Privacy notice - tenants
Privacy notice to all tenants - Collecting and retaining personal information.
West Lothian Housing Partnership (WLHP) will be the 'data controllers' of the personal information that you provide to us about you as a tenant and about the people you live with. This information is required to maintain your tenancy with West Lothian Housing Partnership, as more fully described in this privacy notice.
WLHP forms part of Wheatley Group. The Registered Social Landlords within Wheatley Group include Glasgow Housing Association (GHA), Dunedin Canmore, Cube Housing Association, Loretto Housing, Barony Housing Association and Dumfries and Galloway Housing Partnership.
Our Data Protection Officer is Ranald Brown who can be contacted on #firstname.lastname@example.org.
What we need
The information we require from you, as our tenant, includes:
- your full name (and proof of your identity/photo ID)
- your date of birth
- your contact details (phone, email or correspondence address)
- details of anyone authorised to act on your behalf if applicable
- basic details (name and date of birth) of all household residents including any children
- your banking details if you pay your rent by Direct Debit
- proof of housing eligibility, any interest or equity in other property from 2019
- other personal information that will vary on a case by case basis to help us resolve breach of tenancy, alleged anti-social behaviour or fraud, rent arrears
- other details - next of kin details and employment details
- equality, disabilities or vulnerabilities. We use this information to tailor our service to better meet your particular circumstances and needs. We may use this information for safeguarding of staff
- financial information. We may use this to help customers make a decision around affordability and resolve any housing debt/arrears and provide welfare benefits, fuel and debt advice as a free service to help customers budget and pay bills. We may use this to apply for funding on a customer’s behalf
- your complaints history, and
- health information when we require this to make decisions on the property type customers may require and support funding for adaptations made to the property a customer is living in. More specific details are provided if you use this service.
The information we may collect from you includes:
- disabilities or vulnerabilities. We use this information to tailor our service to better meet your particular circumstances and needs. We may use this information for safeguarding of staff
- financial information. We may use this to help resolve arrears payments and optionally to provide welfare, benefits and debt advice as a free service to help you budget and pay your bills. We may use this to apply for funding on your behalf
- your national insurance number.
We collect your personal information from you via a variety of sources, including when you apply for one of our properties or services, complete one of our forms, when you call, write, email or meet with us or respond to a survey. We may collect information when you use our social media sites, websites or self-service portal ‘My WLHP’ when you apply to become a member.
Our landline phone calls to our Customer Service Centre and to our Group Debt Recovery Team are recorded for training and monitoring purposes and our recordings are usually held for a period of six months.
We operate a CCTV system at our office premises and at various locations within the vicinity of our properties for the detection and prevention of crime, to fulfil our legal obligations to keep our staff safe and in pursuit of our legitimate basis to keep our properties safe and secure. Our CCTV cameras operate continuously and recordings are held for one month.
From time to time we may operate CCTV/sound recording and/or use photography to capture evidence of breach of tenancy, alleged anti-social behaviour or crime.
If you are a tenant in a multi-storey flat, we may monitor use of any key fobs provided in pursuit of our legitimate basis to keep our properties safe and secure. This information is retained for four weeks,
We may also take photographs and video footage at events we organise or take part in, at our properties and in our communities to use for general marketing and publicity. However, photographs of individuals will only be used for those purposes with your consent.
We may transfer information about you to other Wheatley Group subsidiaries for purposes connected to your tenancy or the management of the company’s business.
We may receive information about you from third parties including but not restricted to:
- your local council or benefits office relating to your housing
- prior landlords agencies when you apply for housing
- the police, your GP/health workers and welfare or support organisations dealing with you
- solicitors, councillors, MPs or other representatives acting on your behalf/instruction, for example advocacy services, Shelter
- financial institutions when you apply for our services.
We do not usually process children’s information as part of as part of your tenancy, as all tenants are adults. However, we record children’s basic information if they are to be 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 at a later stage 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.
Why we need your personal information - Contractual purposes and legal obligation
We need to collect your personal information so that we can manage your tenancy. We will use your personal information to manage your tenancy and support you as a valued customer. This may include:
- receiving rent and service charges including arrears
- providing a repairs and maintenance service
- resolving anti-social behaviour disputes
- investigating complaints
- processing requests from third parties for example Council Tax
- monitoring and reporting performance to regulatory bodies
- issuing communications about your tenancy with us
- providing factoring services, if applicable and
- for any other purposes consistent with the proper performance of your tenancy agreement.
We are also under a legal obligation to process certain personal information relating to our tenants for the purposes of complying with our legal obligations under:
- Housing (Scotland) Acts 1987, 2001, 2006, 2010 and 2014
- Homelessness etc. (Scotland) Act 1987 and 2003
- Matrimonial Homes (Family Protection) (Scotland) Act 1981
- Antisocial Behaviour etc (Scotland) Act 2004
- Children Scotland Act 1995
- Children and Young People (Scotland) Act 2014
- Civil Partnership Act 2004
- Immigration and Asylum Act 1999 and Immigration Act 2014
- Protection from Harassment Act 1997
- Management of Offenders etc. (Scotland) Act 2005
- Freedom of Information (Scotland) Act 2002
- Data Protection Act 2018
- Environmental Information (Scotland) Regulations 2004
- General Data Protection Regulation (EU) 2016/679 (GDPR)
- Adult Support and Protection (Scotland) Act 2007
- Adults with Incapacity (Scotland) Act 2000.
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 with us.
Why we need your personal information – legitimate purposes
We also process your personal information in pursuit of our legitimate interests to:
- deliver our investment programme;
- pursue any debts owed to us;
- offer welfare benefits advice;
- offer support services to you and those living with you;
- provide education, employment and training advice and opportunities;
- target customers impacted by welfare reform;
- issue communications to you regarding housing services, including letters, newsletters, emails and texts;
- contact you by way of telephone, letter or text message to advise that you are in arrears of rent;
- provide you with outsourced services;
- write to a local authority and the DWP to advise of a change in rent charge for Housing Benefit and Universal Credit purposes;
- offer you access to our contents insurance scheme;
- keep our properties safe and secure by operating CCTV;
- prevent crime by sharing information with the Police;
- train staff and monitor quality of service by recording incoming calls to our Customer Service Centre (CSC) and Group Debt Recovery Team (GDRT);
- monitor use of any key fobs provided to tenants of multi-storey flats in order to keep our properties safe and secure;
- undertake research and statistical analysis to help improve our business processes and the services offered to our customers, as well as to evaluate our performance against other benchmarks. Where possible, statistical information is anonymised or pseudonymised;
- carry out customer segmentation research to allow us to help us better understand our customers’ characteristics and prioritise, tailor and target services to you;
- prevent crime by sharing information with the Police;
- train staff and monitor the quality of service by recording incoming calls;
- develop new products; and
- we may also conduct surveys regularly and periodically relating to our services in order to gauge satisfaction and make improvements based on feedback.
In order to pursue our legitimate interests we may process other personal information which we have collated through the management of our housing services.
We request that you provide your national insurance number in pursuit of our legitimate interest to future proof our services. You may choose not to provide this information to us.
Where we process your personal information in pursuit of our legitimate interests, you have the right to object to us using your personal information for the above purposes. If you wish to object to any of the above processing, please contact us on InformationRequests@wheatley-group.com If we agree and comply with your objection, this may affect our ability to undertake the tasks above for your benefit.
Why we need your personal information – Equality monitoring requirements
We are required to use your personal information relating to your health, racial or ethnic origin for equality monitoring purposes as required by government departments and agencies, Scottish Housing Regulator and auditors, with other organisations and agencies where we are legally allowed to do so.
We will process such personal information to identify and keep under review the existence or absence of equality of opportunity or treatment between groups of people within the same categories to promote or maintain equality within West Lothian Housing Partnership.
We offer a number of additional voluntary services to our tenants including organising community events, fire safety visits, providing debt advice and adapting the property you live in.
For these voluntary services, where your personal information is needed, we will always notify you about the service being offered, explain the service and obtain your consent to proceed, usually by way of a sign up/consent form for that service.
For the additional voluntary services, much of the information contained in our privacy notice is still relevant, such as details about the Data Controller and the rights you have under the legislation, including the right to withdraw your consent and the right to complain.
Other uses of your personal information
We may ask you if we can process your personal information for additional purposes. For example we may share your information with a language translation service if it is necessary to translate any information into or from a foreign language for you.
Where we do so, we will provide you with an additional privacy notice with information on how we will use your information for these additional purposes.
How we will communicate with you
As our tenant we need to communicate with you. This will usually be in writing or by telephone, but is more commonly becoming electronic and paperless. We are moving many of our services online as this is usually more convenient for you and more efficient for us. Our secure online tenant service is called ‘My WLHP’. You may also have the option of communicating with us by WebChat.
If you use the ‘My WLHP’ service it is important that you keep your password secure and do not share your ‘My account’ details with any other person. The privacy of your information, as with any online service, depends on you keeping your account username and password details to yourself, as well as setting a suitably complex password that cannot be guessed or calculated. In the case of a joint tenancy both parties have their own ‘My account’.
Our tenants receive our newsletters with information about what is going on within the organisation. These may be sent to you by post or email. We are required by our regulator to keep our tenants informed and to offer opportunities for involvement, but you may opt-out of receiving this by contacting email@example.com.
We will only discuss or communicate your tenancy details with those named on the agreement or those authorised (temporarily or permanently) by you.
How we protect your personal information
Your personal information is stored on our paper and IT filing systems which may be copied for testing, backup, archiving and disaster recovery purposes. Access to your information is limited to those who require it to provide services to you. All data is held within the European Union (EU).
If any of your personal information is transferred out with the European Union or the European Economic Area by any of our contractors we will ensure that there are adequate safeguards in place to protect your personal information in accordance with the General Data Protection Regulations and applicable UK Data Protection Legislation.
How long we keep your personal information
We will only keep your personal information for as long as necessary to provide you with housing and/or related services and to safeguard West Lothian Housing Partnership in the event of any claims, complaints, litigation, enquiries or investigations during or following the termination of your tenancy. Unless you ask us not to, we will review and possibly delete your personal information where your tenancy has been terminated for seven years.
We will keep certain personal information of members for longer in order to confirm how long you were a tenant. We need to do this to in the event of a claim against West Lothian Housing Partnership.
We have data retention schedules that set out the periods for retaining and reviewing all information that we hold. These set out different retention periods for all information we hold about your tenancy. You can find our retention schedules in our publication scheme. You can request a copy by contacting us at InformationRequests@wheatley-group.com
You can exercise any of the following rights by writing to us at InformationRequests@wheatley-group.com
Your rights in relation to your personal information are:
- you have a right to request access to the personal information that we hold about you by making a Subject Access Request
- if you believe that any of your personal information is inaccurate or incomplete, you have a right to request that we correct or complete your personal information
- you have a right to request that we restrict the processing of your personal information for specific purposes, and
- if you wish us to delete your personal information, you may request that we do so.
Any requests received by West Lothian Housing Partnership will be considered under applicable UK Data Protection Legislation. If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner's Office.
The accuracy of our information is important to us - please help us keep our records updated by informing us of any changes to your personal information
Changes to our privacy notice
Our privacy notice is regularly kept up to date and this version was updated in February 2020. The latest full version is always available from our website at www.wlhp.org.