Privacy notice

We collect personal data belonging to our customers and the people who work for us in a variety of different ways including via:

1. this website (see section 7 below, ‘Information we collect via this website’ and our Cookies policy
2. on various forms that we may ask you to complete – these help us to gather the data that we need to sign you up to, and deliver, our services to you. Some examples include the online housing application form, a tenancy agreement, service contracts and employment contracts;
3. our ongoing contact with you - and the data or information you provide us with to help us understand your requirements or personal situation so that we can provide a service or services to you. If you provide us with personal data relating to a member of your family, your friends or associates, we will assume that you have done so with their knowledge and their consent to us collecting and processing this information;
4. CCTV images - we may process these for the purposes of resident or staff safety and security and for the prevention and detection of crime;
5. recording calls to our customer helpline - all calls to and from our 01283 528528 main switchboard phone number are recorded for quality, training and legal compliance monitoring purposes; and
6. references, or referrals from third-parties – for example, when you apply to become a Trent & Dove customer or member of staff we will request, and hold on file, any references that may be necessary to assess your application for housing or employment. For prospective tenants this includes (but is not limited to) references from other housing providers or private landlords, your mortgage lender (if you own or have owned your own home), the Police, the Probation Service, support workers, social workers, mental health workers and credit reference agencies.

The law allows us to collect, process, share and securely store personal information for the following reasons:

 

a. We need it to fulfil a contract we have with you - such as your housing application, tenancy, leasehold agreement, shared ownership, employment, or responding to an enquiry or complaint.  In some situations, we also have a legal obligation.  Examples of how we use your personal data include (but are not limited to):

• running a Housing Allocation system, which enables our prospective customers to bid on properties;
• making housing allocations;
• managing tenancies;
• managing leaseholders and shared owners;
• collecting rent and service charges;
• making sure bills and benefits are accurate and paid accordingly;
• providing a repairs and maintenance service;
• resolving Anti-Social Behaviour and Neighbour disputes;
• providing you with any information that you request from us;
• passing details of customers who may be facing homelessness through to Housing Options, the local authority housing advice and homeless prevention service;
• reporting safeguarding concerns;
• reporting criminal activity, engaging with law enforcement and statutory authorities;
• equality, diversity and inclusion;
• providing recruitment, employment and training support and opportunities, including operating a payroll and paying contractors;
• recruitment and appointment of board and committee members;
• managing employee performance and personal development; and
• filing statutory and regulatory returns.

 

b. It is necessary in order for us to pursue our legitimate interests - our legitimate interests are anything which is fair and reasonable for a Registered Provider of Social Housing to do.  This includes:

 

• providing information on home ownership products to enable our customers to purchase their own home;
• offering our customers non-FCA regulated debt and benefits support;
• offering volunteering opportunities;
• offering our customers opportunities to take part in our tenant engagement and involvement groups;
• engaging with customers so we can track the performance of, and make improvements to, our products and services;
• promoting safety in, and quiet enjoyment of, our neighbourhoods and communities; and
• working with partners on projects and services which are designed to improve our products or services, to the benefit of our customers and staff.

 

There are certain types of personal information which are classed as “special category data”. This is information relating to:

• Race or ethnic origin;
• Religious or philosophical beliefs;
• Political opinions;
• Trade union membership;
• Genetic & biometric data;
• Health information; and
• Sex life or sexual orientation.

When we collect Special Category data we will tell you:

• why we are collecting it;
• how we will use it; and
• include the details of who it could potentially be shared with.

At all times, all customers have the right to ask us which Special Category data we are processing about them, and why we are doing this.

We minimise our holding and use of Special Category data, however, given the services we provide, there are times when it is necessary.   

We have a legal obligation:

• to comply with employment, social security or social protection law;
• when providing accommodation for people with disabilities;
• when resolving neighbourhood disputes involving alleged criminal activity or Anti-Social Behaviour;
• when helping someone to get access to care or support services; or
• the establishment, exercise or defence of legal claims, particularly those relating to safeguarding investigations or any legal action that we may take in Anti-Social Behaviour cases.

When it is necessary to help us protect a person’s vital interests:

• when that person is incapable of giving consent. This is sometimes the case in emergency or urgent safeguarding situations, when we need to make decisions relating to calling emergency services or agencies, or if we are assisting agencies who have statutory authority with emergency action.

 

 

We try to meet the highest standards in all areas of our business. We take any complaints we receive very seriously and we welcome any suggestions for improving our procedures.

If you do make a complaint or enquiry we may collect and store personal information in relation to your complaint. We will keep it secure and use it only for the purpose it was collected.

When the matter is resolved or completed, we will retain the details in accordance with our retention schedule and then destroy them.

Some of our properties and our offices have CCTV to prevent, detect and deter crime and anti-social behaviour and for safety and security by helping to identify and prosecute criminal offenders.  We will clearly sign post all areas where CCTV cameras are present. 

If you wish to request CCTV footage of yourself, this can be done by contacting our main switchboard on 01283 528528 or by emailing gdprenquiries@trentanddove.org. See also section 10 on ‘Your Rights’.

You can read more about what your customer data access rights are and how you can exercise them in our Data Subject Rights Procedure.

Please contact us using your preferred contact method if you would like copies of specific information from your customer or colleague files, and we will provide this to you as quickly as possible.

The Data rights you legally have as a customer or colleague of Trent & Dove include:

• The right to be informed - about how we are using your data and what we are doing with it;
• The right of access - or the right to see the personal information we hold about you – this is known as a ‘Subject Access Request’ – more information about how you can make a Subject Access Request can be found below;
• The right to rectification – you have the right to ask us to correct data that we hold about you if you are able to provide proof that it is inaccurate, or that the data we hold should no longer be needed by us to fulfil a contract with, or provide services to, you;
• The right to erasure – you have the right to ask us to erase from our systems any data that we hold about you if you are able to provide proof that it is incorrect or that the data we hold should no longer be needed by us to fulfil a contract with, or provide services to, you;
• The right to restrict processing – you have the right to ask us not to process your data in certain ways, or limit the ways we use it, if you feel that it is being processed in a way that is not necessary in order for us to fulfil a contract with, or provide services to, you.
• The right to data portability – you have the right to ask us to provide a copy of data to you in a ‘portable’ format, which you can share with other agencies, companies or suppliers if you need to;
• The right to object – you have the right to object to us using or processing your data if you feel that it is being processed in a way that is not necessary in order for us to fulfil a contract with, or provide services to, you;
• Automated individual decision-making - you have the right not to be subject to a decision based solely on automated processing.  You can request that a person makes the decision or ask for more information about how the decision was made.  An automated decision process is used for people who do not have a complex housing need, as part of applying to join the East Staffordshire Housing Register, which we manage on behalf of the East Staffordshire Borough Council.  For further reference, see link to ESBC’s Privacy Notice: http://www.eaststaffsbc.gov.uk/privacy-notice.
• The right to withdraw your consent to us processing your data – if we have directly asked for your consent to do something and you feel that the data you have provided is being processed in a way that is not necessary in order for us to fulfil a contract with, or provide services to you;

If you require a substantial amount of your personal information, there is a formal process for this in legislation, known as a Subject Access Request (SAR).

What you need to know about making a Subject Access Request:

1. You can telephone, write or email us with your request. This can be done using any of the contact methods for Trent & Dove or you can email our Data Protection Officer directly: gdprenquiries@trentanddove.org.           
2. We may require proof of your identity and address – we will let you know this when we receive your request. 
3. When we receive your valid request – with proof of id/address if required- we will respond and provide your information within one month.  Sometimes, a request can involve us needing to look at a large volume of data or information or gather this from various sources. If we feel your request cannot be carefully fulfilled within one month, legislation allows us to extend the time period for a response by a further two months – giving us three months in total to respond to you. 
4. You can request to see any of the information that we may hold about you, including CCTV images, but the more specific you can be about what you require, the quicker we can respond to your request. If you are requesting CCTV footage of yourself, please specify the time, date and location of the footage, and supply a clear photograph of yourself so that we can find you on the footage.
5. Please be aware that you are only legally entitled to ask for, and be provided with, copies of information that is about you, and you alone. We may need to edit some information out – known as redacting – if the data you have asked for contains information about other people.  This is because the law requires us to protect the privacy rights of all individuals.

This Privacy Notice will be regularly reviewed and updated to reflect changes either to the way in which we operate or use personal data or changes to data protection legislation.

If, at any time, you are not satisfied with our approach to personal data, or the way we process it, you have a legal right to approach the Data Protection Regulator, the Information Commissioner’s Office (or ICO) with your concerns.

You can obtain more information about the role of the ICO, and guidance about how UK businesses must process your personal data on the ICO’s website – www.ico.org.uk.

The ICO has a helpline you can call on 0303 123 1113. Their normal opening hours are Monday to Friday between 9am and 5pm (excluding bank holidays).

You can also:

email the ICO via their website https://ico.org.uk/make-a-complaint/ or use their live chat.

or write to them:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow, Cheshire
SK9 5AF.