e.g. 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 our ability to provide some services to you if you refuse to provide information that stops us from doing so.
HOW WILL WE USE YOUR PERSONAL DATA?
The personal data that you provide to us when you sign your tenancy agreement with Connect Housing Association will enable us to fulfil our obligations to you and provide you with the appropriate services and support that you may require. Under Data Protection legislation, Connect Housing Association must have a legal basis to process your personal data. Usually this falls within our contractual obligations to fulfil the tenancy agreement, however it could be through your consent or it may be necessary for the legitimate interests of Connect Housing Association or a third party.
To enable us to provide you with the best service possible, Connect Housing Association may use your personal details:
for market research purposes and to get your views and feedback to help us improve the services you receive.
to ensure that we are meeting all our customers’ needs and improve our services. We may segment the data we hold in order to do that.
We may also contact you and members of the public about our services and products and ask you if you would like to get involved in the activities and groups which we hold for tenants, e.g. in our Thrive space at our Dewsbury Office. We will aim to seek your preferences about how you would like to be contacted and these preferences can be changed at any time. The legal basis for processing data in this way is the pursuit of legitimate business interests.
Our legal basis for processing your information for all of the above purposes is:
Contract: the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
Legal Obligation: the processing is necessary for us to comply with the law (not including contractual obligations)
Vital Interests: the processing is necessary to protect someone’s life
Legitimate interests: the processing is necessary for our legitimate interests, or the legitimate interests of a third party, unless there is a good reason toprotect your personal data which overrides those legitimate interests
Consent: you have given clear consent for us to process your personal data for a specific purpose
WHO WILL WE SHARE YOUR PERSONAL DATA WITH?
On occasion it will be necessary to share your personal data with third parties. For example, Connect Housing uses a number of contractors to maintain and service its properties. However, Connect Housing will only share relevant and necessary information with them and in such circumstances we will have a Data Processing Agreement in place that ensures your data is used properly and protected.
Wherever possible we will aim to gain consent from you before sharing your personal information with third parties, such as debt advice and mental health services when providing you with any necessary support that you may require. However sometimes circumstances mean that we are unable to do so. Information sharing with agencies such as the Police, HM Courts & Tribunal Services and Social Services is vital to safeguarding and promoting the welfare of children, young people and vulnerable adults. Connect Housing may share information with these agencies without seeking consent, for example concerns about the welfare of children or vulnerable adults, certain types of criminal activity or health and safety hazards.
Connect Housing holds a number of information sharing agreements/data processing agreements where we share information regularly with organisations; this ensures that data shared is processed in accordance with the law.
Examples of organisations where we share information with include but are not limited to:
Department of Work & Pensions
Utility companies (and their representatives) and Council Tax Offices, to ensure they have the correct address details and tenants are correctly charged
Contractors and suppliers working for Connect
Local Authorities re: housing registers, multi-agency working and social services, as necessary for administering justice, or for exercising statutory, governmental, and other public functions such as handling safeguarding issues
The Police and other relevant authorities (e.g. Probation Service, HM Revenues and Customs) in relation to the prevention or detection of crime and fraud; the apprehension or prosecution of offenders and the assessment or collection of tax or dutyWith third party service providers, in connection with services performed on our behalf. For example a confidential waste disposal company shredding our documents
With third party service providers, in connection with services performed on our behalf. For example a confidential waste disposal company shredding our documents
With other registered providers, trusts and landlords, in connection with tenancy references and associated enquiries
With partners in connection with the delivery of services
With credit reference agencies and debt collection agencies, in connection with
some housing applications and in relation to any outstanding charges
- With our regulator, the Regulator of Social Housing (ROSH), to comply with our regulatory obligations
This list is not exhaustive as there are other circumstances where we may also be required to share information, for example:
TECHNICAL AND ORGANISATIONAL MEASURES
Connect Housing has a number of electronic and physical security measures to ensure the safety of your personal data, only authorised personnel have access to your personal data and all staff are bound by our Acceptable Use Policy.
Any information you submit during the course of an online application on our website is transmitted directly to Connect Housing’s IT system and is stored securely. It is not stored on our website and is not accessible by anyone else.
Our website may contain links to other websites run by other organisations. This Privacy Notice only applies to the information that we hold on our website, therefore we encourage you to read the privacy notices on the other websites you visit.
INTERNATIONAL TRANSFERS OF PERSONAL DATA
Connect Housing Association uses Survey Monkey to facilitate the sending of member surveys from time to time. Survey Monkey subscribes to the EU-US Privacy Shield and their registration can be reviewed on the Privacy Shield website.
HOW LONG DO WE RETAIN YOUR INFORMATION?
We will usually store your personal data for a maximum of 6 years post tenancy, except for certain documentation such as tenancy agreements and care plans which we may need to retain longer for legal or safe guarding reasons. We will not keep your information for longer than is necessary and it will always be in line with legal or regulatory requirements explained in Connect Housing’s Data Retention Policy.
You have the right to access any of your personal information we have used, to correct any erroneous information, and in certain circumstances, erase the data.
Right of Access
You have the right of access to information we hold about or concerning you. If you would like to exercise this right, please do so in writing. We have a subject access request (SAR) form which you can use for this purpose and we ask that your written request is accompanied by proof of identity. If you are seeking to obtain specific information (e.g. about a particular matter of from a particular time period), it helps if you clarify the details of what you would like to receive in your written request. If someone is requesting information on your behalf, they will need written confirmation from you to evidence your consent for us to release this and proof of ID (both yours and theirs). We have one month to provide you with the information you’ve asked for (although we will try to provide this to you as promptly as possible). In response to SARs, we will provide you with a copy of the information we hold that relates to you. This will not generally include information about your property such as repair logs, details of contractor visits, or general property maintenance information as this is unlikely to be ‘personal information’.
Right of Rectification or Erasure
If you feel that any data that we hold about you is inaccurate, you have the right to ask us to correct or rectify it. You also have a right to ask us to erase information about you where you can demonstrate that the data we hold is no longer needed by us, or if you withdraw the consent upon which our processing is based, or if you feel that we are unlawfully processing your data. Your right of rectification and erasure extends to anyone we have disclosed your personal information to and we will shall take all reasonable steps to inform those with whom we have shared your data about your request for erasure.
Right to Restriction of Processing
You have a right to request that we refrain from processing your data where you contest its accuracy, or the processing is unlawful and you have opposed its erasure, or where we don’t need to hold your data anymore but you need us to in order to establish, exercise or defend any legal claims, or we are in dispute about the legality of our processing your personal data.
Right to Portability
You have a right to receive any personal data that you have provided to us in order to transfer it onto another data controller where the processing is based on consent and is carried out by automated means called a data portability request.
Right to Withdraw Consent
Where you have provided your consent to the collection, processing and transfer of your personal data, you may withdraw that consent at any time. This will not affect the lawfulness of data processing based on consent before it is withdrawn. To withdraw your consent please write to Business Assurance Officer at Connect Housing, alternatively you can contact 0300 5000 600 or e-mail CS@Connecthousing.org.uk
Right to Object
You have a right to object to our processing of your personal data where the basis of the processing is our legitimate interests including but not limited to direct marketing and profiling.
You also have a right to lodge a complaint with the Supervisory Authority (Information Commissioners Office (ICO) in the UK at www.ico.org.uk), should you feel that we have not handled your information in line with legislative and regulatory requirements. They can be contacted at:
Information Commissioners Office Wycliffe House
Tel: 0303 123 1113 | Visit: www.ico.org.uk
For further information on how to request your personal information, how and why we process your information, you can contact us using the details below:
Business Assurance Officer Connect Housing
21 Bond Street
Tel: 0300 5000 600 | Email: email@example.com
CHANGES TO THIS PRIVACY NOTICE
We may change this privacy notice from time to time, but if we change it in a way which significantly alters the terms upon which you have agreed, we will post notice of the change on our website and you will be deemed to have accepted such changes. This privacy notice was last updated May 2018.