CONTRACTUAL PURPOSES. Last Updated: 8 Oct 18

Transcription

1 On signing this Tenancy Agreement you will become an RBH Tenant. To deliver our full range of services to you, the personal information you have provided will be processed in a number of ways as set out below. Our legal basis for the processing varies depending on the purpose. The processing set out below is in addition to any processing we ve already told you about: CONTRACTUAL PURPOSES The following are for the performance of the Tenancy Agreement which is a contract between RBH and yourself: Purpose for Processing To determine your legal right to be assigned to the Tenancy Agreement, or have your name removed and/or changed on the Tenancy Agreement. So we can provide a grounds maintenance & caretaking service to your neighbourhood. To ensure that, if necessary, adequate support & early interventions can be put in place to assist you in sustaining your tenancy. To start your tenancy record. Privacy Information with Rochdale Borough Council. following the end of your tenancy. information to comply with employment and Social Protection Law. Your personal information will then be immediately deleted after completion of the work identified. information to comply with the Social Protection Law. with Rochdale Borough Council & other support agencies. following the end of your tenancy. with Probation Services. Your personal information will then be kept on our records for 40 years from the end of the tenancy. To make payments to you for goods or services. As part of this processing your personal data may be shared with external auditors years from payment. To make payments to you in the event RBH needs to do so. As part of this processing your personal data will be shared with RBH s bank in order to pay the money

2 Throughout your tenancy, we may need to carry out work to your home to ensure that it remains warm, safe and dry and we ensure we are meeting the Decent Homes Standard. To enable us to provide you with a responsive repairs service, meet our contractual obligations under the terms of the Tenancy Agreement and monitor tenant satisfaction. So that our surveyors can carry out surveys of your home to identify what work may need doing and ensure your home meets the necessary safety and legal standards. years from the end of your tenancy. information to comply with employment and Social Protection Law. As part of this processing your personal data may be shared with our external contractors and consultants. Sensitive personal information will be removed after completion of works, all other personal information will be held for 6 years from the end of your tenancy. with the emergency out of hours call centre service provider, repair contractors or agents acting on behalf of RBH. after the repair. As part of this processing your personal information will be shared with consultants & auditors. Your personal information will then be kept on our records for 28 days. For the collection of rent and service charges due as a tenant of RBH. As part of this process, your full name, current address, previous address, date of birth, National Insurance Number may be shared with us by the Department for Work and Pensions (DWP). As part of this processing your personal data may be shared with financial institutions such as Banks and Building Societies, DWP, Rochdale Borough Council, and other government bodies. years from the end of your tenancy. To ensure that any breaches of your tenancy conditions are identified & investigated accordingly. The additional legal basis for processing protected categories of personal information is to comply with Social Protection Law. As part of this process, your name, date of birth, address, phone number, personal , household composition (including gender & age of everyone living in the property), name & date of birth of any

3 ONLY if you have a former Tenant Debt with RBH to recover any outstanding debt that you have with RBH in line with our allocations and rehousing policy. other adults living with you, any mental health issues and any physical health issues may be shared with us by any interested 3rd party, including the general public, statutory agencies & internal RBH colleagues. years following the end of your tenancy. As part of this processing your personal data will be shared with debt recovery agencies Your personal information will then be kept on our records for 20 years from termination of your previous tenancy or 6 years from when the debt is repaid; whichever is shorter. Throughout the duration of your tenancy there may be other instances where you may make payments to RBH. Processing will be then necessary for the performance of a contract which is separate from the Tenancy Agreement. Such processing will be as follows: For issuing invoices to you & receiving payments for goods or services provided. As part of this processing, your personal information may be shared with external auditors. from payment. LEGAL REQUIREMENT There are some instances where we are under a legal duty to process your personal information: Purpose for Processing To identify asbestos within the fabric of your RBH home and to keep you and any visitors to your home safe. To assist the Police with the prevention or detection of crime, and the apprehension or prosecution of offenders. Privacy Information We are required to process this personal information to comply with Control of Asbestos Regulations Your personal information will then be kept on our records for 28 days. information for reasons of Substantial Public Interest. This process may involve any information which is shared with RBH in the course of its business by any of its partners, suppliers, customers, employees and members of the public.

4 We are required to process this information in accordance with the Data Protection Act As part of this processing your personal data will be shared with the Police. following the request of disclosure. To assist in the prevention of fraud. information for reasons of Substantial Public Interest. As part of this process contact details, education and skills, health and social care needs, government information such as your National Insurance number, ethnicity, sexual orientation, background checks, criminal history, name, date of birth, household composition (including gender & age of everyone living in the property), name & date of birth of any other adults living with you, family members, any mental health issues, physical health issues, debts, immigration eligibility, bank account information, tax and benefit details may be shared with us by any interested 3rd party, including the general public, statutory agencies & internal RBH colleagues, Rochdale Borough Council s Revenue & Benefit Section, other organisations with whom you have a debt. We are required to process this information in accordance with the Data Protection Act As part of this processing your personal data may be shared with any authorised Anti-Fraud Organisations (this includes Local Authorities). years following the request for a disclosure. To keep RBH employees safe by ensuring they are aware of any risks related to attending an RBH home. information to comply with Employment Law. As part of this process, wellbeing, medical and mental health records, addictions, family history, and criminal history may be shared with us by Stepping Stones, schools, the Police, Petrus, NHS mental health teams, Rochdale Borough Council Adult and Children s Care Services, probation and community rehabilitation agencies, other similar support agencies. We are required to process this personal information by the Health and Safety at Work Act 1974 and Management of Health & Safety

5 Regulations with external contractors / subcontractors working on behalf of RBH. Your personal information will then be kept on our records for 3 years after end of your tenancy. To capture your opinions, to support the development & improvement of our services as required by the Regulator for Social Housing (RSH) & ensure full representation of our customers & members. We are required to process this personal information to comply with the Regulator for Social Housing s Tenant Involvement and Empowerment Standard. Your personal information will then be kept on our records for 2 years. LEGITIMATE INTEREST We have a legitimate interest to process your personal information for the following purposes: Purpose for Processing For the detection & prevention of fraudulent activity with regards to the occupancy of homes designated for use as social housing. This could involve identifying individuals who RBH has not come into contact with previously. To capture your opinions to support the development & improvement of our services & ensure full representation of our customers & members. To enable us, or partner agencies, to assess, investigate, prevent, addressing and/or prosecuting behaviours and/or lifestyles which are found to have placed people at risk of, or have caused harm. Privacy Information We have a legitimate interest to do this because we have duty to ensure that our social housing is used for the purpose and in the circumstances it was intended. RBH needs assurance its homes are being effectively utilised to respond to the needs of individuals and families in Rochdale Borough. As part of this process your name, address, gender, date of birth may be shared with us by RBH s credit rating tenancy fraud detection services providers. Your personal information will be kept on our records for 6 years. We have a legitimate interest to do this because RBH needs to ensure that the services provided meet the needs of our customers. Your personal information will then be kept on our records for 2 years. We have a legitimate interest to do this because RBH has a responsibility towards the welfare & wellbeing of residents & visitors to RBH neighbourhoods.

6 To ensure that we monitor & evaluate fair access to services, homes, jobs & promotions. information for reasons of Substantial Public Interest. As part of this process your contact details, family members, education & skills, health & social care needs or government information such as your National Insurance number, ethnicity or sexual orientation, or information relating to background checks, e.g. criminal history may be given to us by or RBH may share with partner agencies capable of taking direct action to safeguard the well being of vulnerable or at risk persons. In such instances your personal information will be kept on our records for 6 years from file closure. Personal data relating to criminal convictions & offences will be deleted immediately after file closure. The additional legal basis for processing protected categories of personal information is for reasons of Substantial Public Interest. We have a legitimate interest to do this to ensure that we monitor and evaluate fair access to services, homes, jobs and promotions, to ensure compliance with the Equality Act 2010 & the Public Sector Equality Duties. Your personal information will then be kept on our records for 28 days & then anonymised. To communicate updates to you with news about RBH. We have a legitimate interest to do this to keep you up to date with RBH news by allowing us to provide you with information on your home, your neighbourhoods and RBH services. Your contact details to receive tenant communications will be kept until 1 year after the end of your tenancy. RBH will keep editions of our tenant communications and any personal information within the publication will be kept for historical and archiving purposes. ONLY If you have a door access and/or concierge service: To provide a door access and concierge service to our tenants and their visitors. We have a legitimate interest to maintain the safety of tenants & prevent access by unauthorised persons. As part of this process your personal information will be shared with authorised employees, law enforcement agencies & the local authority. Your personal information will then be kept on our records for the duration of your tenancy. To assist RBH in ensuring the services it provides are tailored towards We may need to process protected categories of personal

7 your needs. ONLY If you have a domestic alarm system: To maintain & service your domestic alarm system. We have a legitimate interest to do this because RBH has a responsibility towards the welfare and wellbeing of its customers. As part of this process your contact details, family members, education & skills, health & social care needs or government information such as your National Insurance number, ethnicity, sexual orientation, background checks & criminal history may be shared with us by, or may be shared with, one or more partner agencies who work alongside RBH in looking after the welfare of, or providing safeguarding services to the people of Rochdale, for example Greater Manchester Police or Rochdale Borough Council. Your personal information will then be kept on our records for 3 years after the end of your tenancy. We have a legitimate interest to do this because RBH works to protect its assets by servicing and maintaining the fabric of its homes as well as, fixtures and fittings that are supplied and owned by RBH. Your personal information will then be kept on our records for the duration of your tenancy. All processing of your personal information will remain within the UK. You have a number of rights which we have to respect. One of these is a right to see all your personal information that RBH processes. For more information on your rights and for further information on how RBH protects your personal information, please see the RBH Privacy Statement. If you are unhappy with how RBH processes personal information you may complain to the UK s regulator, the Information Commissioner s Office (ICO). RBH employs a Data Protection Officer (DPO) to ensure RBH protects your rights when processing your personal information. The DPO can be contacted in the following ways: Telephone: By letter: DPO@rbh.org.uk (and ask to speak with the DPO) DPO, RBH, Sandbrook House, Sandbrook Way, Rochdale, OL11 1RY.