This privacy notice tells you what to expect when Coast & Country Housing (CCH) processes personal information. It applies to information about applicants, customers and other service users. CCH is the Data Controller of all personal information you provide.
Coast & Country Housing, 14 Ennis Square, Dormanstown, Redcar, TS10 5JR) – 01642 771300 | email@example.com
Why do we collect and store personal information?
We need to collect, process and store personal information about you and other household members* in order to fulfil our obligations as a registered provider of social housing and to deliver efficient and effective services.
Our legal basis for processing your information will be at least one of the following:
- Contractual: 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 to protect 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.
*When you provide information about household members, it is your responsibility to ensure that you do so with their full knowledge and consent.
What information do we collect about you?
The information we collect about you may vary based on what service we provide to you and the relationship we have with you.
Typically, we need details like:
- Your name, dates of birth, photographic ID and information about your previous housing circumstances to assess housing applications
- 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
- 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.
As well as the information listed above, we also:
- Record information to help us to deliver housing management services including reports of anti-social behaviour, complaints, change in circumstances e.g. if you have a medical need which means you need to move
- Keep financial records about the amount of money you have paid us any amount outstanding and associated recovery action. Depending on your chosen method of payment, we may hold your bank account details
- 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 also:
- Record your telephone calls to us, as some calls to our contact centre are recorded for training and monitoring purposes so we can ensure we’re delivering a good service*
- Capture images on our CCTV systems if you visit an estate, office or community facility which is covered by such technology*
- 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 contact we have with you, or about you, and we process this information so we can deliver services to you.
How do we collect information about you?
We prefer to collect the information we need directly from you. That way, you know what we have and we can be sure you’ve provided us with the most accurate and up-to-date information.
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 (i.e. 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.
What do we do with the information we collect?
Processing of your personal information will be undertaken in accordance with the principles of the UK Data Protection Act 2018 (the Act) and the EU General Data Protection Regulation (the Regulation). Access to personal information is restricted to authorised individuals on a strictly need to know basis. 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 we encourage you to inform us about any changes needed to ensure your details are accurate. To help us to ensure confidentiality of your personal information we may ask you security questions to confirm your identity when you call us and as may be necessary when we call you.
We will not discuss your personal information with anyone other than you, unless you have given us prior written authorisation to do so. Anyone calling on your behalf may also be subject to security questions to ensure we’re taking adequate steps to protect your personal information.
We may apply markers to your information (for example, in relation to your vulnerability or health status) to enable us to tailor and deliver services to you. CCH only holds records during the period of our relationship and for a set period afterwards to allow us to meet our legal obligations including resolving any follow up issues between us.
How do we look after and secure your information?
We make every effort to keep your information safe by taking appropriate care to secure the information we hold about you.
- We have robust technical security such as passwords and information encryption
- We have policies and procedures to make sure your information is only available to our employees who need to see it to do their job, and we train those employees appropriately
- We establish robust agreements and contracts to extend these protections to any other person or organisation we may need to give your information to.
In everything we do with your information we try to be fair, lawful and open, and we take seriously our obligations towards your privacy and the protection of information we may hold about you.
When we use information about you we will:
- Take all reasonable efforts to do so fairly
- Never use information about you unless it is lawful for us to do so and we have a clearly defined need or purpose
- Make sure we minimise what we collect
- Try to collect enough accurate and up-to-date information so we can provide you with the excellent, efficient customer service you demand and no more
- Not keep your information for longer than we need it and make sure the records we have about you are managed properly and deleted promptly and securely when we no longer need them.
Who do we share your information with?
We appreciate you have provided your information to us and may not want us to share it with other people or organisations, however sometimes it is necessary for us to do so. Our relationships with such providers are governed by our contracts with them which include strict data sharing and confidentiality protocols.
We only share your information where we have a legitimate interest in doing so, where we are permitted or required to by law, or where you have requested us to do so. We may share your information with, for example:
- Our contractors, in order to undertake some repairs, maintenance or improvement works
- Third party service providers, in connection with services performed on our behalf. For example if we use a mailing house to distribute our newsletters
- Other registered providers, trusts and landlords, in connection with tenancy references and associated enquiries
- Community partners in connection with the delivery of co-ordinated local services
- Utility companies (and their representatives) and Council Tax Offices, to ensure billing details are correct
- Credit reference agencies and debt collection agencies, in connection with some housing applications and in relation to any outstanding charges
- Local authorities and government departments, as necessary for administering justice, or for exercising statutory, governmental, or other public functions
- Police and other relevant authorities (e.g. Probation Service, Department of Work and Pensions, HM Revenue 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 duty
- Other statutory organisations, e.g. social services and health authorities, as necessary for exercising statutory functions
- Our regulators, including the Regulator of Social Housing, 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:
- To meet our legal obligations
- In connection with legal proceedings (or where we are instructed to do so by court order)
- To protect the vital interests of an individual (in a life or death situation).
International Transfer of Personal Information
We do not envisage transferring any information about or relating to you to anyone who is located outside of the European Economic Area other than as indicated above and we have a commitment from our business partners and data processors that they too will honour this commitment.
Your Rights in Relation to your Personal Information
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 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 or 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 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 requested 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 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.
For further information on how to request your personal information and how and why we process your information, you can contact us using the details below:
Data Protection Officer
Coast & Country Housing
14 Ennis Square
01642 771300 | firstname.lastname@example.org
The Information Commissioner (ICO) is also a source of further information about your data protection rights. The ICO is an independent official body, and one of their primary functions is to administer the provisions of the UK Data Protection Act 2018 and the EU General Data Protection Regulation. You also have a right to lodge a complaint about any aspect of how we are handling your data with the ICO and can do so at the following address:
Information Commissioner's Office
0303 123 1113 | www.ico.org.uk
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 April 2018.