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Last updated 26/08/2015

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Data Protection and Access to Personal Information

  • Overview

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    The Adactus Housing Group and its subsidiaries (AHA, BHA and CCH), are responsible for collecting, processing, storing and safe-keeping personal and other information as part of our business activities. We manage personal information in accordance with the Data Protection Act 1998, and are registered as Data Controllers with the Information Commissioner’s Office.

    We take your privacy and the security of your information very seriously. This article explains how we meet our obligations under the Data Protection Act to protect the personal information we may hold about you, and it also outlines your rights to inspect these details.

  • Data Protection principles

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    The Data Protection Act lists eight data protection principles, which the Group is obliged to follow:

    • Personal data shall be processed fairly and lawfully.
    • Personal data shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes.
    • Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.
    • Personal data shall be accurate and, where necessary, kept up to date.
    • Personal data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
    • Personal data shall be processed in accordance with the rights of data subjects under this Act.
    • Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
    • Personal data shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
  • What personal information we collect

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    We may collect, process and store information such as:

      • Tenant names, date of birth, National Insurance numbers, photographs, contact details and preferences
      • Tenant demographic data (e.g. religion or belief, ethnicity)
      • References from landlords, support providers or other people vouching for applicants’ suitability as a tenant
      • The details of other family members or people living in our properties
    • Rent payments made
      • Income and expenditure estimates
    • Repairs requested
      • Application or referral forms
    • Tenancy agreements
      • Physical and mental health or condition
      • Support contracts
      • Support plans and details of support providers
    • Complaints about our services
      • Responses to surveys or involvement initiatives
      • Allegations of anti-social behaviour
      • Convictions, proceedings and criminal acts
      • Correspondence to and from our residents, service users, other agencies or advocates
      • Recordings of telephone calls made to and from the organisation
      • CCTV images (If you live in a supported accommodation project with the provision of CCTV; the CCTV systems record and retain information for up to a month to safeguard your health and security).


    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.  
    It is important that you notify us of any changes to your personal information. 

  • How we use your Personal Information

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    Tenants and residents

    We use your personal information for responding to your enquiries, providing services to you and managing our relationship with you. We will also use the information to:

    • notify you of changes we are considering or planning to make
    • help us improve our services
    • inform you about our services.

    We may also anonymise your information, so that it cannot be linked to you, as part of research exercises.

    We will always tell you how we will use your information when collecting it from you - for example in an interview, survey form or on our website (see Website Privacy Policy).

    Job applicants

    If you submit a job application we will use your personal information to process your application and to produce and monitor recruitment statistics. We will not take up references without your prior permission. We will not share or disclose your information unless you have given us your consent or we are required to by law. Where we are required to carry out a Disclosure and Barring Service check we will comply with the law and your rights when carrying out these checks.

  • Sharing your Personal Information

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    Access to your information will normally be limited to ourselves. However, there may be occasions when we disclose your details to others.

    With your consent

    We will usually obtain your consent before referring you to another service, an activity that requires us to share your contact and background information with the organisation that provides the service.

    Legally obliged

    We will share specific and relevant information with law enforcement and government agencies or public bodies where we are legally required to do so. Examples may include:

    • The prevention or detection of crime and fraud
    • The apprehension or prosecution of offenders
    • The assessment or collection of tax or duty owed to customs and excise
    • Sharing in connection with legal proceedings
    • Sharing in relation to the physical or mental health of an individual, where disclosure is required to protect them or others from serious harm
    • Research and statistical purposes.

    We may also share your information with emergency services and local authorities, where this is necessary to help them respond to an emergency situation that affects you.

    Contractors and suppliers

    We may share your personal information with our suppliers who enable us to provide services to you, or who provide services on our behalf. Examples of those suppliers are: specialist maintenance contractors who carry out work in tenants’ homes; the contractor who handles your out of hours service calls for us; companies that assist us in mailing out our notices and letters. The data shared is the specific information the supplier requires to carry out their task, as well as any information that ensures we fulfil our health and safety obligations to the people carrying out the task. 

    The Group remains responsible for the fair and lawful processing of personal data shared with suppliers. We ensure this occurs through setting data protection requirements in contracts let with suppliers.

    Utility companies

    In order to assist utility providers (gas, electricity and water, etc) deliver their services and collect revenue, we will provide on request names and contact details of new tenants, and forwarding addresses of former tenants, as well as tenancy dates. 

    Partner agencies

    We may enter into partnerships with other organisations such as local authorities and the police. For example, we may join a partnership to help prevent and control anti-social behavior.  We will enter into a formal data sharing agreement to govern the process and ensure it is lawful. That agreement will be approved by our Data Protection Officer before it is implemented.

     

  • Supported Tenants

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    Tenants' personal matters will be discussed within the supported staff team, however these discussions will be in confidential settings.  If a young adult asks a staff member to arrange support from an external service, they must consent to the disclosure of any personal information beforehand.

    Disclosure of personal information without consent will be exceptional and only if required by law, a court order, or where overriding health and safety considerations apply.

     

  • Protecting Personal Information

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    We aim to ensure that staff and board members do not misuse any confidential information, or pass on this information improperly to a third party. We protect personal information by applying technical measures, implementing policies, training staff and carrying out checks on practice.

    Secure storage

    • Paper files and records containing personal information are kept in secure cabinets. These cabinets are locked when they are not in use. Staff are provided with guidance on secure handling of records when taken from the office – for example, when carrying out a home visit.
    • We ensure any information on our computer system is secure, accurate, relevant and necessary. All our computers are secured with passwords, and staff are all fully trained on our systems. The personal data held on mobile IT devices is minimised, encrypted wherever possible and technical measures taken to secure data should a device be lost or stolen.


    Telephone enquiries

    When a tenant or housing applicant contacts us by phone, they will be asked to provide a piece of identifying data (e.g. date of birth) to ensure that personal information is only disclosed to the correct person.  If a tenant would like someone else to contact us on their behalf they need to confirm that to us directly, or if it is an ongoing arrangement, complete a tenancy contact authorisation form.

    On-line services

    An increasing number of customers want to access information online, information such as:

    • Rent and payment details
      • Personal information
    • Repair details


    We take security very seriously, and to access our online system users require the following details before they can log in:

    • A username (user ID)
    • A password
    • An identity number (tenancy number)


    Users can only view their own data and cannot make changes to the data accessed.

    All information is encrypted, ensuring that data is safe, secure, and available only to the registered user. The personal information viewed will not be stored on the computer used to access the site.

    All data is held in a secure server environment, which uses the following technologies to prevent interference or unauthorised access: firewalls with packet-inspection, virus guard and other advanced technology. The technology in use is reviewed and updated regularly.


    Complaints

    If someone contacts us to raise a complaint on your behalf we will always seek your permission first. This is because in responding to the complaint, the person claiming to represent you might view some of your personal data.


    Rent enquiries

    If you want to make an enquiry about your rent, e.g. your payment history or the balance of your account, we will ask you to quote to us your 'Tenancy Number'.  Every tenant has a own unique Tenancy Number; you can find your Tenancy Number on your regular rent statements.  If you do not know your Tenancy Number we will ask for your full name and date of birth before giving you any details about your rent account.


    Moving house

    When you move out of your home, after 12 months we will destroy the paper files relating to your tenancy (unless we are pursuing money owed or we need the information to support any dispute about disrepair or anti-social behaviour).

  • Accessing your Personal Information

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    The Data Protection Act 1998 gives you a number of rights in relation to your personal information. You can find out about your rights, and get further guidance, on the Information Commissioner Office’s website.

    You have the right to access files or other records containing information relating to:

    • Your present tenancy
    • Your past tenancies
    • Proposed tenancies
    • Support plans


    Please note the following important information about accessing your personal information:

    • You can make your request to any member of staff. All requests are passed by staff to our Data Protection Officer to ensure we act in accordance with the Data Protection Act. 
    • To help us respond, please be as specific as you can be about the information you would like to see.
    • We may make a nominal charge if you ask us to photocopy any documents (we will let you know beforehand if we need to make this charge).
    • Under the legislation, we have up to 40 days from the date you request the information to provide it to you.
    • You have the right to ask us to delete or change any inaccurate information held on our files. We consider all requests and will change or delete information that we agree is inaccurate.


    Because we also need to respect the rights of others, we cannot make the following information available to you:

    • Information relating to, or identifying a third party, unless that person has given their written permission.
    • Information from other agencies such as Social Services, doctors or lawyers which could reasonably be expected to be treated as confidential.
    • Information that could cause physical or mental harm.


    The decision to refuse an individual access to personal information about themselves is taken at ‘Manager’ level within the Association, in liaison with our Data Protection Officer.

    If you are receiving support, the following apply:

    • You can have immediate access to all parts of the file that contains your support plans, reviews etc.
    • If you wish to view the full contents of your file, you must put this request in writing (We will allow you authorised access within 24 hours of the receipt of this request where feasible).


    We will identify ourselves and provide a contact number for you to confirm our identity on request when contacting you about our services.

  • Data Protection Registration Details

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    Adactus Housing Group Ltd.

    Data Protection Registration Number: Z832622X

    Date Registered: 27 November 2003

    Adactus Housing Association Ltd.
    
Data Protection Registration Number: Z1657414
    
Date Registered: 17 March 2009

    Beech Housing Association Ltd.

    Data Protection Registration Number: Z9332739

    Date Registered: 17 March 2009

    Chorley Community Housing.

    Data Protection Registration Number: Z9847037

    Date Registered: 10 April 2007

    Acuna Ltd.

    Data Protection Registration Number: Z4806450
    
Date Registered: 25 August 2000

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  • 26/08/2015

    Updated by Athanasios Protopapas on 26/08/2015 11:42:59

    Comment: Updated chapter on Sharing your personal information with utility companies.

    Details: (show)

    Chapter titled "What personal information we collect" content changed.
    Chapter titled "How we use your Personal Information" content changed.
    Chapter titled "Sharing your Personal Information" content changed.

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  • 11/12/2014

    Updated by Athanasios Protopapas on 11/12/2014 08:51:27

    Comment: Update following attendance at CIH training event on data security and protection.

    Details: (show)

    Chapter titled "Overview" content changed.
    Chapter titled "Data Protection principles" content changed.
    Chapter title changed from "How we use your personal information" to "What personal information we collect".
    Chapter titled "What personal information we collect" content changed.
    Chapter title changed from "Privacy and Confidentiality" to "How we use your Personal Information".
    Chapter titled "How we use your Personal Information" content changed.
    Chapter title changed from "Supported Tenants" to "Sharing your Personal Information".
    Chapter titled "Sharing your Personal Information" content changed.
    Chapter title changed from "Protecting Personal Information" to "Supported Tenants".
    Chapter titled "Supported Tenants" content changed.
    Chapter title changed from "Access to Personal Information" to "Protecting Personal Information".
    Chapter titled "Protecting Personal Information" content changed.
    Chapter title changed from "Data Protection Registration Details" to "Accessing your Personal Information".
    Chapter titled "Accessing your Personal Information" content changed.
    New Chapter added; title:"Data Protection Registration Details" image:"" order:"9".

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  • 24/09/2014

    Updated by Suzy Robinson on 24/09/2014 17:08:06

    Comment: tag added

    Details: (show)

    New Tag assigned "Staff".

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  • 01/09/2014

    Updated by Chris Smith on 01/09/2014 17:29:55

    Comment: Updated prior to 2014 staff training - added DP principles and more detail on the subject access request process

    Details: (show)

    Chapter titled "How we use your personal information" order changed from "2" to "3".
    Chapter titled "Privacy and Confidentiality" order changed from "3" to "4".
    Chapter titled "Privacy and Confidentiality" content changed.
    Chapter titled "Supported Tenants" order changed from "4" to "5".
    Chapter titled "Protecting Personal Information" order changed from "5" to "6".
    Chapter titled "Access to Personal Information" order changed from "6" to "7".
    Chapter titled "Access to Personal Information" content changed.
    Chapter titled "Data Protection Registration Details" order changed from "7" to "8".
    New Chapter added; title:"Data Protection principles" image:"" order:"2".

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  • 07/05/2014

    Updated by Athanasios Protopapas on 07/05/2014 13:50:55

    Comment: Improved information on protecting personal information over the phone.

    Details: (show)

    Chapter titled "Protecting Personal Information" content changed.

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  • 14/12/2012

    Updated by Admin on 14/12/2012 08:26:49

    Comment: Minor improvements to the text.

    Details: (show)

    Chapter title changed from "Information" to "Overview".
    Chapter titled "Overview" content changed.
    Chapter titled "Privacy and Confidentiality" content changed.
    Chapter titled "Supported Tenants" content changed.
    New Tag assigned "personal data".
    New Tag assigned "Personal data".

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  • 13/12/2012

    Updated by Chris Smith on 13/12/2012 16:44:21

    Comment: Update following policy review, in particular occasions when details shared with other parties; commitment to explain what data is used for when collected.

    Details: (show)

    Chapter titled "Information" content changed.
    Chapter titled "Privacy and Confidentiality" order changed from "2" to "3".
    Chapter titled "Privacy and Confidentiality" content changed.
    Chapter titled "Supported Tenants" order changed from "3" to "4".
    Chapter titled "Protecting Personal Information" order changed from "4" to "5".
    Chapter titled "Access to Personal Information" order changed from "5" to "6".
    Chapter titled "Access to Personal Information" content changed.
    Chapter titled "Data Protection Registration Details" order changed from "6" to "7".
    New Chapter added; title:"How we use your personal information" image:"" order:"2".

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  • 20/09/2012

    Updated by Athanasios Protopapas on 20/09/2012 08:35:37

    Comment: Edited format of last chapter

    Details: (show)

    Chapter titled "Data Protection Registration Details" content changed.

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  • 19/09/2012

    Updated by Athanasios Protopapas on 19/09/2012 11:25:49

    Comment: Amended formatting of last paragraph.

    Details: (show)

    Chapter titled "Protecting Personal Information" content changed.
    Chapter titled "Data Protection Registration Details" content changed.

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  • 19/09/2012

    Updated by Athanasios Protopapas on 19/09/2012 11:16:40

    Comment: Added Data Protection Registration details

    Details: (show)

    Chapter titled "Information" content changed.
    Chapter titled "Protecting Personal Information" content changed.
    New Chapter added; title:"Data Protection Registration Details" image:"" order:"6".

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