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 are the Data Controller of all personal information that you provide.
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.
*When you provide information about household members, it is your responsibility to ensure that you do so with their full knowledge and consent.
Information we may hold about you and how we use this
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, 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 hold recordings of 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**
- 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.
*We would like to provide you with information about other products and services (of ours and other reputable companies we work with) which do not form part of our core landlord services but which we think may be of interest to you. This would include information such as accessing training and employment, financial guidance and digital support. 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 never provide your personal information to other companies for their marketing purposes.
**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.
Our legal bases for processing your information for all of the above purposes are:
- 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 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.
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 we manage your personal information
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.
Sharing your personal information
Normally, only our employees will be able to see and process your personal information. However, there may be times when we will share relevant information with third parties for the purposes as outlined in section two, or where we are legally required to do so. When sharing personal information, we will comply with all aspects of the Act and the Regulation.
Sensitive information about health, sexual life, race and religion for example is subject to particularly stringent security and confidentiality measures.
Where necessary or required, we may share your personal information as follows:
- With our contractors, in order to undertake some repairs, maintenance or improvement works
- With third party service providers, in connection with services performed on our behalf. For example if we use a mailing house to distribute our newsletters
- Our relationships with such providers are governed by our contracts with them which include strict data sharing and confidentiality protocols
- With other registered providers, trusts and landlords, in connection with tenancy references and associated enquiries
- With community partners in connection with the delivery of co-ordinated local services
- With utility companies (and their representatives) and Council Tax Offices, to ensure billing details are correct
- With credit reference agencies and debt collection agencies, in connection with some housing applications and in relation to any outstanding charges
- With local authorities and government departments, as necessary for administering justice, or for exercising statutory, governmental, or other public functions
- With police and other relevant authorities (e.g. Probation Service, Department of Work and Pensions, 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 duty
- With other statutory organisations, e.g. social services and health authorities, as necessary for exercising statutory functions
- With our regulator, the Homes and Communities Agency (HCA), 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 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 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 January 2018.
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