KIRKLEES COMMUNITY ASSOCIATION

PRIVACY POLICY

Introduction

At Kirklees Community Association (KCA) we take your privacy and the security of your information very seriously. This privacy statement sets out our approach to safeguarding the personal information we hold about you. It is important that you read this notice in full in order to understand what information we hold about you, how we use that information and your rights in relation to your data.

KCA is a Data Controller and is responsible for collecting, processing, storing and safe-keeping personal and sensitive information as part of our business activities. We manage personal information in accordance with the Data Protection Act, and is registered with the Information Commissioners Office (ICO), registration number ZA432818.

This notice sets out our approach to safeguarding the privacy and security of the personal information we hold. This approach applies to all personal information collected by KCA, our partners, and contractors acting on our behalf.

Our principal partners are Kirklees Neighbourhood Housing, Kirklees Metropolitan Council, Fusion Housing and Bramleys Estate Agents

Our main contractors are Pikelaw Project Management, Kirklees Neighbourhood Housing (Building Services) and N Cartwright (Administration).

This Privacy Notice is a public document available to anyone and applies to customers of KCA to explain how the organisation collects and processes personal information in order to conduct normal business activities, primarily as a housing provider.

Normal activities can be summarised as:

• Providing social and other types of housing.
• Property and grounds maintenance and repair.
• Managing your housing, tenancy/lease and account to provide housing management services.

We also provide additional optional services relating to education and leisure, including:

• Organising and assisting community events
• Offering opportunities to be involved in our services
• Providing access to welfare, benefits and debt advice
• Adaptations made to our properties
• Support our tenants with training and development
• Communality regeneration and improvement activities

About the personal information we collect

When we ask you for information we will:

• Tell you why we need it and how it will be used
• Collect only as much as we need to provide our services
• Take steps to ensure it is accurate and up-to-date
• Make sure we don't keep it longer than is necessary
• Keep it secure and confidential

In return we ask you to:

• Provide us with accurate information
• Tell us as soon as possible of any changes in your circumstances so we can ensure our records are accurate and up to date.

The type of information we will collect about you could include, but is not limited to:

• First Name and Surname
• Date of birth
• National Insurance number
• Address
• Postcode
• Contact details (telephone/mobile/email)
• Number, name and age of children
• Details of anyone authorised to act on your behalf if applicable
• Banking details if you pay your rent by Direct Debit
• Ethnicity
• Faith
• Details of convictions, proceedings and criminal acts
• Physical or mental health condition
• CCTV images

We will only collect information about you that we need and we will ensure that the personal and sensitive information we collect is updated to our systems in a timely and accurate manner.

We may apply markers to your information (for example, in relation to your vulnerability or health status) to enable us to tailor our service delivery to meet your needs.

We may receive information about you from third parties including:

• Your council or benefits office relating to your housing
• Prior landlords and credit agencies when you apply for housing
• Police, Council Departments, DWP, charities etc. providing support or welfare services to you
• Councillors, MPs or other representatives acting on your behalf / instruction

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 or lease with us.

The lawful basis on which we use this information

The law says that we have to meet a legal condition under the Data Protection Act 2018 before we can collect, process or share your personal data.

The conditions which usually apply for the personal data that we process for customers are:

• For the performance of a contract: for our landlord / tenant service

• To comply with a legal obligation: for example, to check your Right to Rent in the UK

• For our or your legitimate interests: this allows us to collect your name, contact details and other non-sensitive information and share it with our partners for our own administrative purposes or in line with our policies. This includes sharing your information with our partners.

The conditions that apply for processing sensitive information are:

• To make sure that we are providing equal opportunities: this is why we ask you for your ethnicity, whether you have a disability etc. You don’t have to tell us this information if you don’t want to, unless you want us to take it into account to provide a service to you or move you to a more suitable home.

• To protect your vital interests: for example if you have an accident or are taken ill, or if we believe that you or a member of your household might be in danger

How we use your personal information

We use your information to respond to your enquiries, provide you with services and manage your relationship with us. We may also use your personal information for technical administration, customer administration and to identify areas where we can improve the services we provide. We only collect or use personal and sensitive information for those purposes indicated in our registration with the Information Commissioner's Office.

We will regularly review the personal information we hold about you and make changes to any service or information-handling processes when the law or the Information Commissioner request such changes.


What processing we do with information collected

The information we collect from you is used to manage your tenancy or leasehold agreement or other contract between you and KCA. Please read your agreement/contract carefully for specific details as 'performance of a contract' is the legal basis for processing your information and carrying out our activities.

The processing activities we conduct can be summarised as:

• Managing your account charges and payments, including arrears.
• Managing the repairs, maintenance and adaptations of our properties.
• Ensuring tenancy (or contract) conditions are complied with, such as dealing with anti-social behaviour or fraud.
• Complying with relevant legislation and regulation.
• Commissioning support services on behalf of our tenants

KCA tenants may be contacted by our partners, who conduct research and statistical analysis to help improve their business processes and the services they offer. They also evaluate their performance against other benchmarks. When possible, statistical information is anonymised or pseudonymised, which means that no individual will be identifiable.

KCA 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 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.

Children's information

KCA does not normally process children's information as part of a tenancy, as all tenants are adults. However, we record children's basic information if they are resident in one of our properties, including their name and date of birth. This is required for checking the property is not overcrowded and to assess other tenancy management issues where all householders and ages are required to be known.

We may occasionally receive children's information if we are involved in the housing and tenancy aspects of a welfare case as part of a multi-agency working solution. In these cases we will not retain this information any longer than is necessary to following the resolution of the case.

Property information

Much of the data we use relates to our properties and specifically to 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 an asbestos survey, planning to replace windows or a repair to a tap.
When your name, contact details or other personal information is used in conjunction with property information, such as carrying out a property repair visit, then it will be treated as personal and sensitive information.

Visiting our website

When you visit our website, we collect standard internet log information for statistical purposes.

• We use cookies to collect information in an anonymous way, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
• We do not make any attempt to identify visitors to our websites. We do not associate information gathered from our sites with personally identifying information from any source.
• When we collect personal information, for example via an online form, we will explain what we intend to do with it.

Our website may contain links to third party websites. We are not responsible for the content or privacy practices of any external websites that can be accessed from our website. If you choose to visit a third party website, ensure that you familiarise yourself with their Privacy Policy.

How we share your personal information

We will not normally share your information without your consent unless we are required to by law. We may seek your consent directly, or may obtain it by telling you about how your information may be used at the time you provide information or enter into a contract (e.g. sign a tenancy or other agreement) with us.

Our legal obligations

We will share specific and relevant information with law enforcement and government agencies or public bodies where we are legally required to do so. Examples may include:

• The prevention or detection of crime and fraud
• The apprehension or prosecution of suspected offenders
• Sharing in connection with legal proceedings
• Sharing in relation to the health of an individual, where disclosure is required to protect them or others from serious harm
• Research and statistical purposes

We may also share your information with emergency services and local authorities, where this is necessary to help them respond to an emergency situation that affects you, for example a serious fire, gas leak or natural disaster.

Sharing information with others

As part of our normal course of business we may need to share information with a number of partners and agencies. In many instances this information sharing is governed by a legal requirement for us to share the information.

In some instances we may enter into partnerships with other organisations such as the local authority and the police. For example, we may join a partnership to help detect, prevent and control anti-social behaviour and criminal activity.

A list of the types of bodies we may share data with is listed below, this list is none-exhaustive:

• service providers and contractors
• healthcare, social and welfare organisations
• voluntary and charitable organisations
• business associates
• professional bodies
• local and central government departments and agencies
• Councillors, MPs or other representatives acting on your behalf / instruction
• housing associations and other landlords
• ombudsman and regulatory authorities
• press and the media
• partner agencies, approved organisations and individuals working with the police
• legal representatives
• courts and tribunals
• utility Companies
• debt collection agencies
• credit reference agencies
• current past and prospective employers

In order to protect your information, we will enter into data sharing agreement with partner organisations before any sharing takes place unless the sharing is required to meet a legal obligation.

Sharing information with our contractors and suppliers

There are some cases when we will share your information to support legitimate business purposes. We do this to ensure that we can meet your needs, and also to meet our health and safety obligations towards those delivering services on our behalf. This may include sharing information with our contractors and suppliers to enable them to carry out duties on our behalf or to meet contractual obligations we may have. For example, we may share information to enable our maintenance contractors to make appointments with you to carry out repairs and/or deliver services.

Keeping your information secure

In most cases we store personal and sensitive information electronically, however in exceptional circumstances it may be kept in paper form.
We implement a range of security policies, processes and technical security solutions to protect the personal and sensitive information we hold from:

• Unauthorised access
• Improper use or disclosure
• Unauthorised modification
• Unlawful destruction or accidental loss

When you contact us, we may ask you to provide us with some information so that we can confirm your identity. If other people (e.g. family members, support workers, solicitors) act on your behalf we will take steps to ensure that you have formally agreed for them to do so. This may include asking them to provide us with supporting information to indicate your consent. We do this to protect you and to make sure that other people cannot find things out about you that they are not entitled to know.

Employees and third parties who have access to, or are associated with the processing of, your personal information are obliged to make reasonable efforts to safeguard it.

How we use your telephone number

Contact via telephone provides the most effective way to communicate and share information with you about the services we deliver. You should ensure that the contact details we hold on you are up to date so we can be confident that messages come directly to you.

Operational SMS/Text Messaging and Calls

If you supply us with your telephone contact details, we may use them to call or send you operational text messages.

Examples of operational text messages include:

• Confirming a repair and/or a time and date for a repairs contractor to visit
• Confirming a home visit or property survey
• Sending a reminder about an appointment
• Asking you to contact a named person
• Satisfaction surveys

Sharing your telephone number with third parties

We may pass your telephone number to third parties so that we can meet our contractual obligations with you, for example to a contractor engaged to carry out maintenance or repairs. We may also share your telephone numbers if we are required to by law. In all cases the information will not be kept longer than is absolutely necessary.

We will never share or sell your telephone number to any telesales or marketing companies.

Telling us about changes to your personal information

You have the right to have inaccurate or outdated information amended, deleted or destroyed. We have a duty to ensure that your information is both accurate and up to date. If any of your details or circumstances change please let us know as soon as possible. You can contact us by telephone on 01484 416774 or write to us care of:

The Data Protection Officer, KCA, Civic Centre 3, Market Street, Huddersfield, HD1 2EY

Finding out what personal and sensitive information we hold about you

In accordance with the Data Protection Act 2018, we will provide details of the data we hold about you as soon as we can, and in most cases within 1 month of your request. In certain circumstances, for example in the case of particularly complex or multiple requests, it may take a further 2 months to provide an answer. In this is the case we will tell you within 1 month of your original request and explain why there’s a delay


If you want to know what personal and sensitive information we hold about you, you will need to submit a formal request in the form of a 'Subject Access Request'.

If you make a Subject Access Request we will provide you with a readable copy of the personal information we hold about you.

To make a Subject Access Request you must:

• Make your request in writing
• Provide proof of your identity
• Specify the information that you require

Please send your request to:

The Data Protection Officer, KCA, Civic Centre 3, Market Street, Huddersfield HD1 2EY

Contacting us

Please tell us if you have any concerns about the personal and sensitive information we hold about you, or how we use it, or If you want to contact us specifically about the privacy of your personal and sensitive information, please contact:

The Data Protection Officer, KCA, Civic Centre 3, Market Street, Huddersfield HD1 2EY

Keeping this policy updated

We keep our privacy policy under regular review. This privacy notice was last updated on 19 July 2018