This privacy notice relates to the Selwood Housing Group and outlines what information we hold about you and how we collect and use your personal data. This privacy notice is applicable to all tenants, customers, employees, board members, consultants and all users of the Selwood Housing Group services.
Selwood Housing Group may regularly review and update this privacy notice to make sure we comply with all the necessary regulations. It is important that you read this privacy notice carefully, along with all other information we give you, to confirm how we collect and use your personal data.
This privacy notice does not form part of your tenancy agreement or employment contract. This privacy notice is effective from 25 May 2018.
The Selwood Housing Group is based in Trowbridge, Wiltshire and includes a group of companies working together to improve homes and communities.
The Group is made up of Selwood Housing, Silcoa Limited, Cottsbury Homes Limited and Selwood Devco.
Selwood Housing is a data controller registered with the ICO (Information Commissioner's Office) (Registration Number Z6454476). Selwood Housing is a not-for-profit housing association with over 6,400 homes for rent at affordable prices in Wiltshire, Somerset and Bath and North East Somerset. We also offer shared ownership, and other schemes to provide a wide variety of homes for people living in our communities.
Silcoa Limited is a data controller registered with the ICO (Registration Number ZA107249). Silcoa is our repairs and improvement company. It is a social enterprise wholly owned by Selwood Housing.
Cottsbury Homes is a data controller registered with the ICO (Registration Number ZA327122). Cottsbury Homes is wholly owned by Selwood Housing and develops and sells homes at market value.
Selwood Devco is a subsidiary of Selwood Housing and is a construction company that contracts with builders and consultants. Selwood Devco does not handle or process personal data and therefore there is no requirement to be registered with the ICO.
Our Group head office is located at Bryer Ash Business Park, Bradford Road, Trowbridge, Wiltshire, BA14 8RT. Telephone 01225 715 715.
Our data protection officer is Arawak Ltd, represented by Pritima Balgobin and can be contacted on email firstname.lastname@example.org
Types of personal data collected
Personal data means any information relating to an individual which uniquely identifies them, directly or indirectly.
The information we require from you includes:
- your full name (proof of identification - passport, drivers licence, birth certificate)
- contact details - telephone number and email
- National Insurance number
- date of birth
- CCTV images.
We also collect and process the following information on our tenants, former tenants and prospective tenants:
- household members - full name, date of birth, age, gender, relationship to main housing applicant
- current address, previous addresses
- physical health conditions
- mental health conditions
- disabilities, mobility issues, learning difficulties
- medication details
- other health, support and behaviour details including drug issues, alcohol issues, criminal convictions and offences, and probation details.
- financial details including current employment, benefits, bank account details, debts, income, pensions and expenditure.
- children's personal data; their full name, age and date of birth, may be captured as part of the tenancy agreement.
The information we require from potential candidates, board members and employees includes:
- recruitment information including references, correspondences, right to work checks and related documents, qualifications and training
- emergency contacts
- employment details including start date, contractual terms, job title and previous employment details
- payroll and bank details
- pay benefits including pension schemes, incentive schemes and expenses
- Holidays and other leave, sickness absences and medical information, and family leave (maternity and paternity)
- disciplinary, conduct and grievance matters
- special categories of personal data for equal opportunities and diversity including health, religious beliefs, relationship status, sexual orientation, trade union membership and ethnicity.
- criminal convictions and offences.
How is your personal data collected
Selwood Housing Group may collect your personal data directly from you using various methods:
- application for tenancy and/or employment opportunity made through telephone, email or visiting at reception
- face to face pre tenancy interview
- application through our recruitment online portal.
Personal data can also be collected from third party organisations and external sources. This would happen when you make an application for a tenancy through the council and/or a job application through an agency. Further information about you may be collected from publicly available sources including social media. References will be collected from previous and current employers.
In some instances, you may provide personal details about someone else. This may include details of an emergency contact and next of kin and details of other household members. In this case, you are required to inform the individual that their personal data will be shared with Selwood Housing and the details of what data was shared. You must also give them our contact details and let them know that they should contact us if they have any queries about how we will use their personal data.
Why we collect your personal data
The lawful basis for processing your personal data may be for:
- the performance of a contract
- our legitimate interest
- a legal obligation
We collect and process personal data in order to provide you with housing and tenancy services. This also covers for the performance of and maintenance of your tenancy agreement. Personal data is also collected for the administration of your employment contract and a contract for services.
Personal data is collected about you for the following purposes:
- to process your tenancy application or for recruitment purposes
- in order to confirm your identity
- in order to contact you when we need to
- in order to provide you with services that meet your needs
- to inform you of other services that may be of interest to you
- to help you claim benefits
- to investigate complaints
- to investigate breaches in terms of your tenancy or employment contracts
- to meet the requirements of our regulators, such as the regulator of social housing
- in order to manage employment contracts and in our legitimate interest to:
- analyse pay and benefits
- make decisions about appropriate compensations
- ensure effective business operation
- manage performance
- ensure appropriate training and qualifications for various roles
- to effectively manage disciplinary, grievances and sickness leave and absences
- for the assessment of working capacity. (This refers to the level of work the employee can perform and whether further training is required.)
- in order to manage your tenancy agreement and in our legitimate interest by ensuring maintenance and repair work is carried out, ensuring your details are updated with different utility companies and ensuring rent arrears are managed.
- to comply with relevant legislation and regulation
- personal data on children is required as a legal obligation and in the legitimate interest of Selwood Housing. This is to assess the needs of our tenants and to make sure that properties are not overcrowded. Personal data on children is also required if there is a safeguarding or welfare case.
- to meet our legal obligations, such as those relating to equality and diversity, health and safety and safeguarding
- to help prevent and detect crime and prosecute offenders
- telephone calls are recorded for training and monitoring purposes
- CCTV images are captured at office premises and various housing locations for the prevention and detection of crime
- photographs are taken of employees, contractors and subcontractors to help colleagues, tenants and security to identify you.
- photographs of tenants and customers may be taken for marketing and publicity purposes. These are taken at various events and at tenancy properties. Photographs are taken and used only with consent.
Who is your personal data shared with
Selwood Housing may be required to share your personal data with third party organisations from time to time. Personal data will be shared when there is a legal ground under the data protection regulation to do so. Sharing of personal data is also necessary to meet and comply with our contractual obligations and where necessary in our legitimate interest.
Sharing of personal data relating to tenants may include:
- with contractors and sub contractors who carry out various maintenance and building services on our behalf. All contractors and sub contractors are required to sign and comply with our data sharing agreements.
- with utility companies providing details of new tenants. We may also provide details and forwarding addresses of former tenants who have left with arrears.
- details of tenants who have left with rent arrears will be shared with debt collection agencies.
- personal data may be shared with government departments, Wiltshire Council, with our regulators and auditors, and other legal entities where there is a legal obligation to share your personal data.
- personal data may be shared with solicitors, insurance brokers and financial advisors.
- credit check agencies for identification of fraud
Sharing of personal data relating to employees may include:
- for the management of payroll services, via Access UK and MHR International UK Limited
- in order to administer pension and benefits via Wiltshire Pension Fund and Scottish Widows
- to facilitate the recruitment function and ensuring safer recruitment processes for working with vulnerable adults via Networx recruitment
- in order to assist with business and company operations via ADP
- personal data may be shared with counselling services, employment agencies, legal and other professional advisers, potential purchasers, customers and interested parties.
- in order to manage sickness and health issues with occupational health and medical professionals
- personal data may be shared with the HMRC and DWP
- personal data may also be shared with other third party organisations including insurance companies and for employment references.
We have installed CCTV at our Bryer Ash and Willowside offices to help keep staff and members of the public safe and to prevent and detect crime. We will only release CCTV images for these purposes. Images will not be used for entertainment purposes.
You have the right to see CCTV images of yourself and be provided with a copy of those images. We have put up signs advising you that CCTV is in place and who to contact for further information. CCTV images are held for a maximum of 30 days.
How long is your personal data stored
Personal data collected by Selwood Housing is kept for as long as is necessary for the various purposes mentioned, and in line with our data retention schedule.
How long we hold your data for varies, depending on the type of personal data and the purposes for processing the data. Factors which affect how long personal data is held are also dependent on relevance to possible future claims, and where applicable, legal, accounting, reporting, finance and regulatory requirements.
For more details on our data retention schedule, please contact us at email@example.com
Under the general data protection regulation (GDPR) and UK data protection legislations, you have a number of legal rights that relate to your personal data held by us.
These include the following:
- your right to a subject access request:
- you may lawfully make a request to receive certain information on how we use your personal data and;
- receive a copy of personal data we hold on you; and
- check that we are lawfully processing your personal data.
If a request is made, you will not be charged and we will aim to respond to your request within 30 calendar days.
In responding to your subject access request, we will firstly ask you to confirm your identity by providing a copy of your passport or driving licence. If we do hold information about you, we will provide you with a description of the data as well as a copy of the requested personal data in a clear printed format or in a commonly used electronic format.
- your right to request that incomplete and inaccurate data are updated appropriately
- your right to request that we delete personal data that we hold about you. This may happen if you no longer wish to use our services, remain an employee or board member or if there is no justifiable reason for us to keep your personal data.
- your right to object to us processing your personal data if we cannot show a convincing reason for doing so
- your right to request us to restrict processing your personal data if the accuracy of the personal data is of concern, or if you believe the processing is unlawful
- your right to data portability. You can request for us to transfer your personal data to you or another third party in an agreed structured format.
If you would like to exercise any of the above rights, please write to us at:
Group Head of ICT, Bryer Ash Business Park, Bradford Road, Trowbridge, Wiltshire, BA14 8RT. Email firstname.lastname@example.org
If you wish to make a complaint to the information commissioner's office on how we process and collect your data, you can do so by contacting their office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. You can also call them on 0303 123 1113 or 01625 545745.