Agamemnon Housing Association Ltd – Privacy Notice (Full)
1. Summary This Privacy Notice is a public document available to anyone and applies to the customers, tenants and trustees of the Agamemnon Housing Association Ltd to explain how the organisation collects and processes personal information in order to conduct normal business activities as a housing association. Agamemnon Housing Association Ltd is a Registered Provider (RP) regulated by Homes England (HE). Normal activities can be summarised as:
a. Providing social housing.
b. Property and grounds maintenance and repair.
c. Managing your housing, tenancy/lease and account as your landlord.
d. We also provide additional optional services including:
I. Help with organising and assisting community events.
II. Adaptations made to the properties we manage.
III. Additional Support for individuals identified to be in need of short-term assistance.
IIII. Managing staff, HR issues, payroll, and/or pension.
V. Trustees’ administration concerning Association business.
2. Who we are Agamemnon Housing Association Ltd is the Data Controller for its customers, tenants, staff and trustees. Their head office is located at Agamemnon House, Lindisfarne Close, Portsmouth. PO6 2SB. Tel: 023 92387086.
3. How we collect your information Agamemnon Housing Association Ltd collect information from you via a variety of sources, including when you apply for one of our properties, complete one of our forms, when you call, write, e-mail or meet with us, respond to a survey or apply to become a Trustee on the Board. We operate a CCTV system at each scheme for the detection and deterrence of crime, which operates continuously and recordings are held for 30 days.
From time to time we may operate CCTV/sound recording and/or use photography to capture evidence of breach of tenancy, alleged anti-social behaviour or crime. We may also take photographs at our events, at our properties and in our communities to use for general marketing and publicity. However, photographs of individuals will only be used for those purposes with their consent. We may receive information about you from third parties including:
a. Your council or benefits office relating to your housing.
b. Police, welfare or support organisations, dealing with you including information provided by NHS or Adult Social Care professionals with your agreement.
c. Councillors, MPs or other representatives acting on your behalf/instruction.
d. Family members (NOK or other with power of Attorney).
e. HMRC, Child Maintenance Services, Pension provider or other related services.
4. What information we collect about you The information we require from you includes, but is not limited to:
a. Full name (and proof of your identity/photo ID).
b. Date of birth.
c. National Insurance number (your unique identifier).
d. Contact details (phone, e-mail or correspondence address).
e. Details of next of kin and / or anyone authorised to act on your behalf if applicable.
f. Basic details (name and DOB) of all household residents.
g. Military service and dates of you or relevant relative.
h. Other personal information that will vary on a case by case basis to help us to provide you with support or resolve breach of tenancy, alleged anti-social behaviour or fraud.
The information we may collect from you includes disabilities or vulnerabilities. We use this information to tailor our service to better meet your particular circumstances and needs. We may use this information for safeguarding of staff. If you do not provide the information we need then we may not be able to provide all our services to you, and ultimately you may not be able to hold a tenancy with us.
5. What processing we do with information collected The information we require from you is used to manage your tenancy or governance with the Agamemnon Housing Association Ltd. Please read either your Tenancy Agreement or Trustees Handbook carefully for specific details as ‘performance of an Agreement’ is usually the legal basis for processing your information and carrying out our activities. The processing activities we conduct can be summarised as:
a. Managing your account charges and payments, including arrears.
b. Managing the repairs, maintenance and adaptations of our properties.
c. Managing the provision of our support service available for your use should it be required.
d. Ensuring tenancy (or contract) conditions are complied with, such as dealing with anti-social behaviour or fraud.
e. Complying with relevant legislation and regulation.
f. Agamemnon Housing Association Ltd conducts research and statistical analysis to help improve our business processes and the services offered to our customers, as well as to evaluate our performance against other benchmarks. When possible, statistical information is anonymised or pseudonymised.
g. Managing staff, payroll and pensions.
h. Trustees’ administration concerning the Agamemnon Housing Association Ltd.
Agamemnon Housing Association Ltd conducts surveys regularly and periodically relating to our services in order to gauge satisfaction and make improvements based on feedback.
Agamemnon Housing Association Ltd operates a range of information and communications systems and technologies for efficient operation of the business. Personal information is stored and managed within those systems, which are maintained to achieve a high level of Confidentiality, Integrity and Availability (CIA) including following best practice cyber security standards.
We hold information in IT systems which may be copied for testing, backup, archiving and disaster recovery purposes. All data is held within the UK.
6. Additional services Agamemnon Housing Association Ltd conducts a number of additional voluntary services including help with organising community events, adapting the property you live in and gathering information to improve our services. For these voluntary services, where your personal information is needed, we will always notify you about the service being offered, explain the service and obtain your consent to proceed, usually by way of a sign up/consent form for that service. For the additional voluntary services, much of the information contained in our Privacy Notice is still relevant, such as details about Agamemnon Housing Association Ltd as the Data Controller and the rights you have under the legislation, including the right to withdraw your consent and the right to complain.
7. Property information Much of the data we use relates to our properties and their maintenance and repair. We do not consider property information used in conjunction with the property address to be your personal information. For example, the age of the kitchen, results from a building survey, planning to replace windows or a repair to a tap. We are usually happy to provide you with answers to questions you may have about the property you are living in and work done to it. As soon as your name, contact details or other personal information is used in conjunction with property information, such as to complete a property repair visit, then this is treated as personal information.
8. How we will communicate with you
a. Tenants – Agamemnon Housing Association Ltd needs to communicate with tenants and this will usually be in writing, telephone, verbally during tenant meetings or via the electronic information screens. Our tenants receive a newsletter twice a year and an Annual Report with information about what is going on within the organisation. We are required by our regulator (HE) to keep our tenants informed and to offer opportunities for involvement. We will only discuss or communicate your tenancy with those named on the agreement or those authorised (temporarily or permanently) by you. You can authorise someone temporarily verbally over the phone or permanently in writing.
b. Trustees – Agamemnon Housing Association needs to communicate with trustees and this will usually be in writing, telephone, verbally during meetings or electronically via email.
9. Who we share data with and how long we keep information Agamemnon Housing Association Ltd share limited personal data with our contractors who are carrying out services on our behalf. Our contractors are required to comply with the law and our own Data Processing Agreement to ensure data is managed appropriately and for specified purposes, including to run our out-of-hours telephone service or to complete emergency, responsive or planned property repairs or manage and maintain our computer systems including data protection and backups.
a. Tenants – Agamemnon Housing Association Ltd may need to share personal information with Government departments and agencies, with our regulator and auditors, with utility companies or with other organisations and agencies where we are legally allowed to do so. Information relating to a tenancy will be kept for as long as the agreement is active or where money is owed on the account, and for a period not exceeding three years afterwards. The basic history of who held a tenancy at which property and when will be held indefinitely.
b. Trustees – Agamemnon Housing Association Ltd may need to share personal information with Government departments and agencies, with our regulator and auditors or with other organisations and agencies where we are legally allowed to do so. Information relating to trustees will be kept for a period not exceeding three years after they have left the Board of Trustees.
10. What we will not do We will not send you unsolicited marketing material or sell your personal data on to third parties. We will not pass on your personal data to unrelated third parties unless we are allowed or required to do so by law or we have your explicit permission to do that. We will not transfer or store your personal data outside of Europe (the European Economic Area) outside of the control of the UK/European regulations.
11. Your rights, the right to complain and the Information Commissioners Office (ICO) You have the right to request a copy of the data we hold about you. Please contact the office if you wish to request access to any of your personal data and we will always endeavour to answer your questions as part of our friendly, helpful service.
We will not normally make a charge for this service and will respond within one month of receiving your request. It will always help if you can be as specific about what personal data you want to see, what it relates to and within what timeframe, as that will assist our search. You have the right to correct information that we hold. Please advise us of any changes or corrections by contacting your scheme manager.
You may withdraw your consent to use any information that was previously provided with your consent. Please advise us if you wish to withdraw any consent previously given to the office. You also have other rights which can be seen by visiting the Information Commissioner’s Office (ICO) website and reading about Data Protection law at https://ico.org.uk/. You have the right to complain about any matter relating to our service, including how we use your personal data:
a. In the first instance please contact our office.
b. If you are still not happy with our service you may complain to the Housing Ombudsman Service at http://www.housing-ombudsman.org.uk/.
c. If you wish to complain about our use of your personal data you may complain to the UK ICO at https://ico.org.uk/.
12. Further information For further information about Agamemnon Housing Association Ltd, please see our website at http://www.agamemnonha.org
13. Changes to our Privacy Notice Our Privacy Notice is regularly kept up to date and this version was updated on 16th May 2018. The latest full version is always available from our website at http://www.agamemnonha.org
This notice will be amended after 25th May 2018 to remove reference to the UK DPA as it will be replaced by the UK Data Protection Bill and EU GDPR laws.