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Keelman Homes Privacy Notice.

by Stuart Gibson & filed under Data Protection

This privacy notice tells you what to expect when Keelman Homes processes personal information. It applies to information about applicants, customers and other service users. Keelman Homes is the Data Controller of all personal information that you provide to us.

All references to Keelman Homes also refer to Gateshead Council for the purposes of its responsibility to provide housing management and maintenance services to Keelman Homes tenants in accordance with the management agreement between the two parties.

Keelman Homes also manages several properties on behalf of Thirteen Housing Group and this policy also tells you what to expect when their personal information is processed.

Why do we collect and store personal information?

We need to collect, process and store personal information about you and other household members to fulfil our obligations as a registered provider of social housing and to deliver efficient and effective services.

In order to access some of our services and for legislative purposes it may be necessary to collect your sensitive personal / special category information, which may include:

  • Gender
  • Race
  • Ethnicity
  • Physical or mental health needs
  • Income and outgoings
  • Bank details.

Sensitive information about health, sexual orientation, race and religion is subject to particularly stringent security and confidentiality measures.

In relation to data relating to criminal convictions, we are authorised by law (in accordance with the GDPR) to process criminal conviction data by relying on the Data Protection 2018 (Schedule 1, Part 3).

Information we may hold about you and how we use this

The information we hold on our records concerns our relationship with you. For example:

  • we hold names and dates of birth, photographic ID and information about your previous housing circumstances to assess housing applications – we will only hold this information as long as required to assess your housing need in line with our retention policies
  • we hold your contact details so we can communicate with you
  • we record information about your needs and requirements to ensure our services are accessible; that we take account of any support needs in our dealings with you; and to improve our communications with you. For example, if you are involved with a carer or social worker, if you need adaptations in your home, if you need large print or translated text
  • we record information to help us to deliver housing management services including reports of anti-social behaviour, complaints, change in circumstances
  • we keep financial records about the amount of money you have paid us; any amount(s) outstanding and associated recovery action
  • we may capture your image on our CCTV systems if you visit a local housing office or other facility which has CCTV cameras in operation
  • we carry out satisfaction surveys to help us to monitor our performance, to keep our records up to date and to improve our services to our customers. This information is store in-line with our retention policies.

This list is not exhaustive, as we hold records of most contacts we have with you, or about you, and we process this information so we can deliver services to you.

Our lawful basis for processing your information for the above purposes will be one of the following (Article 6 GDPR):

  1. Contract: for a contract we have with you, or because you have asked us to take specific steps before entering a contract
  2. Legal Obligation: for us to comply with the law (not including contractual obligations)
  3. Vital Interests: to protect someone’s life
  4. Legitimate interests: for our legitimate interests, or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests. Legitimate interests are those uses of personal data by a Data Controller that are deemed necessary or reasonably to be expected by a data subject.
  5. Consent: You have given clear consent for us to process your personal data for a specific purpose.

Generally the information we hold will have been provided by you (on application or enquiry forms or when we communicate with you), but we may also hold information provided by third parties where this is relevant to your housing circumstances, for example from social workers and health professionals.

We will only ask for personal information that is appropriate to enable us to deliver our services. In some cases, you can refuse to provide your details if you deem a request to be inappropriate. However, you should note that this may impact on our ability to provide some services to you if you refuse to provide information that stops us from doing so.

How we manage your personal information

Processing of your personal information will be undertaken in accordance with the principles of the General Data Protection Regulation 2018 (GDPR 2018). Access to personal information is restricted to authorised individuals on a strictly need to know basis. We will treat your personal information fairly and lawfully and we will ensure that information is:

  • processed for limited purposes
  • kept up-to-date, accurate, relevant and not excessive
  • not kept longer than is necessary
  • kept secure.

We are committed to keeping your personal details up-to-date, and we encourage you to inform us about any changes to ensure your details are accurate. To help us to ensure confidentiality of your personal information we may ask you security questions to confirm your identity when you call us or when we call you.

We will not discuss your personal information with anyone other than yourself, unless you have given us prior written authorisation to do so. Anyone calling on your behalf may also be subject to security questions to ensure we’re taking adequate steps to protect your personal information.

We may apply markers to your information held on our management system (for example, in relation to your vulnerability or health status) to enable us to tailor and deliver services to you. We only hold records during the period of our relationship and for a set period afterwards to allow us to meet our legal obligations, including resolving any follow up issues between us.

Sharing your personal information

Normally only our employees can see and process your personal information. However, there may be times when we need to share relevant information with third parties for the purposes as outlined below, or where we are legally required to do so.

When sharing personal information, we will comply with all aspects of the Data Protection Act 2018 and GDPR.

Where necessary or required, we may share personal information:

  • with our contractors to undertake some repairs, maintenance or improvement works
  • with third party service providers, in connection with services performed on our behalf, for example if we use a mailing company to distribute letters on our behalf
  • with market research companies to carry out customer satisfaction surveys to help to improve the services you receive
  • with other registered providers, trusts and landlords, in connection with tenancy references and associated enquiries
  • with Council Tax offices, to ensure billing details are correct
  • with utility companies to ensure correct billing can take place
  • with credit reference agencies and debt collection agencies, in connection with some housing applications and in relation to any outstanding charges
  • with appointed brokers to carry out affordability checks on Rent to Buy and Shared Ownership applicants
  • with local authorities and government departments as necessary for administering justice, or for exercising statutory, governmental, or other public functions
  • with police and other relevant authorities (eg Probation Service, Department of Work and Pensions, HM Revenues and Customs) in relation to the prevention or detection of crime and fraud; the apprehension or prosecution of offenders and the assessment or collection of tax or duty
  • with other statutory organisations, such as social services and health authorities, as necessary for exercising statutory functions
  • with the Regulator of Social Housing, to comply with our regulatory obligations
  • with CORE – COntinuous REcording of Lettings and Sales in Social Housing in England, The Ministry for Housing, Communities and local Government (MHCLG) collect data on social housing lettings and sales via CORE for statistical purposes.

This list is not exhaustive as there are other circumstances where we may also be required to share information, for example:

  • to meet our legal obligations
  • in connection with legal proceedings (or where we are instructed to do so by Court Order)
  • to protect the vital interests of an individual (in a life or death situation)

How long we will keep your information

We will only hold your records during the period of our relationship with you and for a set period afterwards to allow us to meet our legal obligations including resolving any follow up issues between us (for example if you live in one of our properties we will hold information about you for the duration of your tenancy. If you move and are no longer a resident, we will usually keep records about you for up to 12 years).

Your rights

Right of Access

You have the right of access to personal information we hold about or concerning you. This is called a subject access request. If you would like to exercise this right, please visit the Data Subject Access Request page.

We have a subject access request form which you can use for this purpose and we ask that your request is accompanied by proof of identity. If you are seeking to obtain specific information (e.g. about a particular matter or from a particular time period), it helps if you clarify the details of what you would like to receive in your written request.

If someone is requesting information on your behalf, they will need written confirmation from you to evidence your consent for us to release this and proof of ID (both yours and theirs).

We have 30 days to provide you with the information you’ve asked for (although we will try to provide this to you as promptly as possible).

In response to subject access requests we will provide you with a copy of the information we hold that relates to you. This will not generally include information about your property such as repair logs, details of contractor visits, or general property maintenance information as this is unlikely to be ‘personal information’.

Right of Rectification or Erasure

If you feel that any data that we hold about you is inaccurate you have the right to ask us to correct or rectify it. You also have a right to ask us to erase information about you where you can demonstrate that the data we hold is no longer needed by us, or you withdraw the consent upon which our processing is based, or you feel that we are unlawfully processing your data. Your right of rectification and erasure extends to anyone we have disclosed your personal information to and we will take all reasonable steps to inform those with whom we have shared your data about your request for erasure.

Right to Restriction of Processing

You have a right to request that we refrain from processing your data where you contest its accuracy, or the processing is unlawful and you have opposed its erasure, or where we don’t need to hold your data anymore but you want us to in order to establish, exercise or defend any legal claims, or we are in dispute about the legality of our processing of your personal data.

Right to Portability

You have a right to receive any personal data that you have provided to us in order to transfer it onto another data controller where the processing is based on consent and is carried out by automated means. This is called a data portability request.

Right to Object

You have a right to object to our processing of your personal data where the basis of the processing is our legitimate interests including but not limited to direct marketing and profiling.

Changes to this privacy notice

This Privacy Notice is kept under regular review and was last updated in April 2021.

Further information

For more details on how to request your personal information and how and why we process your information, please contact us:

  • by post: Data Protection Officer, Keelman Homes Limited, Civic Centre, Regent Street, Gateshead NE8 1JN
  • by phone: 0191 433 2106
  • email:  nataliebaldwin@gateshead.gov.uk

The Information Commissioner (ICO) is also a source of information about your data protection rights. The ICO is an independent official body and one of their primary functions is to administer the provisions of the General Data Protection Regulations.

You also have a right to lodge a complaint with the ICO about any aspect of how we are handling your data and can do so at:

  • Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
  • tel: 0303 123 1113
  • web: ico.org.uk