Privacy Notice for Applicants and Tenants
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- Rudolf Morgan
- 5 years ago
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1 Privacy Ntice fr Applicants and Tenants What we need Scttish Brders Husing Assciatin (SBHA) will be a "cntrller" f the persnal infrmatin that yu prvide t us thrugh yur cmpleted Husing Applicatin Frm, and any ther subsequent persnal infrmatin prvided t, r prduced by, SBHA in the curse f yur husing applicatin and/r tenancy unless therwise stated in this privacy ntice. This will als include the persnal infrmatin f members f yur husehld, including children, and as such they shuld be made aware f the cntents f this ntice. When yu apply fr a huse with SBHA, and during the curse f yur tenancy, we will ask yu fr the fllwing persnal infrmatin: cntact details yur name, address (including previus addresses), phne number, address, Natinal Insurance number, date f birth; details f members f yur husehld, including children their name, phne number, address, Natinal Insurance number, date f birth, gender; details f any supprt wrker(s) their name, address, phne number, address; health infrmatin fr yu and yur husehld fr example, pregnancy and any ther health cnditin which may impact n the type f prperty yu wuld be suited t, and any ptential medical adaptatins t yur prperty; criminal cnvictins data including any members f yur husehld wh require t register under the Sex Offenders Act 2003, r wh have been served an Anti- Scial Behaviur Order; details f any previus tenancies including details f any past rent arrears and/r evictins, and names and cntact details f frmer landlrds t act as references; details f yur immigratin status, where applicable; details f any member f SBHA staff t whm yu, r a member f yur husehld, are related; equality infrmatin yur age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, gender, sex, sexual rientatin, religin r belief, and disability; incme infrmatin fr yu and yur husehld emplyment status, incme, benefit entitlement and receipt, and savings payment details yur bank accunt number, srt cde, debit/credit card number; and ther infrmatin which may result frm yur husing applicatin/tenancy with SBHA including infrmatin relating t any cmplaints r alleged anti-scial behaviur. 1
2 Why we need yur persnal infrmatin cntractual purpses We need t cllect yur persnal infrmatin s that we can assess yur eligibility fr and manage yur husing if successful. We will use yur persnal infrmatin fr these purpses t: manage and assess yur applicatin fr husing with SBHA, including the size f prperty yu (and yur husehld) are given pririty fr, in line with SBHA s Plicies and Prcedures. This will als include seeking references frm yur frmer landlrds/ther relevant parties; manage yu and yur husehld's husing services, including prcessing payments f rent and service charges; mnitr yu and yur husehld's cmpliance with yur tenancy agreement cnditins; and carry ut repairs and/r planned maintenance wrks/surveys t maintain the standard f yur prperty. If yu d nt prvide us with all f the persnal infrmatin that we need t cllect then this may affect ur ability t ffer yu and prvide yu with husing. Why we need yur persnal infrmatin legal bligatins We are under a legal bligatin t prcess certain persnal infrmatin relating t ur husing applicants and tenants fr the purpses f cmplying with ur bligatins under: the husing legislatin in Sctland that sets dwn bligatins n registered scial landlrds t prvide husing management services, including in relatin t ur cre activities services t prvide husing and cmply with the regulatry requirements f the Scttish Husing Regulatr; the Equality Act 2010, which requires us t prcess persnal infrmatin t make reasnable adjustments where necessary; the Husing (Sctland) Act 2010, which requires us t reprt statistical data n ur husing applicants and tenants t the Scttish Husing Regulatr; and the Antiscial Behaviur etc. (Sctland) Act 2004, which requires us t disclse and share infrmatin regarding actual r alleged antiscial behaviur. Why we need yur persnal infrmatin public interest purpses We als prcess yu and yur husehld s persnal infrmatin where it is necessary fr the perfrmance f a task carried ut in the exercise f fficial authrity vested in SBHA t: prevent instances f anti-scial behaviur, reslve any reprted instances f antiscial behaviur, and pass any such reprts f anti-scial behaviur t the relevant agencies; and carry ut criminal recrd checks with the apprpriate authrities relevant t yur applicatin and/r tenancy. 2
3 Why we need yur persnal infrmatin legitimate purpses We als prcess yu and yur husehld s persnal infrmatin in pursuit f ur legitimate interests t: mnitr phne calls, s, letters and any ther crrespndence related t yur tenancy r applicatin t enable us t prvide a cntinuus service t yu n matter wh yu cntact at SBHA; issue cmmunicatins and newsletters t yu t prvide yu with infrmatin n yur applicatin and/r tenancy, as well as infrmatin n services that SBHA prvides; target SBHA s services t supprt the needs f husehlds, which culd include welfare benefits advice; undertake research t imprve ur services; and prvide statistical infrmatin t supprt grant funding applicatins. Where we prcess yur persnal infrmatin in pursuit f ur legitimate interests, yu have the right t bject t us using yur persnal infrmatin fr the abve purpses. If yu wish t bject t any f the abve prcessing, please cntact us by ing us at enquiries@sbha.rg.uk, r writing t us at SBHA, Suth Bridge Huse, Whinfield Rad, Selkirk, TD7 5DT. If we agree and cmply with yur bjectin, this may affect ur ability t prvide services t benefit yu with yur husing applicatin and/r tenancy. Why we need yur persnal infrmatin equality mnitring requirements We use yur persnal infrmatin relating t yur age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, gender, sex, sexual rientatin, religin r belief and disability t help us identify and keep under review the existence r absence f equality f pprtunity r treatment between grups f peple within the same categries t prmte r maintain equality within SBHA. Other uses f yur persnal infrmatin We may ask yu if we can prcess yu and yur husehld s persnal infrmatin fr additinal purpses. Where we d s, we will prvide yu with an additinal privacy ntice with infrmatin n hw we will use yur infrmatin fr these additinal purpses. Wh we share yur persnal infrmatin with We may be required t share persnal infrmatin with statutry r regulatry authrities and rganisatins t cmply with statutry bligatins (including the Department f Wrk and Pensins). We may als share the infrmatin with: Scttish Brders Cuncil (and its agencies) fr the purpses f: preventing hmelessness and tackling anti-scial behaviur; investigating and detecting ptential tenancy and benefit fraud; and assisting the Cuncil in respnding t emergencies r majr accidents. This allws the Cuncil, in cnjunctin with the emergency services, t identify citizens wh may need additinal supprt ; 3
4 Plicy Sctland fr the purpse f tackling anti-scial behaviur and any ther suspected criminality; Medical Prfessinals (including dctrs) fr the purpses f assessing any unified health assessment as part f the Applicatin prcess, and sharing this, and ur assessment f it, with partner Husing Assciatins in the Scttish Brders where yu have applied fr husing with them as well; ur partner Husing Assciatins in the Scttish Brders, fr the purpse f tackling antiscial behaviur; the Curts, in the event f any curt case between yu and SBHA; and Sheriff Officers wh are acting under an rder issued by a curt. We may als share persnal infrmatin with ur prfessinal and legal advisrs fr the purpses f taking advice. SBHA als emplys third party suppliers t prvide services, as set ut belw. These suppliers may prcess persnal infrmatin n ur behalf as "prcessrs" and are subject t written cntractual cnditins t nly prcess that persnal infrmatin under ur instructins and prtect it. In the event that we d share persnal infrmatin with external third parties, we will nly share such persnal infrmatin strictly required fr the specific purpses and take reasnable steps t ensure that recipients shall nly prcess the disclsed persnal infrmatin in accrdance with thse purpses. These third parties include: ur printing and mailing suppliers, s that we can prvide yu with infrmatin thrugh the pst relating t yur tenancy, including tenant newsletters and rent statements; ur satisfactin survey prviders, s that they can cntact yu t prvide feedback n the service that SBHA prvides; ur authrised repairs sub-cntractrs t enable them t carry ut repairs t yur hme; ur planned maintenance cntractrs and surveyrs, t enable them t carry ut any necessary upgrade wrk t (r surveys f) yur hme; and tracing and debt cllectin agencies, in the event that yu end yur tenancy with a balance remaining due t SBHA. We may als share yur persnal data (specifically yur name, address and phne number) with a utility cmpany when yu mve int an SBHA prperty. This is because a landlrd has a legitimate interest in making sure that utility charges are directed t thse respnsible. The utility cmpany will then becme the cntrller f yur persnal data. We will d this s that the utility cmpany can take steps t enter int a cntract with yu fr the supply f energy. Once yur tenancy cmmences, yu will be free t change yur energy supplier at any pint. Mre infrmatin n ur preferred energy suppliers privacy plicies is available here: We may als share yur persnal data (specifically yur name, address, cntact details and bank accunt details) with ur payment service prvider. They will then becme the cntrller f yur persnal data. We will d this t enable yu t pay yur rent. Mre infrmatin abut ur current payment prviders privacy plicies is available here: 4
5 Hw we stre yur persnal infrmatin Yu and yur husehld's persnal infrmatin is stred n ur electrnic filing system and ur servers based in the UK, and is accessed by ur emplyees fr the purpses set ut abve. Where hard cpies f dcumentatin are retained in line with SBHA s data retentin schedule, these will be stred securely at SBHA s Head Office, Area Offices r secure ffsite strage. We will nt rdinarily transfer yur data utwith the EU. If this psitin changes and yur persnal infrmatin is prpsed t be transferred utwith the EU, we will prvide yu with infrmatin regarding the safeguards that we have put in place with the recipient cuntry t prtect yur persnal infrmatin. Hw lng we keep yur persnal infrmatin We will nly keep persnal infrmatin fr as lng as necessary t manage yur applicatin fr husing, t prvide yu with husing and/r related services, and t safeguard SBHA in the event f any claims, cmplaints, litigatin, enquiries r investigatins during r fllwing the terminatin f yur applicatin and/r tenancy. Unless yu ask us nt t, we will review and pssibly delete persnal infrmatin 6 years after the end date f yur tenancy. Where yu cancel an applicatin fr husing prir t being ffered a tenancy, we will review and pssibly delete persnal infrmatin 1 year after the date f cancellatin. We may keep certain persnal infrmatin f tenants (and husehld members) fr lnger in rder t cnfirm yur identity and hw lng yu were a tenant f SBHA. We need t d this in the event f a claim against SBHA. We have a data retentin schedule that sets ut the perids fr retaining and reviewing all infrmatin that we hld. This sets ut different retentin perids and yu can request a cpy by ing us at enquiries@sbha.rg.uk, r writing t us at SBHA, Suth Bridge Huse, Whinfield Rad, Selkirk, TD7 5DT. Yur rights Yu can exercise any f the fllwing rights by ing us at enquiries@sbha.rg.uk, r writing t us at SBHA, Suth Bridge Huse, Whinfield Rad, Selkirk, TD7 5DT. Yur rights in relatin t yur persnal infrmatin are: yu have a right t request access t the persnal infrmatin that we hld abut yu by making a "subject access request"; if yu believe that any f yur persnal infrmatin is inaccurate r incmplete, yu have a right t request that we crrect r cmplete yur persnal infrmatin; yu have a right t request that we restrict the prcessing f yur persnal infrmatin fr specific purpses; and if yu wish us t delete yur persnal infrmatin, yu may request that we d s. Any requests received by SBHA will be cnsidered under applicable data prtectin legislatin. If yu remain dissatisfied, yu have a right t raise a cmplaint with the Infrmatin Cmmissiner's Office at 5
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