ICO Registration: Z1138776
Housing Applicant Privacy Notice
River Clyde Homes is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information in relation to your application for social housing. It also details your rights in relation to your personal information.
The types of information we collect
River Clyde Homes is a data controller of the information that you provide to us. This will include personal information about you as a prospective tenant and about the people you wish to live with. This information is required to assess your eligibility for housing and to meet our legal and regulatory obligations as a social housing provider.
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 collect and process the following data:
• Identity Data: your full name, gender, marital status, date of birth and National Insurance number;
• Joint applicant or household member data: name, gender, age, relationship to you;
• Authorised Representative Data: identity and contact data of anyone authorised to act on your behalf;
• Current Address Data: details of your current address, or previous addresses to help us assess your housing circumstances and preferences;
• Housing Circumstances Data:
o Information relating to your current accommodation (size of property, standard of property
o if applicable, referral documentation from homelessness services and any additional information which may be helpful in assessing your housing need
• Behavioural Data: if applicable, details of prior convictions, anti-social behaviour orders, or court action raised against you, for the purpose of meeting your needs and fulfilling our legal obligations;
• Contact Data: your contact details (phone, email, or correspondence address) and communication preferences;
• Health and Disability Data: if applicable, if you or another member of your household is pregnant, details of any medical needs or adaptive living needs you or an additional member of your household may have for the purpose of meeting your housing needs;
Where your personal information comes from
The information we hold about you, or your household, comes from:
- You – the information you provide in the housing application form or when you notify us of a change of circumstances;
- Family member or former partner, where this is needed to verify information included in the application;
- Your previous landlord – we request references in relation to previous tenancies which will include information about rechargeable repairs, outstanding debt and complaints of anti-social behaviour;
- The Health and Social Care Partnership’s Homelessness Service – where a homelessness referral is made on your behalf; and
- Social Work or other supporting agencies – where we require to verify information provided on your application form.
How we use information about you
We will use information about you to assess your housing need in order that we can allocate our homes effectively and in manner that is compatible with legislation applicable to social landlords. We only use your personal data when the law allows us to, under the UK GDPR the lawful bases we reply on for processing are that it is necessary to:
• process your application for housing, assess your housing requirements and enable you to bid for available properties;
• communicate with you regarding your application;
• enter into a contract with you (the tenancy agreement) and;
• for our legitimate interests.
We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|
Purpose |
Type of personal information |
Lawful basis |
|
Process your application for housing with us |
|
To take steps at your request prior to entering into a contract with you |
|
Assess your housing need |
|
To take steps at your request prior to entering into a contract with you Fulfilling our legal and regulatory obligations Public Task |
|
To communicate with you |
|
To take steps at your request prior to entering into a contract with you |
We also process your personal information in pursuit of our legitimate interests to:
- investigate and respond to any complaints or queries you may have;
- improving and developing the services we offer – we may on occasion ask your opinion of the service we provide and analyse any responses provided or information provided in the housing applications for this purpose;
- to monitor and review equality of opportunity; and facilitate any necessary legal proceedings.
In certain circumstances we may require to process or disclose your personal details in order to fulfil our legal or regulatory requirements.
If you do not provide us with all of the information that we require this may affect our ability to assess and process your Housing Application and ultimately affect our ability to enter into a tenancy agreement with you.
In certain circumstances we may require to process or disclose your personal details in order to fulfil our legal or regulatory requirements.
If you do not provide us with all of the information that we require this may affect our ability to assess and process your Housing Application and ultimately affect our ability to enter into a tenancy agreement with you.
Special Categories of Personal Information
We also process some special categories of personal information such as:
- Health related information for the purposes of assessing housing need;
- Relevant criminal conviction information including information related to sexual offences. We process this in order to make appropriate housing arrangements and to comply with our legal obligations as a social landlord; and
- Health, racial and ethnic origin data for the purposes of equalities monitoring – to identify and keep under review the existence or absence of equality of opportunity or treatment between groups of people and to promote or maintain equality.
Children’s information
We do not usually process children’s information as part of the housing application process, as all applicants are adults. However, we record children’s basic information if they are to be resident in one of our properties, including their name and date of birth. This is required for checking the property is not overcrowded and to assess other tenancy management issues where all householders and ages are required to be known.
We may at a later stage receive children’s information if we are involved in the housing and tenancy aspects of a welfare case as part of a multi-agency working solution.
Where we store your data
We store your information in the HomeConnection system – this is basically a large database, an electronic web-based information storage system. Information we receive from third parties is uploaded to the HomeConnections system is uploaded and stored against your individual application. It’s also possible that some information may be held in the email system.
Automated Decision Making
We do not take any decisions based solely on automated processing and we do not envisage this changing.
Who might we share your information with?
We share limited personal data with third parties for the purposes set out in this notice or purposes approved by you, including the following:
• Your information may be disclosed to software/ IT providers maintaining our systems.
• Where you have given us authority to, we will share information with someone acting on your behalf.
• Third parties where necessary to verify information you have included for consideration in your housing application;
• If we are conducting a survey of our products and/ or service, your information may be disclosed to third parties assisting in the compilation and analysis of the survey results;
• We may grant access to auditors, or the Scottish Housing Regulator as required;
• We may also share personal information with our professional and legal advisors for the purposes of taking advice.
Our contractors are required to comply with the law and our own Data Processing Agreement or Data Processing Clauses within our contracts to ensure data is managed appropriately and for specified purposes.
In some circumstances we are legally obliged to share information. We might also share information with regulatory bodies in order to further their, or our, objectives. For example:
• Auditors, solicitors, banks;
• Police Scotland, Local Authority departments, Scottish Fire & Rescue Service and others involved in any complaint we are investigating.
We will only share information where we are satisfied that we have a lawful basis under which to share the information.
In the event that we do share personal information with external third parties, we will only share such personal information strictly required for the specific purposes and take reasonable steps to ensure that recipients shall only process the disclosed personal information in accordance with those purposes.
How we manage your personal information
We process your information in accordance with data protection principles. We will keep your personal details for no longer than necessary. We are committed to keeping your personal details up to date and ask that you inform us about any changes to ensure the details we hold for you are accurate.
We will keep your data for as long as we have an active application for housing. We will contact you regularly, most likely annually, to ensure that you are still looking for a property. If we cannot contact you, or you indicate that you no longer want to be registered, we will withdraw your housing application and anonymise your data for reporting purposes.
Your data protection rights
Under data protection law, you have rights including:
Your right of access - You have the right to ask us for copies of your personal information.
Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
Please contact us at [email protected] if you wish to make a request.
You are not required to pay any charge for exercising your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances. If you make a request, we have one month to respond to you. Occasionally it could 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. Any requests received by River Clyde Homes will be considered under the applicable data protection legislation.
Our contact details
There are many ways you can contact us, including by phone, email, and post.
Our postal address:
River Clyde Homes
22 Pottery Street
Greenock
PA15 2UZ
Phone Number: 01475 788887
Email: [email protected]
If you have any concerns about our use of your personal information, you can make a complaint to us. We aim to resolve all queries or concerns internally but you do have the right to complain to the Information Commissioner’s Office at any time or to claim compensation, through the courts, if we misuse your information. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
The Information Commissioner’s Office – Scotland
Queen Elizabeth House
Sibbald Walk
Edinburgh
EH8 8FT
Telephone: 0303 123 1115
Email: [email protected]
Changes to this Privacy Notice
We keep this notice under regular review to make sure it is up to date. This version was last updated in April 2023. The latest full version is always available from our website at https://www.riverclydehomes.org.uk/