Alamo Housing Co-operative Ltd – PRIVACY NOTICE
YOUR PERSONAL DATA – What is it?
‘Personal data’ is described as information that is held about an individual which can lead them to being identified from the data. This can be through names, email addresses, property addressed photographs, videos etc.
The processing of personal data is governed by legislation, previously the Data Protection Act 1998 which has been replaced by the General Data Protection Regulation (GDPR). Personal data is also covered under the Human Rights Act.
The introduction of the GDPR legislation means that Alamo Housing Co-operative as your landlord is required to provide each member with a ‘Privacy Notice’. The reason for this is because the Co-operative is deemed as the ‘Data Controller’, for further information on what a data controller is, please refer to the Data Protection Policy which accompanies this notice.
In order to fulfill our functions as a landlord we have a requirement to work with other ‘data controllers’ and ‘data processors’ to deliver services to you. Other controllers / processors we will work with are:
• Local Authorities
• Managing Agent
• Legal Services
• Housing Regulator
• Financial Conduct Authority
There will be times when we will need to share your personal data with them so that they can carry out their responsibilities to the Co-operative or in instances where we are governed by legislation to provide information to ‘other bodies’. For example, the Housing Regulator.
A description of what personal data Alamo Housing Co-operative processes and for what purpose is set out in this Privacy Notice.
What personal data will the Co-operative process to deliver its functions as a landlord?
• Names, titles, Aliases
• Contact details (telephone numbers, address, email addresses)
• Where relevant to services provided, we may process information such as age, gender, marital status, nationality, family composition and dependents
• Some data that we will process may include sensitive or other special categories of personal data such as racial or ethnic origin and mental / physical health
We may at times process sensitive personal data including, as appropriate:
• Your racial or ethnic origin or religious or similar information in order to monitor compliance with equal opportunities legislation
• In order to comply with legal requirements and obligations to third parties
The GDPR describes the above types of sensitive data as ‘Special Categories of data’ and they require higher levels of protection. This means that [Insert] Housing Co-operative will need to justify collecting, storing and using this type of personal data.
We may process special categories of data only in the following circumstances:
• With your explicit consent
• Where we need to carry out our legal obligations
• Where it is requested for legal claims and you are not in a position to give consent
Do we need your consent to process sensitive personal data?
We may approach you for your written consent to process certain personal data. If we do, we will provide you with the full details of the personal data we need and the reason we need it. You will then be able to consider if you are happy to consent.
Compliance with Data Protection Law
[Insert] Housing Co-operative will comply fully with legislation that determines Data Protection which states that the personal data we hold about you must be:
• Used lawfully, fairly and transparently
• Collected only for valid purposes that we have explained to you
• Relevant to the purposes we have told you 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 and destroyed securely to protect your personal data from loss, misuse, unauthorised access and disclosure
What will we use your personal data for?
• To confirm your identity to provide necessary services / functions to you as your landlord
• To contact you by post, email, telephone and text
• To help us to build a picture of how we are performing
• To enable us to meet all legal and statutory obligations and functions
• To maintain our own accounts and records
• Co-operative Administration
• To seek your views, opinions or comments
Sharing your personal data
We will share your personal data with certain third parties (refer to section on The Co-operative) and these third parties have an obligation to put in place security measures to protect your data. Alamo Housing Co-operative will monitor this closely where appropriate.
How long will we keep your data?
We will keep some records permanently if we are legally required to do so in connection with our statutory obligations as a landlord.
In general we will only retain your personal data as long as you remain a tenant of the Co-operative. In some cases we will keep your data after your tenancy is ended, but, this is only in cases where a debt is left on your rent account.
Your rights and your personal data
You have the following rights with respect to your personal data:
Your right to access your personal data that we hold
You can contact us to request the personal data that we hold on you as well as to ask us why we have the personal data and who has access to it. Once we receive your request we will respond within one month.
You will not be charged for the first request but, for additional requests for the same personal data or where it is found that the requests are excessive or unfounded you may be charged.
Your right to correct the personal data we hold
If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
Your right to have the data erased
If you think that we should no longer be using your personal data or that we are unlawfully using your data, you can request that we erase the data that we hold on you.
When we receive your request, we will confirm whether the data has been deleted or the reason why it cannot be deleted.
Your right to object to processing your data or restrict it to certain purposes
You have the right to request that we stop processing your data or ask us to restrict processing it. When we receive your request, we will contact you and let you know if we can comply or if we have a legal obligation or obligation as your landlord to continue to process your data.
Your right to data portability
You have the right to request that we transfer some of your data to another data controller. We will comply with your request within one month of receiving it.
Your right to withdraw your consent
You have the right to withdraw your consent easily by visiting this website: https://gdpr-info.com/data-protection-contact-form
Your right to make a complaint
You have the right to make a complaint and you can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
If we are considering using your data for another purpose other than what is detailed in this Privacy Notice, we will provide you with a new notice explaining the new use prior to commencing the processing. We will explain the purpose and will seek your consent prior to the new processing.
Changes to this privacy notice
We will keep the privacy notice under review and will inform you of any updates carried out.
Please contact us if you have any questions about this Privacy Notice of the personal data we hold about you or to exercise all relevant rights, queries or complaints at: The Data Controller, [Insert Office / Registered Address]