Southside Housing Association Fair Processing Notice
This notice explains what information we collect, when we collect it and how we use this. 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 are we?
Southside Housing Association (Reg. No. HCB186) is a Scottish Charity (Scottish Charity Number SCO36009), a registered society under the Co-operative and Community Benefit Societies Act 2014 with Registered Number 1694r(s) and having its Registered Office at 135 Fifty Pitches Road, Glasgow G51 4EB takes the issue of security and data protection very seriously and strictly adheres to guidelines published in the Data Protection Act 2018] and the United Kingdom General Data Protection Regulation (UKGDPR) as amended or replaced as required, together with any other domestic laws subsequently enacted.
We are notified as a Data Controller with the Office of the Information Commissioner under registration number Z6936072 and we are the data controller of any personal data that you provide to us.
Our Data Protection Officer is Desmond Phee (Corporate Compliance Officer).
Any questions relating to this notice and our privacy practices should be sent to the Data Protection Officer.
How to contact us
Telephone: 0141 422 1112
Email: CSD@southside-ha.co.uk
Address: Southside House, 135 Fifty Pitches Road, Glasgow, G51 4EB
Who we may collect personal data on
Customers – Current, and potential customers of SHA who live in our properties or access the services we provide, including tenants, service users and/or their representatives.
Other people – current, former, and potential colleagues, including volunteers, Governing Body members and shareholding members of SHA.
Anyone who makes an enquiry or a complaint, uses the SHA website and online services or visits our premises.
How we collect information from you and what information we collect
• when you apply for housing with us, become a tenant, request services/ repairs, enter into a factoring agreement with ourselves howsoever arising 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, apply for a vacancy, 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).
We may collect the following personal information about you:
• Your personal details: name, address, date of birth.
• Your contact details: home telephone number, mobile phone number and email address.
• Other details: including information about your gender, ethnicity, disability, and marital status.
• Any Medical information which may be necessary for the management of your tenancy or to adequately process your application for housing.
• National Insurance Number.
• Next of Kin.
• Tenancy details: start and end dates for any tenancy you may have had with SHA and records of any rent or service payments you have made.
• Information about the composition of your Household including details of existing accommodation arrangements and individual(s) who may seeking accommodation with an applicant.
• Details of any of your previous addresses in past five years.
• Payment details: your bank account details, any third-party payment details.
• Details of repairs requests that you have made including time and dates for access and when repairs have been completed.
• Details relating to purchase or ‘buy back’ of a property: including mortgage provider and solicitor details.
• Images: this may include photographs from events or images captured by CCTV
• Your IP address: when you access our website.
We may also record other information when you contact us or use any of the services that we provide. We may also record information about action we take e.g. in relation to anti-social behaviour so that we have an accurate record of what has happened.
Southside Housing Association will not collect any personal data for you that we do not need.
We also may receive the following information from third parties:
• Benefits information, including awards of Housing Benefit / Universal Credit
• Payments made by you to us; from third party payment sources such as AllPay.
• 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 to collect your personal data in order to allow us to effectively provide the housing or other services which you have requested from us.
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.
• Process applications for housing.
• Sign up new tenants.
• Ensure our rents are affordable and that your views have been considered.
• Respond effectively to our customers enquiries.
• Provide a high standard repairs and maintenance service.
• Deliver a high quality and value for money factoring service for homeowners.
• Manage payments from you and allow us to effectively manage your accounts.
• Assist in the recovery of debts or if necessary, court or other legal actions.
• Meet our legislative and regulatory obligations including providing our annual returns and other information to regulatory bodies.
• Contact you in order to send you details of any changes to our suppliers which may affect you.
• contact you for your views on our products and services including satisfaction surveys and consultations.
We also need and use your information for all other purposes consistent with the proper performance of our operations and business.
We have produced appendices to this Fair Processing Notice which sets out in more specific detail how we collect and use your personal data in relation to each SHA service area. These can be accessed at the Access to Information area of the SHA website.
Sharing of Your Information
As set out in this Fair Processing Notice, we may be required to share personal data with statutory or regulatory bodies or organisations in order to comply with legal and regulatory obligations. Such bodies include the Scottish Housing Regulator, The Care Inspectorate, Glasgow City Council, Glasgow Health and Social Care Partnership, Scottish and/or United Kingdom courts. We may also share personal data with our or your professional advisors for the purposes of taking advice and in the event of any legal claims.
Where we employ third party suppliers to provide services on our behalf, these suppliers may process personal data on our behalf as “processors” and are subject to written contractual conditions to only process that personal data under our instructions and protect it. In the event that we do share such personal data as is strictly required for the specific purposes and we will take reasonable steps to ensure that recipients shall only process the disclosed personal data in accordance with those purposes.
Where we enter into management agreements with another organisation, or dispose of properties to another organisation we may also share your data with them.
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
Your information will only be stored within the UK and EEA:
Where information is transferred outside the UK or EEA, we will ensure that there are adequate safeguards in place to protect your information in accordance with this notice.
Security
When you give us information, we take steps to make sure that your personal information is kept secure and safe.
Only SHA staff and partners and contractors who have signed data sharing agreements and who need to see your personal information will have access to it.
We will not usually retain your payment details unless you make payments to us using Direct Debit.
Our computer systems are located in our main office, however our staff may occasionally use laptops, tablet, or other devices offsite. In instances where devices are used remotely this will be secure and under strict control at all times in line with SHA’s IT Policy and Remote and Hybrid Working Policy which are both available on request. Additionally, we have the following controls in place to ensure the security of your personal information.
• All paper-based records are securely locked in storage cupboards when not actively being used.
• Our offices are protected by an alarm system, a security company and are monitored by CCTV.
• All SHA computer servers are within a secure network.
• All electronic communication takes place within this secure environment.
The unauthorised use of IT systems is prevented by:
• User ID
• Password assignment
• Lock screen with password activation
• Each authorised user has a private password known only to themselves.
• Regular prompts for password amendments
The following additional measures are taken to ensure the security of any Data:
• Network username
• Network password
• Application username
• Application password
• Application permissions and access restricted to those who require it.
• Multi-factor authentication required for any external access.
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.
We will generally keep your information for the periods set out in our Data Retention Periods Guidelines, after which this will be destroyed if it is no longer required for the reasons it was obtained.
Our full retention schedule is available on request or can be viewed on our website.
Your Rights
You have certain rights under Data Protection laws to ensure you remain in control of your personal data.
• Right of Access - You have the right to ask for a copy of the information about you held by us in our records.
• Right to Rectification – You have the right to have us correct any inaccuracies in your information where it is appropriate and correct for us to do so. We must respond within one month to any requests for rectification, which may be extended to two months where the rectification request is complex.
• Right to Erasure – You have the right to make a request to us to delete what personal data of yours we hold and process, where there is no compelling reason or legal basis for us to continue processing your data; and
• Right to Restrict Processing – You have the right to object to processing of your personal data under certain circumstances. When we restrict processing of your personal data, we are permitted to store the personal data, but not to process it further.
• Right to Data Portability – You may obtain and reuse your personal data for your own purposes across different services.
• Right to Object – You have the right to object to receiving any marketing communications from us, or processing which involves profiling.
If you would like to exercise any of your rights above, please contact us at:
CSD@southside-ha.co.uk
Complaints
If you have any concerns regarding how we handle your personal data, please contact our Data Protection Officer who will investigate your concerns in line with SHA’s complaints handling procedure.
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
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Email: casework@ico.org.uk
Maintaining Your InformationThe accuracy of your information is important to us - please help us keep our records updated by informing us of any changes to your email address and other contact details.