Personal data is:
‘Any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;’
‘Special categories’ of personal data (sensitive personal data) relate to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation.
2. Why does TVH collect and store data?
TVH needs to collect, process and store personal information about you and other household members (when you provide information about household members we assume that you do so with their full knowledge and consent) in order to operate as a registered provider of housing and deliver efficient and effective services.
Legal basis for processing
We often have two main legal bases for processing personal data. Firstly, where it is necessary for the purposes of the legitimate interests pursued by TVH or by a third party to process your information. We can do that so long as we do not interfere with your fundamental rights or freedoms.
Secondly, because we have your consent (i.e. agreement) to us processing your personal information. Our residents are asked to sign a data protection consent form when they apply to us for housing or later if they did not sign one when they were granted their first tenancy. The consent form sets out the organisations and type of organisations we often have to share personal information about residents with. Under the GDPR, consent is a legal basis for processing personal information. You can withdraw your consent at any time. This is explained further below in the section entitled ‘Your rights under GDPR’.
The other reasons we can rely upon to process your personal information under GDPR is as follows:
- Where we are under a legal obligation or an obligation under a contract to process/disclose the information.
- Where we need to protect the vital interests (i.e. the health and safety) of you or another person.
- Some personal information is treated as more sensitive. The legal basis for processing these special categories of personal information is more limited. To lawfully process special categories of personal data, we must identify a lawful basis for the processing and meet a separate condition for the processing. The basis we can use these are:
- With your consent;
- Where we need to protect the vital interests (i.e. the health and safety) of you or another person;
- Where you have already made your personal information public;
- Where we or another person needs to bring or defend legal claims; and/or
- Substantial public interest grounds
To process personal data about criminal convictions or offences, we must have both a lawful basis for the processing and either legal authority or official authority for the processing.
3. What data does TVH collect?
- We may collect the following personal data (“User Data”) from you when you use our online services:
- information you provide by filling in forms on our Site. This includes information provided when reporting repairs or making enquiries via the Site.
information you provide when you report a problem with our Site;
- If you contact us, we may keep a record of that correspondence;
- Details of your visits to our Site and the resources that you access
- Your name and contact details for use across the organisation and by our suppliers and partners.
- Detailed personal information such as photo identification, age, sex, date of birth, ethnicity, income, National Insurance number, private expenditure data, employment status, contact details (telephone numbers and email addresses), relationship status, address history, any disabilities, religion, sexual orientation, nationality, caring responsibilities, details of your next of kin (address and contact details) access to financial services such as banks and credit unions, bank details, benefits, council tax, affordability information, eligibility for UK residency, details of those who you want us to communicate with on your behalf, how you prefer us to contact you, whether you have any literacy problems, your ability to speak English and language preferences, requirements for different communication formats, your preferences for getting involved and the service areas that are of most interest to you.
- Simple details on other occupants of your home such as their name, date of birth, sex, ethnicities, any health issues we may need to know about and their religion.
- Tenancy reference checks/references from other housing providers/private landlords.
- Your particular needs or preferences so that we can understand them better and offer care or support based on these needs.
- Details of Support Services you may use.
- References/information from your mortgage lender (if you own/have owned your own home), When you apply to us for housing, we request information so we can understand your housing needs and assess your application. This may include references from other landlords, your mortgage lender (if you own/have owned your own home), the police and probation services, support workers, social workers, mental health workers and credit reference agencies.
- Medical and health information so that we can prioritise and assess a housing application.
- Your support needs so we know how we can support and assist you before and during your tenancy.
- Details of any harassment or abuse in order to support or protect you.
- Details of any complaints made against you or any anti-social behaviour.
- Details relating to the repair and maintenance of your home.
- Information that you provide to your relevant housing officer, maintenance or other dedicated team, including all emails and other forms of communication.
- Feedback from our contractors about their appointments with you.
- Information about allegations of anti-social behaviour.
- Voice and image (CCTV) recordings for safety, crime prevention and quality management which is used in accordance with our CCTV policies and procedures.
- We may collect information about individuals where they pose a substantial threat to our staff or contractor, such as criminal records or alleged offences.
- We may take pictures at residents’ parties, meetings and other events, and these may be used in newsletters, annual reports, brochures or on the website or Facebook and they may appear in local newspapers. Whenever we take pictures we will always ask you for your written permission and give you the choice whether or not to be included in a photograph.
- We may also record calls to our customer service staff and some other departments. This is to help us identify how to provide you with a better service. These calls will be kept securely for 12 months then destroyed, unless they are part of a dispute – in which case we reserve the right to keep them for dispute resolution purposes.
- The information we may collect from you includes:
- Disabilities or vulnerabilities. We use this information to tailor our service to better meet your particular circumstances and needs. We may use this information for safeguarding of staff.
- Financial information. We may use this to help resolve arrears payments and optionally to provide welfare, benefits and debt advice as a free service to help you budget and pay your bills. We may use this to apply for funding on your behalf.
- Health information when we require this to support funding for adaptations made to the property you are living in. More specific details are provided if you use this service.
- Photo ID, bank statements, payslips or income details when we require this information for processing a house sale or purchase.
- TVH may also collect User Data that your provide to us when you visit any of our premises
4. Who the personal information relates to
We collect and hold personal information about:
Residents - This includes current, former and potential residents who live in our properties or access our support and other services, together with members of their families and people associated with them.
Visitors - Visitors to our offices
Anyone - who makes an enquiry to TVH.
Anyone - who makes a complaint to TVH.
We will minimise our holding and use of sensitive categories of personal information. This means that we will only collect and use it when it is necessary to provide special services, or to deal with special circumstances. Examples include when we receive applications from people with disabilities or with problems such as substance abuse, when there are anti-social behaviour issues involving actual or alleged criminal activity or when residents need access to care services.
5. What use does TVH make of User Data?
- TVH will use the User Data that it collects from you for the following purposes:
providing you with our services;
dealing with your enquiries and requests;
administering your account;
statistical monitoring for marketing purposes and/or to improve or tailor the services we provide; and
providing you with information and offers from us that we believe you may find useful or interesting, such as marketing or promotional materials, if you have opted-in to receive such information via our mailing list;
We also process personal information using CCTV systems and we monitor and collect visual images for:-
- Security reasons
- The prevention and detection of crime; and
- Staff safety and monitoring purposes.
6. Protecting and sharing information
TVH may make User Data available to other parts of its organisation, including to any member of our group of companies and successors in title to our business.
We may engage third party companies and individuals to facilitate our services, to provide the services on our behalf and to perform services related to administration of the services or the Site (including, without limitation, maintenance, hosting and database management services and administration). These third parties may have access to or be provided with your User Data only to perform these tasks on our behalf. These third parties that operate through websites may have their own privacy policies. We encourage you to read the privacy policies and other terms of such websites before using their services.
Your personal information will be kept secure and confidential as per our data protection policy. Our staff only have access to your personal information when and if they need to have it to provide the service to you. We may share information with contractors, or agencies we work with, such as local authorities, social services, police, other social landlords and others when we think it is in your interest or in the public’s interest to do so. We will also disclose information as required by law.
In particular, please be aware that:
- Current or forwarding addresses may be shared with utility companies and Council Tax offices to ensure billing details are correct.
- If you default on any tenancy or licence conditions, information about you may be provided to authorised debt recovery agencies, to enable them to recover the debt. This may affect future applications for tenancies, credit and insurance.
- We may discuss your financial situation, rent payments (including any arrears) and any claims made for welfare benefits with an external debt advice agency, welfare rights advisor, a council’s housing benefit department or housing advice and homeless prevention team to ensure that benefits are paid correctly.
- We may pass data about your rent payment record to credit reference agencies. This will enable them to assist other organisations to assess your financial standing if you apply for products and services.
- We may pass your information to support services if we feel it is in your interests to do so or if you ask us to do so.
- We may pass your contact information to a third party to conduct surveys and research on our behalf which allow us to gather feedback and improve the services we offer you. The third party will always be bound to strict terms and conditions outlined by us and will not share your data with other organisations. Should you choose not to participate in the surveys the third party will securely destroy your data.
- We may share your National Insurance number to verify your Universal Credit application and manage these payments.
- We may also share your National Insurance number in order to prevent - and investigate - tenancy and right to buy applications fraud.
7. Additional services
TVH conducts a number of additional voluntary services including organising community events, providing debt advice, adapting the property you live in, selling properties and gathering information to improve our services.
For these voluntary services, where your personal information is needed, we will always notify you about the service being offered, explain the service and obtain your consent to proceed, usually by way of a sign up / consent form for that service.
8. Children’s information
TVH does not normally process children’s information as part of a tenancy, as all tenants are adults. However, we record children’s basic information if they are resident in one of our properties, including their name and date of birth. This is required for checking the property is not overcrowded and to assess other tenancy management issues where all householders and ages are required to be known.
We may receive children’s information if we are involved in the housing and tenancy aspects of a welfare case as part of a multi-agency working solution.
9. How Long Do we hold your data for
In most cases we hold the majority of your tenancy data for up to  years after your tenancy ceases. However some data we may get rid of during your tenancy if we no longer have a purpose for keeping it. For full details on how long we keep your personal data you can contact us and ask to see our full retention policy.
10. National Fraud initiative
TVH may occasionally participate in the National Fraud Initiative (NFI) data matching exercise carried out by the Government. Our participation in NFI assists in the prevention and detection of fraud against TVH and other public sector organisations.
Data matching involves comparing computer records held by one organisation with records held by another to see how far they match. This is usually personal information. Data matching allows fraudulent claims and payments to be identified. Where a match is found it may indicate that there is an inconsistency which requires further investigation. No assumption can be made as to whether there is fraud, error or any other explanation until an investigation is carried out.
The use of data in this way is carried out with statutory authority and therefore does not require the consent of the individuals concerned under the Data Protection Act 2017.
11. Your rights under the GDPR
Right to be informed: We will provide you with a privacy notice to tell you how we are using your personal data.
Right of access: You have the right to obtain access to your own personal data at any time so you are aware of and can verify the lawfulness of processing. Information will be supplied within one month of receipt of the request. This can be extended by a further two months where requests are complex or numerous. This will be provided free of charge unless you ask for multiple copies or the request is manifestly unfounded or excessive. We can also refuse your request if it adversely affect the rights and freedoms of others or is manifestly unfounded or excessive. You can make a subject access request by contacting anyone at TVH, preferably someone on our corporate services team.
Right of rectification: You have the right to have your personal data rectified if it is inaccurate or incomplete. If we have disclosed this to third parties, we will tell you if this is appropriate and we will inform them of the rectification where possible.
We must respond within one month, extendable by two months where the request for rectification is complex.
Right of erasure: You have the right to request the deletion of personal data where there is no compelling reason for its continued processing or if we are processing it in an unlawful manner – for example if we are using it for a different purpose than originally stated.
Right to restrict data processing: Under certain circumstances, you have a right to ‘block’ or suppress processing of personal data. When processing is restricted, we are permitted to store the personal data, but not further process it. We can retain just enough information about you to ensure that the restriction is respected in future.
Right to data portability: You can obtain and reuse your personal data for your own purposes across different services. This right applies where the processing is based on your consent or for the performance of a contract; and when processing is carried out by automated means.
Right to object: You have the right to object to:
- Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
- Direct marketing (including profiling); and
- Processing for purposes of scientific/historical research and statistics.
If we process personal data for the performance of a legal task or our organisation’s legitimate interests, you must have an objection on “grounds relating to you particular situation”
We must stop processing the personal data unless:
- We can demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or
- The processing is for the establishment, exercise or defense of legal claims.
- The Personal Data is essential to the continuation of the tenancy or is in the ‘vital interests’ of the tenant.
You Maintain the Right to Withdraw Consent at any Time: You may contact TVH to request this. Although we may not be able to accept your request for certain types of data, please contact us if you wish to discuss this further.
You have the right to complain about any matter relating to our service, including how we use your personal data:
- In the first instance please contact our Customer Services team on 0300 456 2929 or e-mail Tim_Grannell@tvha.co.uk
- If you are still not happy with our service you may complain to the Housing Ombudsman Service at http://www.housing-ombudsman.org.uk/.
- If you wish to complain about our use of your personal data you may complain to the UK Information Commissioner’s Office (ICO) at https://ico.org.uk/.
12. Legal Requirements
While it is unlikely, TVH may be required to disclose your User Data by a court order or to comply with other legal requirements. TVH will use all reasonable endeavours to notify you before we do so, unless we are legally restricted from doing so.
13. No commercial disposal to third parties
TVH will not sell, rent, distribute or otherwise make User Data commercially available to any third party without your prior permission.
14. Storage of User Data
16. The internet
Given that the internet is a global environment, using the internet to collect and process User Data necessarily involves the transmission of data on an international basis. Therefore, by browsing our Site and communicating electronically with us, you acknowledge and agree to our processing of your User Data in this way.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your User Data, we cannot guarantee the security of your User Data transmitted to our Site; any transmission is at your own risk. Once we have received your User Data we will use procedures and security features to try to prevent unauthorised access.
17. Information about us
Thames Valley Housing Association Limited, registration number 17375R and Thames Valley Charitable Housing Association Limited, registration number 25301R are registered under the Industrial and Provident Societies Act 1965. Thames Valley Charitable Housing Association Limited is an exempt charity as defined within the Act and is a wholly owned subsidiary of Thames Valley Housing Association Limited. The Registered Office for the above companies is Premier House, 52 London Road, Twickenham, TW1 3RP.
Please contact us at the following email address with any questions and/or complaints about our service to you: firstname.lastname@example.org