GDPR Fair Processing Notice

(How we use your personal information)

Introduction

This notice explains what information we collect, when we collect it and how we use it. During the course of our activities we will process personal data (which may be held on paper, electronically, or otherwise) about you and we recognise the need to treat it in an appropriate and lawful manner. The purpose of this notice is to make you aware of how we will handle your information.

Who we are

East Lothian Housing Association is a Scottish Charity (Scottish Charity Number  SC028900), a registered society under the Co-operative and Community Benefit Societies Act 2014 with Registered Number 2266R(S) and having our Registered Office at 18-20 Market Street, Haddington, EH41 3JL   (“We” or “us”).  We take the issue of security and data protection very seriously and strictly adhere to guidelines published in the General Data Protection Regulation (EU) 2016/679, together with any domestic laws subsequently enacted.

We are notified as a Data Controller with the Office of the Information Commissioner under registration number Z6072420 and we are the data controller of any personal data that you provide to us.

Our Data Protection Officer is Jackie Robinson, Service Manager, R3 Repairs Limited.

Any questions relating to this notice and our privacy practices should be sent to enquiries@elha.com to be considered by our Compliance Group.

How we collect information from you and what information we collect

We collect information about you:

  • When you apply for housing with us, become a tenant, request services or repairs, enter in to a factoring agreement with ourselves or otherwise provide us with your personal details
     
  • When you apply to become a member
     
  • From your use of our online services, whether to report any tenancy / factor related issues, make a complaint or otherwise
     
  • From your arrangements to make payment to us (such as bank details, payment card numbers, employment details, benefit entitlement and any other income and expenditure related information)
     
  • From social media such as Facebook

We collect the following information about you:

  • Name
     
  • Address
     
  • Telephone number
     
  •  Emergency Contact Details
     
  • E-mail address
     
  • National Insurance Number
     
  • Next of Kin and family members
     
  • Information about your health and that of family members
     
  • Information about your tenancy including any complaints made by or about you
     
  • Information about your employment, income and any benefits you receive

We receive the following information from third parties:

  • Benefits information, including awards of Housing Benefit and Universal Credit
     
  • Payments made by you to us
     
  • Complaints or other communications regarding behaviour or other alleged breaches of the terms of your contract with us, including information obtained from Police Scotland
     
  • Reports as to the conduct or condition of your tenancy, including references from previous tenancies, and complaints of anti-social behaviour 

Why we need this information about you and how it will be used

We need your information and will use your information:

  • To undertake and perform our obligations and duties to you in accordance with the terms of our contract with you
     
  • To enable us to supply you with the services and information which you have requested
     
  • To enable us to respond to any repair requests, housing applications and complaints made
     
  • To analyse the information we collect so that we can administer, support and improve and develop our business and the services we offer
     
  • To contact you in order to send you details of any changes to our products or services which may affect you
     
  • For all other purposes consistent with the proper performance of our operations and business
     
  • To contact you for your views on our products and services.

Sharing of Your Information

We may disclose your information to other third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:

  • If we enter into a joint venture with or merge with another business entity, your information may be disclosed to our new business partners or owners
     
  • If we instruct repair or maintenance works, your information may be disclosed to any contractor
     
  • If we are investigating a complaint, information may be disclosed to Police Scotland, Local Authority departments, Scottish Fire & Rescue Service and others involved in any complaint, whether investigating the complaint or otherwise
     
  • If we are updating tenancy details, your information may be disclosed to third parties (such as utility companies)
     
  • To  East Lothian Council in relation to:

 

  • Any application you may make for Housing Benefit

  • Council Tax - so that they can send your Council Tax Bill

  • Antisocial behaviour either by or against you

  • Re-housing Applications

  • ​Child protection (Social Work Department)

  • Adult protection (Social Work Department)

  • Tenancy Support

  • Criminal Justice

 

  • If we are investigating payments made or otherwise, your information may be disclosed to payment processors, East Lothian Council and the Department of Work & Pensions
     
  • To Payment Agencies such as your / our bank, and Allpay in connection with rent and other payments made to us
     
  • With Experion to enable rent payments to count towards your credit rating
     
  • If we are conducting a survey of our products and / or our service, sending information about our products and services, or are using our online help service, your information may be disclosed to third parties assisting in the compilation and analysis of the survey results, managing e-mail preferences, sending postal mailings or storing online chat records.
     
  • To Welfare Rights or advice services to enable them to offer you help
     
  • To Support providers so that we can help you access support you may need to maintain your tenancy
     
  • If we need to collect money owed to us (such as debt collectors)
     
  • In the event that we need to take action against you for breach of your tenancy agreement (such as our solicitor)
     
  • To other Landlords to provide tenancy references or when negotiating mutual exchanges or other re-housing options.

Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.

Transfers outside the UK and Europe

The Majority of personal information is stored on systems in the UK. Where information is transferred outside the UK or EEA we ensure that there are adequate safeguards in place to protect your information in accordance with this notice, including the following:

  • Survey Monkey
    Used to collect survey information
    Covered by the reciprocal EU-US ‘Privacy Shield’
     
  • Live Person
    Used for online chat records
    Covered by the reciprocal EU-US ‘Privacy Shield’
     
  • Mail Chimp
    Used to send e-mails to multiple addresses
    Covered by the reciprocal EU-US ‘Privacy Shield’

Security

When you give us information we take steps to make sure that your personal information is kept secure and safe. Further information can be found in our Privacy Policy.

How long we will keep your information

We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you.

Our full retention schedule can be obtained on request from our offices at 18-20 Market Street, Haddington, EH41 3JL.

Your Rights

You have the right at any time to:

  • Ask for a copy of the information about you held by us in our records (although most tenants can view all the data we hold in relation to their tenancy at any time by logging into their My Home account)
     
  • Require us to correct any inaccuracies in your information
     
  • Make a request to us to delete what personal data of yours we hold
     
  • Object to receiving any marketing communications from us

If you would like to exercise any of your rights above please contact us at 18-20 Market Street, Haddington, EH41 3JL

You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information.  The Information Commissioner’s contact details are noted below:

The Information Commissioner’s Office – Scotland

45 Melville Street, Edinburgh, EH3 7HL

Telephone: 0131 244 9001

Email: Scotland@ico.org.uk

The accuracy of your information is important to us - please help us keep our records updated either by informing us of any changes to your email address and other contact details or by correcting the information in your My Home account.

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