BCHA respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights under the General Data Protection Regulations 2018 (GDPR) and the Data Protection Act 1998.
Purpose of this Privacy Notice
This privacy notice aims to give you information on how BCHA collects and processes your personal data.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Who we are
Bedford Citizens Housing Association Limited is the controller and is responsible for your personal data (collectively referred to as ”BCHA”, “we”, “us” or “our” in this privacy notice).
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO by using the details set out below.
Data Protection Officer
1 B Kimbolton Road Bedford MK40 2PU
Or use our email address email@example.com
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
If you do not have a contract* with BCHA, or are not part of an application process or have never had a contract with BCHA we may hold data about you as a contact on behalf of one of our residents, tenants or employees. If we hold your data as a third party we will obtain your consent to process your data.
*You may have a contract with BCHA if you have a power of attorney for a relative or have entered into a responsible person agreement if this is the case we have a lawful reason to process your data.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, which may include:
· Telephone numbers
· Present, previous and forwarding addresses
· Date of Birth
· Marital Status
· Rent payment details
· Bank details
· Housing benefit
· Employment details
· National Insurance number
· Health and care details
· Ethnicity, culture or religion
· Anti-social behaviour, violence and criminal activities
· Leave and absence records
· Training undertaken
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.
Where you are a third party contact we will obtain your consent to hold data about you and you may withdraw this consent at any time. This will mean that we will not be able to hold information which will enable us to contact you.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
· Where we need to perform the contract we are about to enter into or have entered into with you.
· To provide the services you need including care, repairs, maintenance, rents, transfers, and anything to do with your care contract or tenancy and property.
· To deal with your account(s) including payments, grants and benefits or run any other service we provide to you
· To manage applications made by you
· To provide a helpful and efficient response when customers ask for help and advice
· To deal with complaints
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal or regulatory obligation.
· When we need to process your data protect your “vital interests”. Information will only be passed on when we need to process personal data for medical purposes but you are incapable of giving consent to the processing
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to holding third party information to contact relatives or friends on your behalf. You have the right to withdraw consent to being a contact at any time by contacting us.
Change of purpose
We will only use your personal data for the purposes for which we have collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with third parties for the purposes set out above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Sometimes we may have to share information for legal reasons, for example to the Police, Benefits Agency and other landlords, or if it related to anti-social behaviour, crime or fraud.
If you would like to authorise someone to access your personal data and act on your behalf, please complete a consent form in full and return to BCHA. You can obtain the consent form from firstname.lastname@example.org. If you wish to withdraw this permission you must notify us in writing.
We will only transfer your personal data to a country outside the European Economic Area (”EEA”), provided that one of the following conditions applies:
· The country to which your personal data is transferred ensures an adequate level of protection for your rights and freedoms.
· We have your consent.
· The transfer is necessary under regulation, in the performance of our contract with you, or to protect your vital interests.
· The transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims.
· The transfer is authorised by the relevant data protection authority where we have adduced adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of your rights.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our Data and Document Retention Schedule which you can request from us by contacting us.
In some circumstances you can ask us to delete or remove your personal data where there is no good reason for us continuing to process it. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Automated decision making and Profiling
BCHA do not use automated decision making and profiling.
Under the GDPR you have rights regarding the personal data that BCHA process and hold about you. You have the right to:
· Find out what information BCHA hold on you
· Correct or complete inaccurate personal information BCHA holds about you
· Delete data about you that BCHA have (BCHA reserve the right to refuse this request if we hold data about you for a lawful reason such as having a contract with you. If we refuse to delete data we will tell you why)
· Move your data between landlords
· Challenge how BCHA process your information
· Be notified about changes to the way we use your personal data
If you would like to contact us you must write to us and tell us what you want to do and follow our procedure for requesting access to information. We will ask you to provide proof of identity before disclosing any information. It is free to use these rights, but BCHA reserve the right to charge a reasonable fee if we feel there are excessive requests.
Data Protection Officer
1 B Kimbolton Road
Or use our email address email@example.com
We will respond to all legitimate requests without delay and within one month of receipt. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Where the request is manifestly unfounded or excessive we may charge a “reasonable fee” for the administrative costs of complying with the request.
In some circumstances we can refuse to comply, if this is the case it will be explained to you. Please note that your right to see certain information may be limited. For example, if it may affect a police investigation or a criminal prosecution then we are not permitted to disclose the information to you.
If you believe our records are inaccurate, you can write to us, asking for them to be amended. If you believe we have unfairly withheld information or unfairly refused to amend our records, you can make a complaint using our standard complaints procedure. Alternatively, you can contact the Information Commissioner’s Office.