How we handle personal data
Port of Leith Housing Association GDPR privacy notice
This notice explains what personal information we (Port of Leith Housing Association, Scottish Charity Number SC027945), collect, when we collect it and how we use it. We collect and use personal data for a variety of reasons in line with the guidelines published in the Data Protection Act of 1998 and the General Data Protection Regulation (GDPR) (EU) 2016/679.
We are registered as a Data Controller with the Office of the Information Commissioner under registration number Z5626639 and we are the data controller of any personal data that is provided to us. All personal data we hold is stored securely within the UK and EEA (European Economic Area).
Any personal data we process is done so for a clear purpose and with a clear legal basis for doing so. We only hold personal data for as long as is necessary, as is required by law or as is set out in any contract we enter. The length of time we hold certain types of personal data for is set out in our Data Protection Policy.
How we collect information from customer and what we collect
We collect information about customers:
- When they apply for housing with us, become a tenant, request services/repairs, enter into a factoring agreement with us or otherwise provide us with their personal details
- When they apply to become a member
- When they use our online services, for example to report any tenancy/factor-related issues or make a complaint etc
- When they make payments to us (such as bank details, payment card numbers, employment details, benefit entitlement and any other income and expenditure related information).
We collect the following information about customers:
- Telephone number
- Email address
- National Insurance number
- Next of kin
- Details of any dependents.
- Date of birth
We receive the following information from third parties:
- Benefits information, including awards of Housing Benefit/ Universal Credit
- Payments made by you to us
- Complaints or other communications regarding behaviour or other alleged breaches of the terms of your contract with us, including information obtained from Police Scotland
- Reports on the conduct or condition of your tenancy, including references from previous tenancies, and complaints of anti-social behaviour
- Medical information for the purposes of managing your tenancy.
- Why we need this information and how it’s used
- We require this information for the following reasons:
- To undertake and perform our obligations and duties to customers in accordance with the terms of our contract with them
- To enable us to supply customers with the services and information which they request
- To enable us to respond to repair requests, housing applications and complaints
- To analyse the information we collect so that we can administer, support and improve and develop our business and the services we offer
- To send customers details of any changes to our suppliers which may affect them
- For all other purposes associated with the proper performance of our operations and business
- To contact customers to find out their views on our products and services.
The information provided to us will be treated confidentially and will be processed only by our employees within the UK/EEA (European Economic Area). When we use a third-party (a data processor) to process personal data, we enter into a written data sharing agreement with the processor to ensure that they fulfil the obligations of the data protection law.
We may disclose information to other third parties who act for us for the purposes set out in this notice or for purposes approved by the customer, including the following:
- If we enter into a joint venture with or merge with another business entity, information may be disclosed to our new business partners or owners
- If we instruct repairs or maintenance works, information will be disclosed to any contractor
- If we are investigating a complaint, information may be disclosed to Police Scotland, local authority departments, Scottish Fire & Rescue Service and others involved in any complaint, whether investigating the complaint or otherwise
- If we are updating tenancy details, information may be disclosed to third parties (such as utility companies and the local authority)
- If we are investigating payments made or otherwise, information may be disclosed to payment processors, the local authority and the Department of Work & Pensions
- If we are conducting a survey of our products and/ or service, information may be disclosed to third parties assisting in the compilation and analysis of the survey results
- Health and Safety Executive and Scottish Public Services Ombudsman.
Unless required to do so by law, we will not otherwise share, sell or distribute any of the information provided to us without your consent.
Security of personal information
We take steps to make sure that personal information we hold is kept secure and safe.
How long we keep personal information
We review our data retention periods regularly and will only hold personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with the individual.
We will generally keep information for the minimum periods set out in our Data Protection Policy.
Understanding individuals’ rights
Any individual whose personal data we collect and process has the right at any time to:
- Ask for a copy of the information we hold about them
- Require us to correct any inaccuracies in their information
- Request that we delete the personal data we hold about them
- Withdraw consent (if processing is based on consent)
- To complain to the Information Commissioner’s Office about our use of their information. The Information Commissioner’s contact details are noted below:
- The Information Commissioner’s Office – Scotland
45 Melville Street, Edinburgh, EH3 7HL
Telephone: 0131 244 9001
Keeping in touch with us
The accuracy of the personal data we hold is important to us. Please help us keep our records updated by telling us about any changes to your personal and/or contact details by calling our Customer Advice Team on 0131 554 0403 or emailing firstname.lastname@example.org.
Any questions about this notice should be sent to Heather Kiteley, Director of Finance & Corporate Services, at email@example.com or at our registered office: 108 Constitution Street, Leith, Edinburgh, EH6 6AZ.