Trent & Dove Housing Limited is an Exempt Charity and a Registered Society under the Co-operative & Community Benefit Societies Act 2014 Soc. No. 30668R, HCA Reg. L4311.
‘We’, or ‘our’ refers to Trent & Dove Housing Limited and ‘our website’, ‘site’ or ‘the website’ refers to Trent & Dove Housing Limited’s website and sub-sites.
What this Privacy Notice covers, and who you can contact for more information:
Trent & Dove Housing Limited, which includes our commercial subsidiary, First Housing Limited, generates records from our contracts and contact with you. This Privacy Notice explains our approach to data protection and explains how our organisation collects, uses and protects the personal data you provide us with.
It is important that you notify us as soon as possible if there are any changes to your personal data, so we can keep our records up to date.
At all times, we comply with the requirements of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
We are registered as Data Controllers with the Data Protection Regulator, the Information Commissioner’s Office (ICO), and our ICO registration numbers are Z5498137 for Trent & Dove Housing Limited and ZA326179 for First Housing Limited.
You can contact our Data Protection Officer by telephone: 01283 528528 or by email: firstname.lastname@example.org.
We manage the East Staffordshire Housing Register on behalf of East Staffordshire Borough Council (‘ESBC’) and our Housing Partners. In this instance, ESBC are the Data Controller, and we have a formal contract in place with ESBC in order to collect and process the data on their behalf.
For further information see ESBC’s Privacy Notice: http://www.eaststaffsbc.gov.uk/privacy-notice.
How we collect Personal Data
We collect personal data belonging to our customers and the people who work for us in a variety of different ways including via:
- this website (see section 7 below, ‘Information we collect via this website’ and our Cookies policy
- on various forms that we may ask you to complete – these help us to gather the data that we need to sign you up to, and deliver, our services to you. Some examples include the online housing application form, a tenancy agreement, service contracts and employment contracts;
- our ongoing contact with you - and the data or information you provide us with to help us understand your requirements or personal situation so that we can provide a service or services to you. If you provide us with personal data relating to a member of your family, your friends or associates, we will assume that you have done so with their knowledge and their consent to us collecting and processing this information;
- CCTV images - we may process these for the purposes of resident or staff safety and security and for the prevention and detection of crime;
- recording calls to our customer helpline - all calls to and from our 01283 528528 main switchboard phone number are recorded for quality, training and legal compliance monitoring purposes; and
- references, or referrals from third-parties – for example, when you apply to become a Trent & Dove customer or member of staff we will request, and hold on file, any references that may be necessary to assess your application for housing or employment. For prospective tenants this includes (but is not limited to) references from other housing providers or private landlords, your mortgage lender (if you own or have owned your own home), the Police, the Probation Service, support workers, social workers, mental health workers and credit reference agencies.
Who the personal data we collect relates to
We collect personal information about:
- customers - this includes current, former and potential customers, who live in our properties or access our support and other services, and could also include their family and people associated with them;
- leaseholders and shared owners – this includes current, former and potential leaseholders and shared owners;
- Involved residents and volunteers – this includes current former and potential customers who would like to volunteer or to join a customer group;
- members of the public – and anyone who makes a complaint, submits an enquiry or volunteers with us;
- members of staff (our Colleagues) - this includes current, former, potential colleagues, apprentices and agency workers; and
- Board and Committee members – this includes current, former and potential board and committee members.
How we use personal data
The law allows us to collect, process, share and securely store personal information for the following reasons:
a. We need it to fulfil a contract we have with you - such as your housing application, tenancy, leasehold agreement, shared ownership, employment, or responding to an enquiry or complaint. In some situations, we also have a legal obligation. Examples of how we use your personal data include (but are not limited to):
- running a Housing Allocation system, which enables our prospective customers to bid on properties;
- making housing allocations;
- managing tenancies;
- managing leaseholders and shared owners;
- collecting rent and service charges;
- making sure bills and benefits are accurate and paid accordingly;
- providing a repairs and maintenance service;
- resolving Anti-Social Behaviour and Neighbour disputes;
- providing you with any information that you request from us;
- passing details of customers who may be facing homelessness through to Housing Options, the local authority housing advice and homeless prevention service;
- reporting safeguarding concerns;
- reporting criminal activity, engaging with law enforcement and statutory authorities;
- equality, diversity and inclusion;
- providing recruitment, employment and training support and opportunities, including operating a payroll and paying contractors;
- recruitment and appointment of board and committee members;
- managing employee performance and personal development; and
- filing statutory and regulatory returns.
b. It is necessary in order for us to pursue our legitimate interests - our legitimate interests are anything which is fair and reasonable for a Registered Provider of Social Housing to do. This includes:
- providing information on home ownership products to enable our customers to purchase their own home;
- offering our customers non-FCA regulated debt and benefits support;
- offering volunteering opportunities;
- offering our customers opportunities to take part in our tenant engagement and involvement groups;
- engaging with customers so we can track the performance of, and make improvements to, our products and services;
- promoting safety in, and quiet enjoyment of, our neighbourhoods and communities; and
- working with partners on projects and services which are designed to improve our products or services, to the benefit of our customers and staff.
How long we keep information
All information will be retained in accordance with statutory and sector best practice requirements and the retention periods for each type of data and document are set out in our Data Retention Schedule. Our Data Retention Schedule is based on the National Housing Federations Retention Guidance.
Special Categories of Personal Data
There are certain types of personal information which are classed as “special category data”. This is information relating to:
- Race or ethnic origin;
- Religious or philosophical beliefs;
- Political opinions;
- Trade union membership;
- Genetic & biometric data;
- Health information; and
- Sex life or sexual orientation.
When we collect Special Category data we will tell you:
- why we are collecting it;
- how we will use it; and
- include the details of who it could potentially be shared with.
At all times, all customers have the right to ask us which Special Category data we are processing about them, and why we are doing this.
We minimise our holding and use of Special Category data, however, given the services we provide, there are times when it is necessary.
We have a legal obligation:
- to comply with employment, social security or social protection law;
- when providing accommodation for people with disabilities;
- when resolving neighbourhood disputes involving alleged criminal activity or Anti-Social Behaviour;
- when helping someone to get access to care or support services; or
- the establishment, exercise or defence of legal claims, particularly those relating to safeguarding investigations or any legal action that we may take in Anti-Social Behaviour cases.
When it is necessary to help us protect a person’s vital interests:
- when that person is incapable of giving consent. This is sometimes the case in emergency or urgent safeguarding situations, when we need to make decisions relating to calling emergency services or agencies, or if we are assisting agencies who have statutory authority with emergency action.
Job applicants and our current and former colleagues
Personal information about unsuccessful job applicants will be held for 12 months after a recruitment exercise has finished. It will then be destroyed or deleted. We retain anonymised statistical information about applicants to help inform our recruitment activities, but no individuals are identifiable from that data.
Once a person has taken up employment with Trent & Dove, we will compile a file relating to their employment. The information contained in this file will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once their employment with Trent & Dove has ended, we will retain the file in accordance with the statutory requirements set out in our retention schedule and then delete it.
A separate privacy notice for prospective colleagues can be found on our recruitment page.
Complaints or enquiries
We try to meet the highest standards in all areas of our business. We take any complaints we receive very seriously and we welcome any suggestions for improving our procedures.
If you do make a complaint or enquiry we may collect and store personal information in relation to your complaint. We will keep it secure and use it only for the purpose it was collected.
When the matter is resolved or completed, we will retain the details in accordance with our retention schedule and then destroy them.
Information we collect via our website
We collect and store personal information for a number of reasons including to help us provide better services and products to customers and potential customers.
The information we collect via this website fits into two categories:
- Personal information entered into online forms by visitors to this website;
- Anonymous statistical information collected by Cookies. See the ‘Cookies’ page for more information.
If you request a brochure, call back or information from us via an email, online form or register your interest in a service we will use your information to fulfil that request.
How we use CCTV
Some of our properties and our offices have CCTV to prevent, detect and deter crime and anti-social behaviour and for safety and security by helping to identify and prosecute criminal offenders. We will clearly sign post all areas where CCTV cameras are present.
If you wish to request CCTV footage of yourself, this can be done by contacting our main switchboard on 01283 528528 or by emailing email@example.com. See also section 10 on ‘Your Rights’.
Sharing your information with third-parties
Your personal information will always be kept secure and confidential. Usually, we will not disclose personal data to third-parties without your knowledge or consent, however, there are occasions where we have to share information with contractors, agencies or others we work with, such as Local Authorities, Social Services, Police, the Government Department for Levelling Up, Housing and Communities (DLUHC) and other Registered Providers of social housing. If we do this, it will be because we have to do this to fulfil a contract we have with you, we are required by law or we have been legally advised to do so.
- Providing contact details to our contractors to carry out repairs, property improvements, quality assurance checks on the works carried out and safety checks to your home.
- Current or forwarding addresses may be shared with utility companies and Council Tax offices in line with legislation to ensure billing details are correct and any statutory monies owned can be collected.
- If you default on any tenancy/licence conditions, information about you that we hold may be provided to authorised debt recovery agencies, to enable them to recover monies owed to us. This may affect future applications for tenancies, credit and insurance.
- Trent & Dove will only refer a customer for debt or welfare benefit advice with their consent. Anyone who is referred to the CAB Advisor who works with Trent & Dove customers, the Advisor as part of Citizens Advice procedures will obtain from the customer authority to disclose information to any third party – local authority, creditor, etc.
- Towards the end of the financial year new rent figures are set for the forthcoming financial year. Of those customers who have a housing benefit claim and have requested direct payments to Trent & Dove, we will advise the local authority of the new weekly rent figure in respect of those particular tenancies.
- If any third-party request information regarding a customer e.g. Housing Options Team, Letting Agency, information will only be disclosed upon receipt of written authority from the tenant.
- We report information about our lettings and shared ownership sales via the CORE (Continuous Recording) system. This is so that the Government, DLUHC (Department for Levelling Up, Housing and Communities) can produce statistical information. This is necessary for the performance of a task in the public interest. The information provided does not include your name or full address but it does include information which is particularly sensitive. Please see the CORE Website for further details.
- We do not transfer any personal data belonging to customers, colleagues or third-parties outside the UK nor do we enter into any contracts with third parties who store personal data belonging to customers, colleagues or third-parties outside the UK.
You can read more about what your customer data access rights are and how you can exercise them in our Data Subject Rights Procedure.
Please contact us using your preferred contact method if you would like copies of specific information from your customer or colleague files, and we will provide this to you as quickly as possible.
The Data rights you legally have as a customer or colleague of Trent & Dove include:
- The right to be informed - about how we are using your data and what we are doing with it;
- The right of access - or the right to see the personal information we hold about you – this is known as a ‘Subject Access Request’ – more information about how you can make a Subject Access Request can be found below;
- The right to rectification – you have the right to ask us to correct data that we hold about you if you are able to provide proof that it is inaccurate, or that the data we hold should no longer be needed by us to fulfil a contract with, or provide services to, you;
- The right to erasure – you have the right to ask us to erase from our systems any data that we hold about you if you are able to provide proof that it is incorrect or that the data we hold should no longer be needed by us to fulfil a contract with, or provide services to, you;
- The right to restrict processing – you have the right to ask us not to process your data in certain ways, or limit the ways we use it, if you feel that it is being processed in a way that is not necessary in order for us to fulfil a contract with, or provide services to, you.
- The right to data portability – you have the right to ask us to provide a copy of data to you in a ‘portable’ format, which you can share with other agencies, companies or suppliers if you need to;
- The right to object – you have the right to object to us using or processing your data if you feel that it is being processed in a way that is not necessary in order for us to fulfil a contract with, or provide services to, you;
- Automated individual decision-making - you have the right not to be subject to a decision based solely on automated processing. You can request that a person makes the decision or ask for more information about how the decision was made. An automated decision process is used for people who do not have a complex housing need, as part of applying to join the East Staffordshire Housing Register, which we manage on behalf of the East Staffordshire Borough Council. For further reference, see link to ESBC’s Privacy Notice: http://www.eaststaffsbc.gov.uk/privacy-notice.
- The right to withdraw your consent to us processing your data – if we have directly asked for your consent to do something and you feel that the data you have provided is being processed in a way that is not necessary in order for us to fulfil a contract with, or provide services to you;
If you require a substantial amount of your personal information, there is a formal process for this in legislation, known as a Subject Access Request (SAR).
What you need to know about making a Subject Access Request:
- You can telephone, write or email us with your request. This can be done using any of the contact methods for Trent & Dove or you can email our Data Protection Officer directly: firstname.lastname@example.org.
- We may require proof of your identity and address – we will let you know this when we receive your request.
- When we receive your valid request – with proof of id/address if required- we will respond and provide your information within one month. Sometimes, a request can involve us needing to look at a large volume of data or information or gather this from various sources. If we feel your request cannot be carefully fulfilled within one month, legislation allows us to extend the time period for a response by a further two months – giving us three months in total to respond to you.
- You can request to see any of the information that we may hold about you, including CCTV images, but the more specific you can be about what you require, the quicker we can respond to your request. If you are requesting CCTV footage of yourself, please specify the time, date and location of the footage, and supply a clear photograph of yourself so that we can find you on the footage.
- Please be aware that you are only legally entitled to ask for, and be provided with, copies of information that is about you, and you alone. We may need to edit some information out – known as redacting – if the data you have asked for contains information about other people. This is because the law requires us to protect the privacy rights of all individuals.
Protecting your information
Trent & Dove employs a wide range of technical and organisational measures to protect your personal information and protect it from accidental or intentional loss, theft or criminal appropriation. These measures are regularly reviewed, checked and externally audited.
For network security reasons we are unable to publicly list the measures we have in place for our servers and computer networks, however, if you would like general information about the measures we take to robustly protect your data please feel free to contact us and we can review the reasons for your request.
This Privacy Notice
This Privacy Notice will be regularly reviewed and updated to reflect changes either to the way in which we operate or use personal data or changes to data protection legislation.
We welcome any queries you may have regarding this Privacy Notice, or any information we hold about you.
You can contact our Data Protection Officer via email on email@example.com for further information about our approach to personal data, or gaining access to any of the personal data that we hold about you.
Contacting the Information Commissioner’s Office (ICO)
If, at any time, you are not satisfied with our approach to personal data, or the way we process it, you have a legal right to approach the Data Protection Regulator, the Information Commissioner’s Office (or ICO) with your concerns.
You can obtain more information about the role of the ICO, and guidance about how UK businesses must process your personal data on the ICO’s website – www.ico.org.uk.
The ICO has a helpline you can call on 0303 123 1113. Their normal opening hours are Monday to Friday between 9am and 5pm (excluding bank holidays).
You can also:
email the ICO via their website https://ico.org.uk/make-a-complaint/ or use their live chat.
or write to them:
Information Commissioner's Office