The General Data Protection Regulation (GDPR) came into force in May 2018. This notice sets out how we use personal information about service users of Self Help Community Housing Association Ltd.
Please see the section ‘Collection of your information’ for the type of information we hold about you, and ‘How we use your information’ for the reasons for which we use your information. We are committed to protecting your information and acting in accordance with your rights under data protection law.
1. Collection of your information
- We collect and process your basic identification information such as your name, date of birth, title, passport number and other reference numbers such Housing benefit, National insurance numbers.
- We collect sensitive information about gender identity, ethnicity and other protected characteristics to ensure that our services are appropriate to each individuals needs and so we can check that no discrimination is occurring in access to our services.
- Because our services are conditional upon service users having specific needs, we have to check that you are eligible to receive our services and that our services are appropriate to your needs. This means that we must collect sensitive information about you such as your housing history, legal status, health, offending history and substance misuse.
- Much of this information will be supplied by you directly but we will also routinely receive information about you from a variety of other sources including; other service providers you may have worked with, the local council, health professionals or by other third parties who hold relevant information. This will happen when you apply for supported housing, at the subsequent needs assessment and during the time when you are using receiving services.
- During your time as a service user we may also receive information from neighbors, friends and family in the context of complaints, concerns and personal crisis. Information of this kind is considered essential as it may be needed in a legally or contractually as evidence.
- As a condition of receiving our service – we require you to sign a permission to share form which allows us to request for information about you from other agencies. This sort of permission may be used to verify your medical details, or that you are engaging with other specialist support or to help us to progress your housing benefit claim or to help us access other services on your behalf. You have the right to withdraw this permission at any time but it is important to understand that this may impact upon your eligibility to receive our services.
2. How we use your information
We use your information for the following purposes:
- to deliver our services safely, fairly and effectively.
- to help us to manage our relationship with you and other service providers that you use.
- to help us deal with enquiries, complaints and reports.
- to help us advocate on your behalf to ensure that you are receiving appropriate services from third parties.
- to make sure you that are eligible to receive our services and that they are appropriate to your needs.
- for general administration of the service including: your rent account, reviews, statistical and reference purposes; and for other checks or administrative activities that may become necessary from time to time.
- for meeting our on-going legal obligations and investigating or preventing crime;
- for maintaining health and safety and managing risk.
- to carry out performance reviews, satisfaction surveys and other surveys.
3. Legal Basis for Processing your Information
Under the new data protection regulations that came into effect in May 2018 we are required to inform all of our service users of the legal basis for processing your information. Our use of your information is permitted by applicable data protection law because it is necessary in order to:
- Fulfill and maintain our contract with you to provide housing and support. We have a contract to provide you with Supported Housing – this is your tenancy or license agreement.
- Fulfill and maintain contracts with Bristol City Council and their partners who have commissioned the support services that you receive.
- Meet our legal or regulatory responsibilities, including when we make the disclosures to authorities, regulators or government bodies.
- Fulfill health and safety responsibilities to our staff, contractors, service users and members of the general public.
- On the basis of our legitimate interest to provide you with support, housing and property maintenance services and to communicate effectively with service users, partners and contractors.
4. Disclosures of your information
We share information with the following recipients:
- The Salvation Army, Second Step, Places for People, LivWest & Elim Housing and other service providers as part of the Men’s Homeless Pathway 1.
- Past, current and future specialist support and agencies such as Bristol Drugs Project, ARA, Missing Link, Second Step.
- Past, current and future landlords including local councils, housing associations and private landlords.
- Medical and social agencies such as Social Services, NHS clinicians, your GP, etc.
- Various agencies such as the Department of Work and Pensions, Bristol City Council in respect of your benefits and rent account.
- The police, the courts, prison and probation service.
- Other Statutory agencies who have a legal right to receive information (e.g. Child Support Agency, Security services, etc.).
- Our professional advisers to obtain legal and medical advice.
- Other providers of services to us, including printing, communication, IT and hosting, debt recovery, archiving and marketing providers.
- Public authorities, regulators or government bodies, including when required by law or regulation, under a code of practice or conduct, or when these authorities or bodies require us to do so.
- Other persons from time to time when the disclosure is needed to fulfill, exercise or protect legal rights, including those of our Management Board or other stakeholders, or in response to requests from individuals or their representatives who seek to protect their legal rights or such rights of others.
When we share or request information we take steps to ensure that the recipients meet our data security standards, so that your information remains secure.
Under no circumstances will we sell your information or knowingly divulge any information about you unless it is to the recipients listed above and for the reasons explained in Section 2 how we use your Information.
5. Transfers of your information abroad
The use and disclosure of your information does not involves transferring your personal information outside of the European Economic Area.
6. Retention of your information
We have a data retention policy which ensures that we keep your information only as long as we need to in order to meet our legal, regulatory or contractual responsibilities.
7. Your rights
- You have rights under data protection law of access to, and rectification or erasure of, your personal information, and to restrict its processing.
- You will not normally be charged for an initial Subject Access Requests (SAR) providing the request is reasonable and proportionate. In such cases we will provide you with the data we hold within 40 working days. The Association reserves the right to charge you for subsequent or unreasonable requests and refuse requests where no systems exist to extract the data.
- You also have the right to object to the processing of your information in some circumstances, and to tell us that you do not wish to receive marketing information.
- You can exercise any of these rights by contacting our data protection officer (contact details set out below).
- You also have the right to withdraw your consent to the use of your information, to the extent such use is based on your consent. You can notify us of your withdrawal of consent by contacting us at the details set out below.
- You can also lodge a complaint about our processing of your personal information with the office of the Information Commissioner - www.ico.org.uk.
8. Visitors to our website:
9. CCTV Cameras:
CCTV Cameras are used in a variety of locations. Handling of these cameras is covered by the ICO’s CCTV Code of Practice and The Surveillance Camera Code of Practice.
10. Photographs on publications and our website
Photographs on publications and our website: Occasionally we may place pictures of our properties and service users on our website. However, we would only identify you specifically in pictures with your permission. Group photos at events may also be taken and placed in our newsletters, press releases or on our website. If you do not want your photo to appear in group photos then please advise the person taking the photographs, or contact our office to ask for the photo to be removed from display.
11. Status of this privacy notice
This privacy notice was updated in August 2022. It is a notice explaining what Self Help Community Housing Association Ltd does with your information but it is not a document that binds the Association or any other party contractually.
We reserve the right to amend this notice from time to time, and will take appropriate steps to bring any such amendments to your attention.
12. Contact information, and exercising your rights
If you wish to exercise your rights described under heading 7 above, or if you have any questions about our use of information or this document, please contact:
Data Protection Officer
Self Help Community Housing Association Ltd
12 King Square Avenue, Bristol BS2 8HU