Privacy Notice

Who are we?

Tai Calon Community Housing Ltd (“we” or “us”) is a charitable registered social landlord and is registered under the Co-operative and Community Benefit Societies Act 2014. Tai Calon Community Housing Ltd is also a Data Controller and responsible for your personal data.

 

We take privacy seriously

Your privacy is important to us.  We are committed to protecting the privacy and security of your personal information. We make sure we comply with all aspects of the UK’s data protection framework including the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

This privacy notice explains what personal information we collect from you and how we use it.  It applies to current, prospective and former tenants.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

 

What personal information do we process?

Most of the personal information that we process is information that you’ve given us about you and the people who live with you.  This includes:

  • Personal contact details like your name, title, address, telephone numbers and personal email addresses
  • Date of birth, gender, marital status and dependents
  • Emergency contact information
  • National insurance number and bank account details
  • CCTV footage.

We will also process “special categories” of more sensitive personal information such as your race or ethnic origin, religion, and information concerning your health (including any medical condition or disability) or sexual orientation but we will only do this where there is a clear reason for us to do so or where you make it public or volunteer it to us.

In addition to the above, when we deal with antisocial behaviour cases, safeguarding issues or legal disputes we may process information relating to criminal convictions or allegations.

 

How we will use information about you

We will only use personal information about you when the law allows us to. We rely on the following legal bases to process your personal information:

Performance of a contract  This applies where we need to collect and use your personal information in order to takes steps to enter into a contract with you or to perform our obligations under a contract with you
Legal obligation This applies where we need to collect and use your personal information to comply with applicable laws and regulatory requirements
Legitimate interests  We may collect and use your personal information to further our legitimate business interests. We only do this where we are satisfied that your privacy rights are protected satisfactorily. We’re committed to putting you in control of your data and you’re free at any time to opt out from any activity we’re undertaking based on this legal basis.
Consent  We may (but usually do not) need your consent to use your personal information. You can withdraw your consent by contacting us (see below).
Public interest Although we are not a public body, we do collect and use some personal information where this is necessary to perform tasks that are in the public interests.

 

Why do we collect and process your personal information?

We process your personal information, including any special categories of personal information, primarily to allow us to manage your tenancy. In some cases we may use your personal information where it is in the public interest for us to do so or to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. In more rare situations, we may need to use your personal information to protect your interests or someone else’s interests.

The situations in which we will process your personal information and our legal bases for processing are set out in the table below:

 

Purpose/Activity Lawful basis for processing
To process your tenancy application Performance of  a contract with you

Necessary for our legitimate interests (to provide suitable housing)

Necessary in the public interest

 

Administering the tenancy agreement you hold with us including monitoring compliance and dealing with its termination Performance of a contract with you

Necessary for our legitimate interests (to provide suitable housing)

Managing your account charges and payments, including payment of any arrears which you may owe. Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

Necessary in the public interest

Managing the repairs, maintenance and adaptions of our properties (including the property you are allocated) Performance of a contract with you

Necessary for a legal obligation

Necessary for our legitimate interests (to provide suitable housing)

Necessary in the public interest

Offering and brokering help with debts and benefits Necessary for our legitimate interests (to assist with helping our tenants achieve financial health)

Necessary in the public interest

Dealing with legal disputes involving you or other tenants. Necessary for our legitimate interests (in resolving  disputes or defending our legal rights)

Necessary for a legal obligation

Necessary in the public interest

Complying with health and safety obligations. Performance of a contract with you

Necessary for a legal obligation

Necessary for our legitimate interests (to provide safe housing and community spaces)

Necessary in the public interest

To promote a safe and positive living environment for the community Necessary for our legitimate interests (to provide safe housing and community spaces)

Necessary in the public interest

To prevent and detect crime or unlawful acts, including nuisance and fraud. Necessary for a legal obligation

Necessary for our legitimate interests (in preventing or detecting crime)

Necessary in the public interest

To provide you with support services (such as help with training and employment or support services such as help with your personal safety, independence, economic support and health and wellbeing), products or information you asked for Performance of a contract with you

Necessary for our legitimate interests (to ensure the well-being of our tenants)

To undertake equal opportunities monitoring Necessary for our legitimate interest (to ensure that our housing activities are fair)

Necessary in the public interest

To better understand how we can improve our services, products or information by conducting analysis, market research and asking you take part in a survey Necessary for our legitimate interests (to ensure we are a fit for purpose organisation and to improve the service that we provide to you)
To send you correspondence and communicate with you, including updating your contact details Performance of a contract with you

Necessary for our legitimate interests (in managing your tenancy)

To otherwise carry out the day-to-day operations of our organisation efficiently including managing our financial position, capability, planning, communications, corporate governance and audit Necessary for a legal obligation

Necessary for our legitimate interests (in managing our organisation)

Necessary in the public interest

Some of the above grounds for processing will overlap and there may be several bases which justify our use of your personal information.

If you fail to provide certain information when requested, we may not be able to provide all our services to you and we wouldn’t be able to provide you with a tenancy. We may also be prevented from complying with our legal obligations (such as to ensure the health and safety of our tenants).

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

How we use particularly sensitive information

We will use your particularly sensitive personal information in the following ways:

  • We will use information about your physical or mental health, or disability status to ensure that we provide suitable (maintained and adapted) accommodation for disabled persons or those with problems around substance abuse.
  • When resolving neighbourhood disputes involving alleged criminal activity.
  • When helping someone to access care services.
  • When preventing or detecting crime or unlawful acts (including protecting the public against fraud or dishonesty).
  • When monitoring equality of opportunity or treatment.
  • When safeguarding children and vulnerable individuals.
  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations, carry out tasks in the public interest or protect vital interests. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

We will also use information about criminal convictions when dealing with antisocial behaviour cases, legal disputes or safeguarding issues.

We are allowed to use your personal information in this way because it is in the public interest for us to do so. We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

 

Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

 

Where do we get your personal data from?

Sometimes we process personal information about you that we’ve been given by other organisations such as the local authority or the Police.  This could include, for example, information relating to a housing application, housing benefit claim or support package, or something like antisocial behaviour.  The other organisation would only share this information with us, though, where either you’ve given them permission to do so or the law allows them to do so.

We have installed CCTV systems at our Head Office and at some of our locations used by staff, tenants and members of the public, for the purposes of public and staff safety, crime prevention and detection and business related functions.  In all locations, signs are displayed notifying you that CCTV is in operation and providing details of who to contact for further information about the scheme.

Tai Calon has a call recording system for all of our external telephone conversations.

   

Who do we share your personal information with?

In order to manage your tenancy, we sometimes share your personal information with other people or organisations.  This includes contractors working for Tai Calon Community Housing; organisations like the local authority, to allow them to process any claim for housing benefit that you might make or to provide a service to you; or the Police and other agencies for the purposes of crime prevention or detection; or utilities providers which we are required to do by law; or third parties used to conduct research on our behalf.

In order to provide you with additional support, we sometimes share your personal information with organisations such as potential employers, training providers and other appropriate agencies who can provide you with support to find a job or relevant training.

We only do this though, if you consent for us to do so, where there are laws that allow us to do so, if it’s necessary for us to do so in order for us to manage your tenancy, we have a legitimate interest in doing so, or to protect your vital interests.

We will only disclose CCTV images to others who intend to use the images for the purposes of public and staff safety, crime prevention and detection and business related functions.

 

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

 

How long do we hold your personal information for?

We hold personal information in line with the guidance issued by the National Housing Federation and around good practice.  We have a document retention policy in place which is reviewed regularly.

Images captured by CCTV will be retained until they are overwritten; this is typically a 3 month time period. However, on occasions there may be a need to keep images for longer, for example where a crime is being investigated. 

Call recordings will be kept for 24 hours from the point the call was made. However, on occasions there may be a need to keep the call for longer, for example where a complaint is being investigated.

 

Is your personal information transferred outside of the European Economic Area (EEA)?

Much of the personal information that we process at Tai Calon is held electronically, and most of this is held in our offices in Blaenau Gwent.  Some of our computer systems store the information off-site though and, when they do, we work closely with the software providers to make sure that the information is stored in accordance with the requirements of the GDPR.

If any personal information is transferred outside the EEA , we will make sure that suitable safeguards are in place.

 

What rights do you have?

You have a number of rights when it comes to your personal data.

 

Under certain circumstances, by law you have the right to:

  • You have a right of access to the personal information we hold about you (commonly known as a “data subject access request”).
  • You have the right to ask us to correct any information we hold about you that you think is wrong or incomplete.
  • You have the right to object to any processing of your personal information where we are relying on a legitimate interest to do so and you think that your rights and interests outweigh our own and you wish us to stop. There may, however, be legal or other legitimate reasons why we need to keep or use your information. If this is the case, we will consider your request and explain why we cannot comply with it. You can ask us to restrict the use of your personal information while we are considering your request.
  • You have the right to object if we process your personal data for the purposes of direct marketing. If you no longer want to receive communications from us, please contact us. We will stop sending you communications, but will continue to keep a record of you and your request not to hear from us. If we deleted all of your information from our direct marketing databases, we would have no record of the fact that you have asked us not to communicate with you and it is possible that you may start receiving communications from us at some point in the future, if we obtain your details from a different source.
  • You have the right to ask us to delete your information. This is also known as the right to be forgotten or to erasure. We will not always agree to do this in every case as there may be legal or other legitimate reasons why we need to keep or use your information. If this is the case, we will consider your request and explain why we cannot comply with it. You can ask us to restrict the use of your personal information while we are considering your request.
  • Where our processing of your personal information is based on your consent, you have the right to withdraw it at any time. Please contact us if you wish to do so. However, please bear in mind that if you withdraw your consent, we may not be able to provide the full range of tenant services to you. We will advise you if this is the case at the time you withdraw your consent.
  • You may have a right to obtain the personal information that you have given us in a format that be easily re-used and to ask us to pass this personal information on in the same format to other organisations. Please contact us to find out if this right applies to you.

`You also have the right to lodge a complaint at any time to a supervisory authority, the Information Commissioner’s Office for the UK.

 

Changes to the Privacy Notice

We will continually review and update this privacy notice to reflect changes in our services and feedback from customers, as well as to comply with changes in the law. We encourage you to check this privacy notice for any changes on a regular basis.

 

Further Information

If you would like to know more or have any concerns about how your personal information is being processed, you may contact us by post, telephone or email using the details below:-

 

Tai Calon Community Housing Ltd,
Solis One,
Rising Sun Industrial Estate,
Blaina,
Blaenau Gwent,
NP13 3JW

Tel: 0300 303 1717

Our Data Protection Officer is Vicki Thomas and you can contact her on the telephone number above or at vicki.thomas@taicalon.org