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 ensure we comply with all the necessary regulations. It is important to ensure 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 25th 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 email@example.com
Types of Personal Data Collected
Personal data means any information relating to an individual or data subject who can be identified directly or indirectly, in particular by reference to an identifier.
The information we require from you include the following:
- 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 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, probation details.
- Financial details including current employment, benefits, bank account details, debts, income, pensions, expenditure.
- Children's personal data, which includes 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 include the following:
- Recruitment information including references, correspondences, right to work checks and related documents, qualifications, training
- Emergency contacts
- Employment details including start date, contractual terms, job title, 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, family leave (maternity and paternity)
- Disciplinary, conduct and grievance matters
- Special categories of personal data for equal opportunities and diversity including health, religious beliefs, sexual life or sexual orientation, trade union membership, 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 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 when you make an application for a tenancy through the council and application through an agency. Further information about you may be collected from publicly available sources including social media and references from previous and current employers.
In some instances, you may provide personal details about someone else which includes 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 the personal data 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 one of the following:
- For the performance of a contract
- In our legitimate interest
- As a legal obligation
We collect and process personal data in order to provide you with housing and tenancy services and for the performance of and maintenance of your tenancy agreement. Personal data is also collected for the administration of your employment contract and contract for services.
Personal data is also 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, assessment of working capacity.
- In order to manage your tenancy agreement and in our legitimate interest by ensuring maintenance and repair work are carried out, ensuring your details are updated with various utility companies, 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 to assess the needs of the tenants and to ensure 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 and health and safety and safeguarding
- 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 various 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 the following:
- 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 - details of new tenants. 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 the following:
- For the management of payroll services, Access UK and MHR International UK Limited.
- In order to administer pension and benefits, Wiltshire Pension Fund, Scottish Widows.
- To facilitate the recruitment function and ensuring safer recruitment processes for working with vulnerable adults, Networx recruitment.
- In order to assist with business and company operations, ADP.
- Personal data may be shared with counselling services agencies, 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, 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 ensure the safety of staff and members of the public 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.
Data retention periods vary 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 applicable legal, accounting, reporting, finance and regulatory requirements.
For more details on our data retention schedule, please contact us at firstname.lastname@example.org.
Under the General Data Protection Regulation and UK Data Protection Legislations, you have a number of legal rights as it relates 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, 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 copies of any one of the following: passport, driving licence. If we do hold information about you, we provide you with a description of the data and provide you with a copy of the requested personal data in a legible form or a commonly used electronic form.
- 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 if you no longer wish to use our services or remain an employee / 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 the processing.
- Your right to request us to restrict processing if the accuracy of the personal data is of concern or if you believe the processing is unlawful.
- Your right to data portability and 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 contact us in writing to:
Group Head of ICT, Bryer Ash Business Park, Bradford Road, Trowbridge, Wiltshire, BA14 8RT. Email email@example.com
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. Telephone 03031 231 113 or 01625 545 745.