Privacy Policy - Tai Calon

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.

We are also a “Data Controller”. This means that we are responsible for deciding how we hold and use 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 UK General Data Protection Regulation 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.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.

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 but is not limited to:

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
Proof of housing eligibility
Benefit details
CCTV footage
Marketing and communications data which includes your preferences in receiving marketing from us and your communication preferences
Support and action plans that are produced by us during your tenancy
Your employment history

We will also process the following “special categories” of more sensitive personal information 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:

Information about your race or ethnicity, religious beliefs, sexual orientation, sex life and political opinions.
Information about your health, including any medical condition or disability.
Trade union membership.

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 is your personal information collected?

We collect personal information about you in a variety of ways.

We collect personal information about our current and prospective tenants initially through the application process, in the majority of cases directly from you as the tenant (or applicant) but sometimes from a referring agency or other background check provider. We may also collect personal information directly from you via project referral forms and/or our Hanlon software system.

This information will be collated from identity documents, various forms, tenancy agreements and contracts and through our ongoing contact with you including over the phone and email. We may also collect personal information that you provide during in person or virtual Microsoft Teams meetings and/or interviews with us.

We may also process personal information about you that we’ve been given by third parties, including but not limited to:

former landlords;
credit reference agencies or other background check agencies;
care providers and other support agencies and/or volunteers;
doctors, other medical professionals and occupational health providers;
benefits agencies such as the DWP and/or Jobcentre Plus ; and/or
the local authority or the police.

The type of information that is shared could include, for example, information relating to a housing application, housing benefit claim or support package, or 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 will also collect additional personal information in the normal course of landlord/tenant activities throughout the period that you rent with us.

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 other legitimate business interests. 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’s Contact Centre has a call recording system in place for all of our incoming and outbound telephone conversations.

How will we 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).

We may also use your personal information in the following situations:

Where we need to protect your interests (or someone else’s interests).
Where it is needed in the public interest.

Additional legal bases are required when we process special category personal data and additional safeguards. In the case of information about criminal convictions and actual and alleged offences, this will only be collected and processed where it is appropriate to do so.

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 line with the terms of the relevant agreement. 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 and market research, asking you take part in a survey and inviting you to take part in focus groups

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 ensuring 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

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information.

We may process special categories of personal information in the following circumstances:

In limited circumstances, with your explicit written consent.
Where it is needed in the substantial public interest.
Where it is needed in relation to legal claims.
Where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent.
Where you have already made the information public.

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, employment and training 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.

Information about criminal convictions

We envisage that we may hold information about criminal convictions.

We may only use information relating to criminal convictions where the law allows us to do so.

In most cases, this will usually be where such processing is necessary in the public interest and provided we do so in line with our data protection policy. Such situations may include where we need to use the information when dealing with antisocial behaviour cases, to prevent or detect crime or unlawful acts (including protecting the public against fraud or dishonesty), to monitor equality of opportunity or treatment and for the purposes of safeguarding children and vulnerable individuals.

We may also use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

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’s Contact Centre has a call recording system in place for all of our incoming and outbound telephone conversations.

Who do we share your personal information with?

Your personal information may be shared internally by the housing team with finance and members of other teams in the relevant business areas when there is a genuine business need to do so.

In order to manage your tenancy, we sometimes also share your personal information with other third-party organisations or individuals where required by law, where it is necessary to administer the tenancy relationship with you or where we have another legitimate or public interest in doing so. In limited circumstances, we may share your personal information with other third parties with your explicit written consent.

Examples of third parties that we may share your personal data with include (but is not limited to):

contractors working for Tai Calon Community Housing in order to manage repairs, maintenance and adaptions of our properties;
organisations like the local authority or DWP, to allow them to process any claim for housing benefit that you might make or to provide a service to you;
the Police and other agencies for the purposes of crime prevention or detection;
emergency services and medical professionals;
welfare advisers;
utilities providers which we are required to do by law (see below for further information); or
third parties who are engaged to provide both our “out of hours” call centre and alarm monitoring services;
third parties used for the purposes of conducting tenant satisfaction surveys and research on our behalf (see below for some further information on this).

If you require further details in relation to the above, please contact our Data Protection Officer (whose details can be found at the end of this privacy notice).

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.

When a change of tenancy takes place at our properties, we will also share the following personal information with Dŵr Cymru Welsh Water in accordance with our obligations under the Water Industry (Undertakers Wholly or Mainly in Wales) (Information about Non-owner Occupiers) Regulations 2014:

full names and dates of birth of all occupiers of the property (other than any children under the age of 18); and
the date or dates on which occupation of the premises began.

We will only disclose CCTV images to third parties when we have a clear legal basis to do so.

We may also need to share your personal information with a regulator or to otherwise comply with the law. This may include HMRC or the housing regulator or making disclosures to social services or to the police or where we share information with our professional advisors.

We do not sell, rent or otherwise make personal information commercially available to any third party.

Our relationship with the Institute of Customer Services (ICS)

As an organisation, we continuously work to improve tenant satisfaction. This involves us working closely with third party market research companies for the purposes of conducting genuine market research, including tenant satisfaction surveys, on our behalf.

We have recently partnered with ICS to undertake a standardised benchmarking survey on our behalf which will be undertaken three times each year.

It is necessary for us to share some of your personal information with ICS (such as your name & personal email address) so that they can email you an individual URL code to enable to you partake in the survey

The purpose of us sharing your personal information with ICS is to further our legitimate interests which include:

ensuring we are a fit for purpose organisation;
to better understand and improve the service that we provide to you and all our tenants; and
to improve overall tenant satisfaction.

Please rest assured that the completed survey will be returned to us in an entirely anonymised format by ICS unless you specifically consent to us contacting you regarding your experience. Whilst it not compulsory for you to complete the survey, we really hope that you will take part as it will help us to better understand and improve the service that we provide you.

ICS is required to take appropriate security measures to protect your personal information in line with our policies. We require ICS to agree that they will use your personal data fairly, securely and only for research purposes and not for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with the terms of the data sharing agreement.

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 will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

The majority of your personal information is retained 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 and is available upon request.

Images captured by CCTV will be retained until they are overwritten; this is typically a 90 day 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 90 days 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.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a tenant of ours we will retain and securely destroy your personal information in accordance with our retention policy.

Is your personal information transferred outside of the UK?

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 data protection legislation.

If any personal information is transferred outside the UK, 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 a right of access to the personal information we hold about you (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
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 will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

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

For more information on individual’s rights, you may wish to visit the Information Commissioner’s website:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

Changes to the Privacy Notice

We will continually review and update this privacy notice to reflect changes in our services and feedback from our tenants, as well as to comply with changes in the law. This privacy notice was last updated on 24^th March 2022. 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@www.taicalon.org