What is the GDPR and the Data Protection Act?
The General Data Protection Regulation ((EU) 2016/679) (the “GDPR”) is EU legislation and the Data Protection Act 2018 is UK legislation which both apply as data protection laws in the UK and provide for the regulation of processing of personal information, including the obtaining, holding, use or disclosure of such information.
The GDPR and the Data Protection Act 2018 define a set of regulations and guidelines Lewisham Homes must follow when handling your personal information.
The purpose of this guide is to tell you how your information may be used Lewisham Homes.
How we use your Personal Data?
Personal data will be processed in accordance with the GDPR and the Data Protection Act 2018.
Except where we are sending you direct marketing, or in relation to resident involvement (see below), in accordance with the GDPR, we process your personal information as it is necessary for the performance of our services carried out in the public interest i.e. the provision of social housing.
This guide sets out how we use your information in the following circumstances:
- Your Tenancy
- Resident Involvement
- Marketing Communications
Who do we share your information with?
From time to time we may need to provide third parties with personal information relating to you or members of your household or obtain personal information relating to you or members of your household from third parties. However, this will only be so that we can accomplish the purposes described above.
We may disclose your personal details if required to do so by law or any Governmental body.
We try to deal with instances of rent arrears without the involvement of third parties. However, in cases of unresolved arrears and those where arrears remain outstanding after the termination of a tenancy agreement by either party, we may disclose personal details to tracing and/or debt collection agencies.
During your tenancy Lewisham Homes will collect and process information about you and members of your household for the following purposes:
- managing your tenancy
- managing your property
- monitoring compliance with the terms of your tenancy agreement
- delivering support for special needs to you or any member of your household within an agreed support plan
- conducting surveys in order to monitor and improve our services
- administering property grants
- providing associated welfare services, advice and support
- maintaining our accounts and records
- recruiting, supporting and managing our board, employees, agents and contractors
- promoting the services we provide
- carrying out surveys and conducting research
- local fraud initiatives
- corporate administration and all activities we are required to carry out as a data controller
- ensuring we meet our legal obligations as a housing provider
Unless we specifically advise you otherwise, we will only collect and process personal information that we need in order to carry out these functions.
We will collect the following personal information about you:
- Phone number
- Your marital status
- Whether you have any dependants
- National Insurance Number
- Homesearch application number (if applicable)
- In addition to the above:
- For an adult occupant: One photographic document e.g. passport, national identity card, provisional/full driving license; proof of national insurance number; legal documents if there has been a change of name.
- For a child occupant: Passport or full birth certificate; Child benefit letter.
If you do not provide us with the information required we will not be able to process your application for a tenancy or provide you with a property that meets your needs.
We also collect special categories of data and criminal conviction data
We collect information revealing racial or ethnic origin and religious beliefs and data concerning sexual orientation. This information is collected by Lewisham Homes for equality monitoring purposes and is necessary for keeping under review equality of opportunity. This information is collected in the Resident Profiling Questionnaire but you do not have to disclose this information if you do not wish to do so.
The Resident Profiling Questionnaire also asks for information about your health. You do not have to disclose this information but if you do, the information will allow Lewisham Homes to provide a service that meets your needs and the personal information is processed for social care purposes.
The processing of personal information revealing racial or ethnic origin and religious beliefs and data concerning health and sexual orientation is necessary for the performance of Lewisham Homes’ role as a housing provider and is carried out in the public interest.
Criminal conviction information is collected as part of the Lewisham Homes Procedure for Tenants sent to Prison. This allows Lewisham Homes to monitor housing benefit and to assess the tenancy, such as whether bail conditions exclude the tenant from the property or area. Criminal conviction data would also be collected if a tenant applied to Lewisham Homes for a friend or relative to be a caretaker of the property whilst the tenant is in prison. This information is processed because of Lewisham Homes’ role as an arms length management organisation to Lewisham Council which has a statutory function to provide social housing and handle housing benefit.
This personal information may be stored on our computer systems and/or a paper tenancy file. It is held securely and we have security measures in place to prevent it from being accessed by any unauthorised person. Lewisham Homes does not transfer your data outside of the European Union.
CCTV is installed on some of our estates, to monitor building security and crime prevention and detection. Lewisham Homes has some mobile CCTV, however the main estate based CCTV is operated by Lewisham Council for us and is stored by them.
We operate our CCTV in accordance with the guidance issued by the ICO. The GDPR and the Data Protection Act 2018 cover images of people and information about people derived from CCTV, for example a vehicle registration plate.
Lewisham Homes collects this data as part of its public function as a housing provider to ensure the health and safety of residents and its staff.
We will not hold images for longer than necessary and will dispose of them securely.
Lewisham Homes encourages residents to become involved in helping us to improve the services that we provide. Should you decide to be kept informed about community projects and ways to get involved you will be added to the resident involvement database.
To be added to this database, the following personal information will be collected from you:
- Phone Number
- Email Address
Information on that database will be kept separate from the main database and your personal information will be used specifically for this purpose.
Lewisham Homes may use this information to contact you and for consultation exercises. Lewisham Homes processes this information as part of its role as a public authority as resident involvement helps us to provide you with a better service as a housing provider.
To keep you up to date with the work of Lewisham Homes we may contact you from time to time by email and text and twice a year provide you with a copy of our magazine.
To provide you with the updates we process the following types of information:
- Phone Number
- Email address
Lewisham Homes processes your information in this circumstance because we have your consent to do so and you may withdraw your consent to marketing communications at any time. Please note however that Lewisham Homes may still continue to process your personal data for other purposes as set out above, to continue to provide you with social housing.
You can view your marketing preferences and update your settings at any time on My Lewisham Homes. Or, you can call us on 0800 028 2 028 to opt in or opt out of any method of marketing communication.
How long do you keep my Personal Data for?
All personal data is retained in line with the Lewisham Homes Records Retention Guidelines. As part of those Guidelines, the following applies:
- Current tenants’ Tenancy Files, including rent payment records, and details of any complaints and harassment cases, are retained for the length of the tenancy plus 6 years thereafter;
- Resident meeting minutes are retained for one year;
- Former tenants’ Tenancy Agreements, and details of their leaving are retained for 6 years;
- If you go on to purchase your property, documentation relating to your statutory right to purchase council housing is retained for 12 years after the sale of the property.
How can I apply to see the Personal Data you hold about me?
If you wish to see a copy of the personal data we hold about you then you can ask us at any time and we must respond with 1 month.
You will not have to pay a fee to access your personal information. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
You can apply by email to email@example.com
Or, in writing to Customer Relations, Lewisham Homes, Old Town Hall, London SE6 4RU
Other Data Protection Rights
Depending on the purpose for which we process your personal data, you have the right to:
- Request correction of the personal information that we hold about you.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
You can make a request in relation to any of the rights set out here by contacting the Data Protection Officer at the address or email address set out above.
If you wish to make a complaint about how we are processing your personal information you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO). You can find out how to contact the ICO on their website.
Data Protection Officer
Lewisham Homes has appointed a Data Protection Officer. If you have any questions about this guide then you can contact the Data Protection Officer at firstname.lastname@example.org
Changes to This Privacy Notice
Lewisham Homes reserves the right to update this privacy notice at any time, and we will notify you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.