Lister – Privacy Notice / Fair Processing Notice
This notice explains what information we collect, when we collect it and how we use it. We will process personal data (held on paper, electronically or otherwise) about you and we need to treat it in an appropriate and lawful manner.
Lister Housing Co-operative is a fully mutual co-operative housing association registered with the Scottish Housing Regulator (HAC 150); and a registered society under the Co-operative and Community Benefit Societies Act 2014 (1876 RS) at 36 Lauriston Place, Edinburgh, EH3 9EZ. Lister (“we” or “us”) is committed to preserving your privacy. We are registered as a Data Controller with the Information Commissioner Office (no. Z616971X). Please read the following privacy notice to understand how we use and protect the information that you provide to us.
When we collect information about you
- When you apply for housing with us, become a tenant, become a member, request services/repairs or otherwise provide us with personal details.
- When you use our website or online services, enquire or report issues to us.
- When you arrange to make payments to us and discuss rent or benefit issues.
- When you complete surveys that we carry out although you do not have to respond to them.
- When you visit our office / use our premises.
What information we could collect about you
The type of personal information collected on the website could include your name, date of birth, company name, address, email address, telephone number(s) and IP address.
The type of personal information collected from tenants could include the above plus: next of kin & household details, maiden name, place of birth, national insurance number, support needs, medical/health issues, GP contact, vulnerabilities/risks, employment status, proof of ID inc. photo ID, bank details, credit/debit card details, criminal convictions/offences, ethnicity/nationality, language, housing benefit/universal credit notifications, images of your tenancy to evidence breaches or to assist repair works or to catalogue the characteristics of the property.
If you come to our office we have a CCTV system that records images at the front doorway and the entrance hallway continually. Voicemail messages to the office telephone may be stored.
Information we receive about you from third parties
- Benefits information including awards of Housing Benefit/Universal Credit
- Payments made by you to us (through financial processing arrangements)
- Complaints or other communications regarding behaviour or any 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, complaints of anti-social behaviour, referrals or enquiries from medical or health professionals.
Processing Personal Data
As an organisation we will process data in accordance with the following legal grounds:
Our Contract with you (as a tenant):
We need to process the data we hold on you in order that we comply with our obligations with you under the contract (tenancy agreement) we have with each other.
We are required to meet certain legal obligations as a landlord and organisation.
Processing is necessary for the performance of a task carried out in the public interest. An example of such a task is the allocation of social rented housing to those in need as defined in the housing and homelessness legislation.
We are also required to process your data in accordance with our legitimate interests which can occur, during and after our customer / tenant relationship.
Why we need this information and how it will be used:
- To undertake and perform our obligations and duties to you (if you are a tenant) in accordance with our contract with you – the Lister Scottish Secure Tenancy Agreement.
- To enable us to supply you with the services and information which you have requested and meet your specific needs.
- To enable us to respond to your repair request, housing application or complaints made to analyse the information we collect so that we can administer, support and improve and develop our business and the services we offer.
- To enable us to respond to your application for membership and communicate with you in relation to your membership of the Co-operative. To record your membership.
- To enable us to communicate with you and keep you informed about our services and our performance.
- To contact you in order to send you details of any changes to our services or supplies which may affect you.
- For completion of annual returns to regulatory bodies including the Scottish Housing Regulator and the Financial Conduct Authority (Mutual Societies section).
- For all other purposes consistent with the proper performance of our operations & business.
- We record CCTV video for the purposes of crime prevention and public safety.
- We record our office telephone voicemail so we can deal with enquiries received that way.
- To contact you for your views on our services.
- We may contact you by post, telephone, text or e-mail. If you change your mind about being contacted in the future by any of these means then please let us know.
Sharing of your information
The information you provide to us will be treated by us as confidential and will be processed only by our employees within the UK/EEA. We may disclose relevant information to other third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:
- When we instruct repair, maintenance or enhancement works, your information may be disclosed to any contractor/consultant.
- When we are investigating a complaint, information may be disclosed to Police Scotland, Local Authority departments, Scottish Fire & Rescue Service, the Scottish Public Services Ombudsman, the Scottish Housing Regulator, the Information Commissioner Office and others involved in any complaint, whether investigating the complaint or otherwise.
- When we are updating tenancy details, your information may be disclosed to third parties (such as utility companies and Local Authority).
- When we are organising or investigating payments made or otherwise, your information may be disclosed to payment processors, Local Authority, the Department of Work & Pensions.
- When we are conducting a survey of our services, your information may be disclosed to third parties assisting in the compilation and analysis of the survey results.
- The production of information for electronic distribution via our website or in hard copy format e.g. newsletters, annual reports, leaflets.
- If we have to take legal action against your tenancy or pursue you for tenancy related debt, your information will be disclosed to Sheriff Officers and/or Solicitors and the courts.
- If we feel that you would benefit from support or advisory services we would disclose your information to relevant agencies e.g. Mediation, Interpretation Services.
- For the purposes of crime prevention and/or the protection of vulnerable adults/children we would disclose your information to Police Scotland, Health & Social Care Services, Victim Support, Local Authority etc.
- We supply ethnic origin information in a anonymised statistical format to the Scottish Housing Regulator and in general reports produced by us.
- 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.
- Your information will only be stored within the UK and EEA.
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The information below explains the cookies we use and why.
WordPress sets cookies as part of its functionality.
Cookie: Universal Analytics (Google)
Name: _gat, _ga, _gid
These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in ananonymous form, including the number of visitors to the website,where visitors have come to the website from and the pages they visited.
Third Party Websites
We employ security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction or damage. We cannot guarantee the security of any information you disclose online and you do so at your own risk. Please help us keep our records updated by informing us of any changes to your e-mail address and other details.
This Privacy Notice will be updated from time to time to reflect changes either to the way in which we operate or changes to the data protection legislation. To make sure that you keep up to date, we suggest that you revisit this notice from time to time.
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. Your data will be destroyed after the retention period has passed if it is no longer required for the reasons it was obtained. CCTV images are scrubbed after one month automatically unless stored specially. Voicemail messages are not saved unless stored specifically. The full retention schedule is detailed within our Information Retention Policy which is available, free of charge from our office.
You have the right at any time to:
- Ask for a copy of the information about you held by us in our records.
- Require us to correct any inaccuracies in your information
- Make a request to us to delete what personal data of yours we hold.
If you would like to exercise any of your rights above, please contact us at email@example.com.
From 11 November 2019, Lister is deemed to be a Public Authority under the Freedom of Information (Scotland) Act 2002 therefore we must appoint a Data Protection Officer (DPO). Lister has engaged RGDP LLP to act as our DPO. To contact them please email: firstname.lastname@example.org Please also copy us in at: email@example.com
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 – Scotland, 45 Melville Street, Edinburgh, EH3 7HL Telephone: 0131 244 9001 Email: Scotland@ico.org.uk
If you have any queries concerning your personal information, or to correct any inaccuracies or any questions on our use of the information then please contact us at firstname.lastname@example.org or by sending us a letter to Lister Housing Co-operative Ltd, 36 Lauriston Place, Edinburgh, EH3 9EZ or by telephoning us on 0131 229 6176.
The accuracy of your information is important to us – please inform us of any changes to your telephone number, email address and other contact details.
(c) Lister Housing Co-operative Ltd 2019
Lister privacy notice reviewed 11 November 2019.