Privacy and your Personal Information

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Introduction

This privacy statement explains how we collect and use your personal information and who we share it with.

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Who are we?

Rooftop Housing Association is a asset-holding, charitable Registered Society and Registered Provider of social housing and is a ‘controller’ under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

You can contact our data protection officer at:

Data Protection Officer, Rooftop Housing Group, 70 High Street, Evesham, Worcestershire, WR11 4YD

Email: dpo@rooftopgroup.org

Rooftop Housing Association provide homes and housing related support services in South Worcestershire and North Gloucestershire.

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What data will we collect

We will only collect information from you that is relevant to the matter we are dealing with. In particular, we may collect the following information from you which is defined as ‘personal data’:

• Personal details
• Family, welfare and social circumstances
• Financial details

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Special Categories

We may also collect information that is referred to as being in a ‘special category’. This could include:

• Physical or mental health details
• Racial or ethnic origin
• Religious beliefs or other beliefs of a similar nature
• Criminal convictions
• Sexual orientation

Because of its highly sensitive nature, we take extra precautions to safeguard this type of information

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Basis for processing personal data ‍

• It is necessary for the performance of a contract with you

Certain information is required to enter into a contract (tenancy agreement) with you and failure to provide this information may result in us being unable to offer a tenancy to you.

• It is necessary for us to comply with a legal obligation
• It is in our legitimate interests to do so
• You have given us your consent (this can be withdrawn at any time by advising our data protection officer)

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Legitimate interests

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests

For example:

• we may contact you to tell you about other services we provide that we think may interest or benefit you

You will always have a right to object to receiving further communications

• we need to share your contact details with our third-party service providers to enable them to provide requested services to you on our behalf

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Basis for processing special categories data

The basis on which we process your special categories data is one or more of the following:

• you have given us your consent (this can be withdrawn at any time by advising our data protection officer)
• it is necessary to protect your vital interests
• you have chosen to make the data public
• it is necessary for the establishment, exercise or defence of legal claims on your behalf
• it is necessary for reasons of substantial public interest

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How will we use your data?

We may use your information for the following purposes:

• Delivery of our tenancy related obligations and services, for example maintenance of your property, dealing with anti-social behaviour and resolving dissatisfaction or complaints with our services, providing money, benefits and welfare advice and making referrals with your consent to specialist support providers.
• Promotion of specific support, advice and other services to you where you have expressed you are open to further contact from us and signposting customers to support and advice services provided
• Collecting and processing payment of your rent & service charges which includes sharing former tenant forwarding addresses and contact details with debt collection agencies to help recover outstanding arrears from former tenants and utilities providers to ensure liability for any outstanding charges incurred during a tenancy is collected from those responsible
• Considering any vulnerabilities or needs of customers in making any tenancy management or enforcement decisions and making reasonable adjustments to how we deliver services

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Who will we share your information with?

We will only share information that is necessary, proportionate and relevant to our legitimate purposes or you have asked us to provide.

This may include:

• Reactive, cyclical and planned maintenance contractors
• Local authorities housing and benefit departments
• Adults and children’s safeguarding agencies
• Courts and local police and other law enforcement authorities
• Social and welfare organisations
• Other registered social landlords
• Our professional and legal advisors
• Utility companies and debt collection agencies
• Members of Parliament and other housing advocacy groups or statutory bodies who work on your behalf
• Information technology and other service providers who may collect, store and process your data on our behalf

Where you authorise us, we may also disclose your information to your family, associates or representatives.

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Who do we receive information from?

While providing housing related services to you we may receive information about you from:

• Local authorities housing and benefit departments
• Adults and children’s safeguarding agencies
• Local police and other law enforcement authorities
• Other registered social landlords
• Survey or research companies who work on our behalf

A full list of organisations that process your personal data is available from our Data Protection Officer on request.

Your information will be shared and held securely and be treated as confidential at all times.

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How long will we keep your information for?

• We will normally keep your information throughout the period of your tenancy, lease or our engagement with you and for a period of six years after, but this depends on the continuing need to process your data e.g. to establish or defend legal claims
• In some cases, we may retain your information for a longer period and will advise of you of this at the time and the lawful reasons for this.
• More information is set out in our data retention policy which is available on request from our Data Protection Officer

Transfers to third countries

• We may from time to time transfer your personal data to a country outside of the UK.
• Normally this will be necessary for the performance of your contract with us or for the exercise or defence of legal claims
• Sometimes we may transfer for other reasons and we will ensure the appropriate safeguards are in place at all times

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What rights do you have?

You have the following rights under the GDPR:

• Right to be informed
• Right of access
• Right to rectification
• Right to erasure
• Right to restriction of processing
• Right to data portability
• Right to object
• Rights concerning automated decision making and profiling

Further information about your rights is available on request from our Data Protection Officer.

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Right of access

• You have a right to see the information we hold about you
• You can contact anyone at Rooftop to request this by any means i.e. verbally or in writing; sometimes we may require proof of identity to ensure we are not inappropriately disclosing your information
• We will acknowledge your request and usually process your request free of charge within 30 days, but have the right to charge a reasonable administration fee and to extend the period of time by a further two months if the request is manifestly unfounded or excessive and/or is very complex
• We will disclose to you all the personal data that we hold about you but please be aware that sometimes exemptions may apply
• To further discuss your right of access please contact our Data Protection Officer

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Right to erasure

• You have the right to ask us to erase your personal data in certain cases
• We will deal with your request free of charge and within 30 days but have the right to refuse to erase information that we are required to retain by law or regulation, or that is required to exercise or defend legal claims or is covered by an exemption under the Data Protection Act. We can also refuse to comply with a request if it is manifestly unfounded or excessive.
• To exercise your right to erasure please contact our Data Protection Officer

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Who can you complain to?

• If you are unhappy about how we are using your information or how we have responded to your request then initially you should contact our Data Protection Officer.
• If your complaint remains unresolved then you can contact the Information Commissioner’s Office, details available at https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/