PLUS DANE PRIVACY NOTICE – FOR CUSTOMERS
This Privacy Notice is a public document available to anyone and applies to customers of Plus Dane Housing to explain how the organisation collects and processes personally identifiable information (PII) in order to conduct normal business activities as a Registered Social Landlord (RSL) regulated by the Regulator of Social Housing (RSH).
WHO ARE WE
Plus Dane Housing owns and manages more than 13,500 homes across Merseyside and Cheshire and employs over 500 people working together to deliver support and services to our customers.
Plus Dane Housing is a Data Controller which means that as an organisation we determine the purpose for which, and the way in which the information we collect about you is processed, stored and deleted.
As we act as the Help to Buy agent for the North West, we act as a Data Processor on behalf of Homes England, which means we process the data we collect on their behalf in accordance with a contract with them.
Our head office is based at 13-15 Rodney Street, Liverpool, L1 9EF.
The company Data Protection Officer (DPO) can be contacted at DPO@plusdane.co.uk
INFORMATION WE MAY COLLECT ABOUT YOU
We may collect the following personal information about you:
When you first make an application to us for housing:
In order to enter into a tenancy agreement or other type on contract with a customer, we need to collect certain types of personal data. This data ensures we can provide appropriate services and meet the requirements of the Regulator for Social Housing.
Personal data we collect includes:
- Full name (and proof of your identity / photo ID).
- Date of birth (DOB).
- National Insurance number.
- Contact details (phone, e-mail or correspondence address).
- Details of anyone authorised to act on your behalf if applicable.
- Basic details (name and DOB) of all household residents.
- Banking details if you pay your rent by Direct Debit.
- Card details if you pay by card (however card details are not stored).
- Proof of housing eligibility, any interest or equity in other property.
- Other personal information that will vary on a case by case basis to help us resolve breach of tenancy, alleged anti-social behaviour or fraud.
It may also be necessary to collect additional information to ensure we can meet the specific needs of our customers.
Additional information may be requested including:
- Disabilities or vulnerabilities.
- Financial information to provide assistance and advice on financial matters.
- Health information when we require this to support funding for adaptations made to the property you are living in.
- Photo ID, bank statements, payslips or income details for processing a house sale or purchase.
In respect of our Help to Buy contract we are requested by Homes England to collect Special Data including information about applicants’ ethnicity. Providing this data is optional and your consent is sought for processing of this data when you sign the application form.
Information required for managing your tenancy and contacting you about your housing needs:
- Your support needs, so we know how we can assist you before and during your tenancy
- Details relating to the repair and maintenance of your home
- Information that you provide to your relevant local housing, maintenance or other dedicated team
- Feedback from our contractors, about their appointments with you
- Voice and image recordings for safety, crime prevention and quality management
- We may also record factual information whenever you contact us or use our services, so we have a record of what
To help you buy part or the whole of your home
- Affordability checks
- Credit ratings
To provide security
- We operate CCTV systems, which collect images and can be used for evidence/intelligence for court proceedings, police information or tenancy enforcement.
- Calls made to our Freephone Customer Access Team are recorded for training and quality purposes.
To enhance your experience with us
- You can give us details of your friends, relatives or neighbours who you trust, and have provided us with their consent to process their data, to contact us on your behalf.
- Your name and contact details for customer satisfaction surveys, newsletters and service information
- With your consent, your name, photo, video or story could be used for brochures, advertising or press releases
- Details about complaints about our service or other individuals, accidents or incidents involving you or your home
- Your comments about our service or our suppliers’ services
- We record some calls for training and quality purposes
When you ask for additional services
- Name and contact details for someone to contact you (the person may be a member of our staff or from another organisation. Where it is a third party we will advise you before we process your information
- If you ask us for Care and Support requirements we will hold detailed information about your needs and your family’s needs
- Records of payments for the services provided to you
- If you contact us about financial problems we will hold detailed information about your income and financial situation
- If we offer you training or other learning opportunities we will ask about your employment and learning history
- We may hold information about your history, for example, regarding credit status or offences, to enables us to determine how best to deliver services to you
PROCESSING YOUR INFORMATION
Plus Dane will only process personal data where we have a lawful basis for doing so. There are six lawful basis against which we process information.
- Contract Fulfilment –The processing is necessary for the performance our obligations detailed in our contract with you. We use this basis for all processing concerning the managing of your tenancy, your account with us and your property.
This extends to us ensuring tenancy conditions are complied with, as signed up to in your tenancy agreements. We use this basis for all processing involved in dealing with anti-social behaviour, detecting and prosecuting fraud or otherwise ensuring that tenancy conditions are complied with.
- Consent – We may ask your consent to use your data for example to supply you with information about any offers and services that you may be interested in. You do have the right to deny consent at the point of request or later if you change your mind.
- Legal Obligations – The processing is necessary in order for us to comply with our legal obligations. We use this basis for all our processing involved in complying with regulations or laws that apply to us.
- Vital Interests – The processing of your data is necessary in order to protect your interests. This would be in order prevent a life-threatening incident and could include us providing medical and other information to emergency services, if necessary.
- Public Interest – We may need to fulfil a duty given to us by an official authority. This would include our obligation to the government or a local authority where we may be obligated to process your data for specific purposes.
- Legitimate Interests – We may need to process your data for specific purposes not covered in the other types of lawful basis. We would provide justification for doing so whilst ensuring that we balance your rights and freedoms with the needs of our business.
We also process information on behalf of organisations. In this case we will only process the data that is provided to us in the way in which the third party instructs us’
Plus Dane strives to ensure that we listen to our customers with regards to the development or improvement of products and services. We therefore may seek customer views on a regular basis through the use of surveys, focus groups or meetings. Where we believe it’s necessary to do so we will seek your consent on these matters.
Plus Dane used a number of IT systems to store personal data. This enables us to ensure the smooth running of the organisation and to provide the appropriate level of service to customers.
Should you have any questions or concerns about our justification for using your personal data, please contact the Data Protection Officer at DPO@plusdane.co.uk.
WHO HAS ACCESS TO YOUR PERSONAL DATA?
There are some instances where your personal data will be shared with third parties and partners who are providing a service to you.
Plus Dane employees - personal data is restricted on a need to know basis (i.e., staff are only given access to data that they need in order to do their job).
Third parties – we do share personal data with some third parties but these will always be subject to General Data Protection Regulation (GDPR) compliant sharing agreements (e.g., we will share customer files with the company that print and distribute your rent statement, and once the task is completed, the data will be deleted by the third party).
Where we ask third parties to process your data on our behalf we will be clear about how they should use your data and they will not be permitted to use it for any other purpose. Any third parties processing your data are obligated to adhere to the GDPR and can be routinely audited by the Plus Dane Data Protection Officer to ensure that your data is being safeguarded properly.
Contractors carrying our work for Plus Dane e.g. we have a number of contractors who support us with the repair, maintenance and compliance of our properties.
Government departments and agencies Department for Work and Pensions (DWP), Regulator of Social Housing and Homes England
Who else we may pass your information to
There may be times when we disclose your details to others, as follows:
- Advocacy partners, contractors and suppliers who provide services to you, or who provide services on our behalf. We will ensure that we have appropriate information sharing protocols in place
- Housing maintenance and repairs contractors to undertake repairs or improvements to your home
- Our out-of-hours service call handling provider Orbis
- Banks to carry out payments through a secure system
- Companies that help us mail out leaflets/newsletters
- Local authorities, other housing and support organisations and statutory agencies
- Mediation partner organisations
- Advocacy partner organisations
- Our solicitors
- Our insurers, in case of public liability claims and similar
- Credit reference agencies for rental tenants
- Debt collection agencies to collect current and former debt
- External assistance where you have agreed to the referral, for example, to investigate money problems
- Training providers or learning institutions
- Utility companies
- Debt collection agencies acting for others and on our behalf
- Tracing agencies in order to recover debt where no forwarding address is known
In some cases we may have a duty to disclose your information by law to:
- Local authorities, regulatory bodies and government departments
- Police, fire services or health authorities, or medical staff
We don’t give anyone access to your information in return for payment for their marketing or commercial purposes.
We won’t share your personal information with anyone who claims to represent you unless we’re satisfied that you have appointed them or they act in some recognised official capacity.
As part of our Help to Buy contract with Homes England, we are asked to collate application data, which we process and maintain on their behalf. When you complete an application for any of the schemes covered by this contract, we will make you aware of who will receive your data as part of this this agreement and ask you to declare your consent as part of the application.
Personal data is kept by Plus Dane Housing in accordance with its Personal Data Retention Schedule. Data is retained in accordance with legislative, regulatory of statutory guidelines. It is kept for no longer than is necessary for the purposes for which the personal data are processed.
Details of retention periods should be made available to you at the time of us requesting the data.
YOUR RIGHTS REGARDING YOUR PERSONAL DATA
You have a number of rights when it comes to the holding and processing of your personal data. You can request:
- The right to access your data
You have the right to request access to the personal data that is held for you by Plus Dane Housing.
- The restriction of processing of your personal data
You have the right to request that Plus Dane reduces or stops altogether the processing of your personal data.
- The rectification of your data
You have the right to ensure that your data is accurate and complete. Should you identify any errors in the data we hold, you can contact us with the details and request that this is amended in our records.
While we assess your request we will stop processing your data until we determine whether a correction needs to be made.
In some instances, you have the right to have your personal data erased. This is also known as the ‘right to be forgotten’. This right is not absolute and only applies in certain circumstances. Examples include where the personal data we hold is no longer required for the purpose it was originally collected.
In certain circumstances you may be asked to give consent for us to lawfully process your personal data. Where consent has been given, you may withdraw it, at any time, unless we have some reason to deny your request (e.g. an account in arrears, legal proceedings, or due to significant business or public interests).
- Rights related to automated processing of your data
You have the right to have a human being involved in the processing of your data. Where we have systems that make automated decisions we will always be able to explain in person how the decision making processes works.
The right to data portability
You have the right to request to move, duplicate or transfer your personal data where you have provided that data directly to us.
To make a request to Plus Dane for details of the personal data we may hold or to exercise any of the rights detailed above please complete the relevant forms here and send to DPO@plusdane.co.uk for our Data Protection Officer (DPO) to process.
COMPLAINTS OR QUERIES
We try to meet the highest standards when collecting, processing and storing your personal information. If you feel that our collection, processing or storing of your information is inappropriate in any way, we would encourage you to contact us in order for us to address it. In the first instance you should contact DPO@plusdane.co.uk
Alternatively you can make a complaint via our website www.plusdane.co.uk or call us on 0800 169 2988.
The right to lodge a complaint with a supervisory authority.
If you wish to raise a concern, about the way we have handled your personal information, to a supervisory authority then you can raise this with the Information Commissioner’s Office (ICO) ico.org.uk.