Data protection

Privacy Notice

Tower Hamlets Community Housing (THCH) is committed to protecting the personal information we collect about you and obtaining, using and disclosing this information in accordance with legislation. For the purposes of the Data Protection Act 2018 and the EU General Data Protection Regulation (GDPR), THCH is classified as a data controller. This means that we collect personal data and decide how and why it is used and ‘processed’. We will only use it for the legitimate purposes listed below and for purposes that we have told you about in advance.

Privacy is important to us, and we are committed to protecting and ensuring your data remains safe at all times, in accordance to our legal obligations. Privacy laws govern the way in which we process your information as well as the rights you have to the information we hold about you.

This privacy notice tells you everything you need to know about THCH’s processing of personal data for the purposes of housing management and covers the following 5 areas:

 

1. What Information we collect from you

We collect personal data and special categories of personal data (also known as sensitive personal data, e.g. ethnicity and heath information relating to any disabilities) so that we can understand your needs better and can tailor our service to you. Information is collected from you in a range of ways and at a number of different times. These include but are not limited to:

• Application forms and supporting information when you apply for a rented property with us. Supporting information can include identification documents such as passports or identity cards
• As part of the application process for purchasing a shared ownership or outright sale property, e.g. financial information and supporting documentation
• Information collected during the course of any tenancy or agreement that you are granted, e.g. contact details, welfare benefits, your income and savings, along with any information gathered as part of any investigations into nuisance or anti-social behaviour
• Information provided by you when replying to surveys, questionnaires, feedback forms, competitions or requests from THCH, e.g. satisfaction surveys, preference and profiling data
• When you report repairs or other issues, such as nuisance or anti-social behaviour, to us, e.g. details of the issue or access details
• A forwarding address provided by you at the end of a tenancy agreement
• As part of the development process, for example, sharing resident names and addresses with contractors or consultants to facilitate consultation meetings, deal with boundary enquiries and defects work etc.
• We may collect information on your support needs, so we can understand how to best support and assist you, e.g. medical and next of kin details.
• We may capture images on CCTV in the public areas of our offices or schemes.
• Photographs taken at THCH events may contain your image.
• We may record telephone calls made to our Customer Services Team for training or quality assurance reasons but we will tell you if we are going to do this.
• Information when you complete surveys, questionnaires, feedback forms and participate in competitions.

Any information entered into a form on the website or emailed to us may contain personal information which will be transmitted securely and treated in accordance with this Policy.

We may also process information about you on behalf of another organisation you receive services from:

• We will receive the information we need to provide a service to you (for example to ensure we can find a property that suits your needs)
• We may obtain the information, or related information, from you or our partner organisations, our staff or public information sources including credit reference agencies.

 

2. How we store your information

We store personal and special categories of personal information both electronically and in paper format. We use a range of controls to keep your personal information secure from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. These include security policies, processes and technical physical security solutions.

Information kept on computer is protected by system security such as passwords, firewalls, virus protection software and encryption. Systems are backed up daily with copies of the backed-up data kept securely off site.

Information kept in a paper format is placed in secure storage, e.g. lockable filing cabinets. When you call our Customer Services Team, we will ask you security questions to clarify your identify before disclosing any account-related information. We do this to protect you and to make sure that other people are not privy to your personal information.

If you would like another person, e.g. a relative, partner, friend, etc to talk to us about your account or relationship with us, you will need to provide them with your permission and make us aware of this. We cannot discuss your personal situation or disclose information about you without your permission. You can explain this permission verbally every time you call us if the other person is with you or put it in writing so we can make a note of your request on our system and then speak with your chosen contact.

 

3. Why we collect your information

In order to:

• Provide a service to you more effectively
• Keep in touch, understand your needs and be able to invite you to events
• Tell you about changes to THCH
• Meet your housing management needs and requirements
• Manage payments from you, to you and for accounting purposes including debt collection
• Provide additional services at your request, including resident involvement initiatives and every day support services
• Tackle anti-social behaviour
• Ensure THCH colleague and customer security and health and safety
• Deliver quality management
• To promote the work of THCH by showcasing our activities and events
• Meet our legal obligations including the requirements of our funders or regulators
• Resolve complaints and queries
• Participate in initiatives to assist in the prevention of financial and social exclusion
• Ensure no group is disadvantaged in the design of our homes

 

4. Who we may share your information with and why

There may be times when we disclose your details to others, as detailed below. Where required, we will ensure that we have appropriate information sharing protocols in place.

• Our staff, contractors and suppliers who provide services to you, or who provide services on our behalf, e.g. housing contractors who undertake repairs or improvements to your home or research companies who conduct surveys for us
• Another person who you have provided permission to act on your behalf, e.g. your next of kin
• Banks, e.g. 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
• Our solicitors and other advocacy partner organisations
• Our insurers, in case of public liability claims and similar
• Credit reference agencies
• External assistance where you have agreed to the referral, e.g. to investigate money problems or for social services support
• Training providers or learning institutions
• Utility companies
• Debt collection agencies acting for others and on our behalf to collect former debt.
• Facebook, Twitter and Instagram as part of our social media activities.

In some cases, we may have a duty to disclose your information by law to:

• Other housing associations
• Local authorities, regulators and government departments
• Police, fire services, health authorities, or medical staff
• Others who may need information from us for their own purposes, for example detecting and preventing crime, prosecuting offenders and for the prevention and detection of fraud.

We do not provide organisations with access to your information in return for payment for their marketing or commercial purposes. However, at times we may be obliged to disclose your information by law to a regulator with appropriate powers (e.g. the Homes and Community agency), or via court order.

We will not share your personal information with anyone who claims to represent you unless we are satisfied that you have appointed them or they act in some recognised official capacity. We will take necessary steps to confirm the callers’ identity or check that we have your consent to deal with them on your behalf.

We are clear with organisations that they must comply with data protection legislation and maintain confidentiality with regard to the personal and special categories of personal information we have provided to them. This includes how they will use, store and share personal information. We have information sharing agreements with them that set out these requirements.

 

5. How you can access the information we hold on you

You have a legal right to access information we hold about you, including the right to:

• be informed about how we process your personal information – this is why we have developed this privacy notice
• have access to a copy of the personal information we collect and keep on you – known as a subject access request
• have inaccurate or incomplete personal information rectified
• restrict the processing of your personal data in certain circumstances, for example when you have challenged the accuracy or you object to the processing
• object to processing for direct marketing or for THCH’s legitimate interests or performance of a task in the public interest, or for the purposes of scientific/historical research and statistics
• have your personal information erased in certain circumstances where there is no compelling reason for THCH to continue processing it
• receive a copy of your personal information is a machine-readable format, this right allows you to move, copy or transfer information to another company, e.g. another housing association, this is known as “data portability”
• object to automated decision making that would affect you significantly, in certain circumstances
• claim compensation for damages caused by a breach of data protection laws (this can only be remedied via the courts)
• at any time, withdraw your consent for THCH to use or share your special category personal information where you have previously given consent.

THCH does not use automated decision making to make decisions about tenants, residents, employees or applicants. If you want to exercise any of your rights above, please complete this form and submit to the contact details below.

If you have any questions about the manner in which we collect, use, share and store your information please contact dpo@thch.org.uk.
You can ask any of our staff or write to:

The Data Protection Officer

Tower Hamlets Community Housing

285 Commercial Road

London. E1 2PS

 

Complaints:

If you have any concerns about the manner in which THCH, or any contractors/suppliers working on behalf of THCH has handled your personal information, you can write to the Data Protection Officer at the above address or email  dpo@thch.org.uk. Should you remain dissatisfied you can contact the independent Information Commissioner’s Office by completing their online complaints form https://ico.org.uk/concerns/handling or via phone on 0303 123 1113

 

Changes to our Privacy Notice

If this privacy notice changes in any way, we will place an updated version on this page. By regularly viewing this page you will ensure that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with others.

Job Applicant Privacy Notice

As part of any recruitment process, Tower Hamlets Community Housing (THCH) collects and processes personal data relating to job applicants. THCH is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

 

1. What personal data does THCH collect?

THCH collects a range of information about you. This may include, but is not limited to:

• Your name, address and contact details, including email address and telephone number
• Age/date of birth
• Sex/gender
• Copy of your driving licence and/or passport/identity card
• Nationality/citizenship/place of birth
• Social security number and other tax-related information
• Details of your qualifications, skills, experience and employment history
• Information about your current level of remuneration, including benefit entitlements
• Whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process
• Information about your entitlement to work in the UK
• Details of any criminal convictions
• IP address, if you submit your application form/curricular vitae (CV) via our website
• CCTV footage if you attend our premises.

THCH collects this information in a variety of ways, e.g. data might be contained in application forms and CVs, or may be obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.

THCH will also collect personal data about you from third parties, such as references supplied by former employers, and information from criminal records checks.

Your personal data will be stored securely, in a range of different places, including on your application record (hard copy file), in THCH’s core Human Resources (HR) management system, applicant management system and on other IT systems (including email, THCH servers).

 

2. Why does THCH process personal data?

THCH needs to process your personal data in order to conduct interviews and enter into an employment contract with you.

In some cases, THCH needs to process personal data to ensure that we are complying with our legal obligations.  For example, we are required to check a successful applicant's eligibility to work in the UK before employment starts.

THCH has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process.  Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job.  THCH may also need to process data from job applicants to respond to and defend against legal claims.

Where THCH relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.

If you provide us with explicit consent, and advise us on any disabilities, THCH will use this to make reasonable adjustments to the recruitment process.  This is done in order to carry out our obligations and exercise specific rights in relation to employment.

Where THCH processes other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes, for which completion is optional.

For all roles, THCH is obliged to seek information about criminal convictions and offences.  Where THCH seeks this information, we do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment, nonetheless, THCH is compliant with the Police Act 1974 and the Rehabilitation of Offenders Act 1974.

THCH will not use your data for any purpose other than the recruitment campaign for which you have applied.

 

3.Who has access to your personal data?

Your information will be shared internally for the purposes of the recruitment exercise.  This includes members of the HR team, interviewers involved in the recruitment process, managers in the hiring business area and IT staff if access to the data is necessary for the performance of their roles.

THCH will not share your personal data with third parties, unless your application for employment is successful and we make you an offer of employment.  THCH will then contact former employers in order to obtain references for you, and the necessary body to carry our criminal records checks, which is Disclosure Scotland in THCH’s case.

THCH will not transfer your data outside the European Economic Area.

 

4. How does THCH protect your personal data?

THCH takes the security of your personal data seriously.  We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

 

5. For how long does THCH keep your data?

If your application for employment is unsuccessful, THCH will seek your consent to hold your data on file for up to 6 months after the end of the relevant recruitment process.  If consent is provided, at the end of that period, your data will be securely deleted and paper copies destroyed.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment.  The periods for which your data will be held will be provided to you upon offer of employment, but will typically be for the life of your employment at THCH and 6 years post-employment.

 

6.Your rights as a data subject

As a data subject, you have a number of rights. You can:

• Withdraw your consent if consent was previously provided
• Access and obtain a copy of your data on request
• Require us to change incorrect or incomplete data
• Require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing
• Object to the processing of your data where THCH is relying on its legitimate interests as the legal ground for processing
• Ask us to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override THCH’s legitimate grounds for processing data.

If you would like to exercise any of these rights, please contact Head of HR at dpo@thch.org.uk.  [You can make a subject access request by completing the THCH Data Subject Request Form.]

If you are unhappy with the way your subject access request was handled, you can request an internal review of the process. The internal review will be carried out by an Executive Director of the company and will be completed with 4 weeks.

If you believe that THCH has not complied with your data protection rights, you can complain to the Information Commissioner’s Office.

Information Commissioners Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

0303 123 1113

Website: https://ico.org.uk/concerns/

 

7.What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to THCH during the recruitment process.  However, if you do not provide the information, THCH may not be able to process your application effectively or at all.

Complaints:

If you have any concerns about the manner in which THCH, or any contractors/suppliers working on behalf of THCH has handled your personal information, you can write to the Data Protection Officer at the above address or email  dpo@thch.org.uk. Should you remain dissatisfied you can contact the independent Information Commissioner’s Office by completing their online complaints form https://ico.org.uk/concerns/handling or via phone on 0303 123 1113

Changes to our Privacy Notice

If this privacy notice changes in any way, we will place an updated version on this page. By regularly viewing this page you will ensure that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with others.

Last updated May 2018

 

Tower Hamlet Community Housing’s (THCH’s) website uses cookies, by default, for the purpose of making your visits to our site friendlier and more efficient. Cookies are small text files that are stored on your internet-connected device (computer, smart phone, tablet, etc) by websites that you visit. They are used across the Internet in order to make the web-experience more user friendly as well as to provide information to the owners of the site and remember choices you make, such as your language, region, preferences and settings.

 

1. What cookies are used

Essential cookies.

Some session cookies are required to make navigating through our website a smooth process. Positioning information is retained so that the website remains fully functional when accessed via a smartphone, table or other device.

Performance/analytical cookies.

These cookies allow Dysfunction to recognise and count the number of visitors and track how visitors navigate around and use our website. This helps us to improve the way the website works, e.g. making searches easier for visitors. Dysfunction can also see overall visitor patterns of usage rather than any one person’s activity.

Our site by default uses a single ‘Session Cookie’. Session Cookies allow websites to collect information (including your IP address) during a browser session. These Session Cookies expire at the end of a browser session so would not be stored longer term.

No name, address or specific user details are recorded from site visits and we will not attempt to identify individuals from such information unless required to investigate a breach of law or regulation. Any personal information that we do collect from you, will be legally protected under the UK’s data protection laws, as well as the EU General Data Protection Regulation (GDPR) as we have a duty to protect your personal information. We do not pass on your details to any third party or government department unless you give us the permission to do so or the law requires/permits it.

You may delete and block all cookies from this site, but parts of the site may not work exactly as intended.

 

2. Third-party cookies

THCH and Dysfunction have no control over third parties, including providers of external services, who may also use cookies to record your visit to our website, pages visited and links followed in order to display advertisement relevant to your interests (Targeting cookies). They may also use performance/analytical cookies.

 

3. Google Analytics

Google Inc (Google) provides a web analytics service, Google Analytics, which uses cookies to help website operators analyse how the site is used. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google services in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.

 

4. Monitoring

THCH reserves the right to monitor the use of the email (incoming and outgoing electronic mail) and internet system to ensure effective and appropriate use, and other lawful purposes when required.

 

5. Links

www.thch.org.uk contains links to other websites. This cookie notice applies only to the THCH’s website. When you are transferring to another site you should read their privacy/cookie statement for their policy on the use of personal information. We do not pass on any personal information you have given us to any other site.

 

6. Changes

If this cookie notice changes in any way, we will place an updated version on this page. By regularly viewing this page you will ensure that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with others.

 

Complaints:

If you have any concerns about the manner in which THCH, or any contractors/suppliers working on behalf of THCH has handled your personal information, you can write to the Data Protection Officer at the above address or email  dpo@thch.org.uk. Should you remain dissatisfied you can contact the independent Information Commissioner’s Office by completing their online complaints form https://ico.org.uk/concerns/handling or via phone on 0303 123 1113

 

Changes to our Privacy Notice

If this privacy notice changes in any way, we will place an updated version on this page. By regularly viewing this page you will ensure that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with others.

 

Last updated May 2018