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Customer Privacy Notice
River Clyde Homes is committed to protecting the privacy and security of your personal information.
As a social landlord and property factor we require to process personal information to deliver our services.
This privacy notice describes how we collect and use personal information and your rights in relation to your personal information. It applies to housing applicants, tenants, owners of properties that we factor, and other service users.
We are registered as a data controller with the Information Commissioner.
Further information to help you
- Where does your personal information come from?
We collect information about you and your family directly from you, for example, when you:
- apply for housing with us;
- become a tenant;
- enter into a factoring agreement;
- report any tenancy or factor related issues; or
- apply to become a general member or join a customer involvement group.
We also receive the following information from third parties:
- benefits information, including awards of Housing Benefit/ Universal Credit;
- payments made by you via bank transfer, Allpay or any other method;
- complaints or other communications regarding behaviour or other 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, and complaints of anti-social behaviour; and
- information supplied by the local authority with regards to a homeless application.
- What Information do we hold about you?
We collect, store and use the following information about you and your household:
- date of birth;
- bank account details;
- National Insurance number;
- ethnicity, sexual orientation or religion – to monitor equal opportunities (if you choose to tell us);
- disability, medical or health information – for your personal plan if you live in sheltered housing or adaptations to your home;
- complaints or enquiries from you or made on your behalf by MPs, councillors or others at your request;
- payment records and affordability information;
- benefit information;
- photographs from events (if you don’t object to having your photograph taken);
- telephone number(s);
- email address;
- Home insurance details and claims history;
- record of repairs requested;
- customer satisfaction surveys;
- CCTV images and call recordings;
- information about anti-social behaviour or other breaches of your tenancy; and
- information relating to any legal cases for example rent arrears, disrepair claims and boundary disputes.
- How will we use information about you?
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information where it is necessary to:
- to enter into or perform the contract (tenancy agreement or factoring agreement) we have entered into with you (e.g. repairing your property);
- for our legitimate interests; and
- to meet our legal obligations (e.g. health and safety responsibilities).
There will be situations where we will seek your written consent such as when you ask us to provide you with digital inclusion support and financial wellbeing advice.
We may also use your information in the following, less common circumstances:
- to protect the vital interest of an individual (a life or death situation); and
- to perform a specific task in the public interest.
Our legitimate interests include:
- analysing the information we collect so that we can administer, support and improve and develop our business and the services we offer;
- to contact you for your views on our products and services;
- adapting the way in which we communicate with you to meet your needs and preferences;
- to provide you with or signpost you to additional support services;
- to monitor and review equality of opportunity;
- to promote our organisation and services;
- to contact in order to notify you of any changes that may affect you;
- manage payments for accounting purposes including issuing invoices;
- ensure rent is affordable and up to date;
- the prevention and detection of crime; and
- facilitate any necessary legal proceedings and adhere to statutory regulations.
- If you do not wish to provide your personal data
If you fail to provide us with certain information when requested we may be unable to enter into a tenancy agreement with you or administer the tenancy effectively and in some circumstance an occupant may not be able to exercise the right to succeed to the tenancy.
- Automated Decision Making
We do not take any decisions based solely on automated processing and we do not envisage this changing.
- Who might we share your information with?
We sometimes need to share your personal information with third parties for the purposes set out in this notice or purposes approved by you. This includes our suppliers who provide a service to you, or who provide services on our behalf. The data shared is the specific information the supplier requires to carry out their task, as well as any information that ensures we fulfil our health and safety obligations to the people carrying out the task.
These third parties include:
- our maintenance contractors and suppliers, in order to undertake repairs, maintenance or improvement works;
- insurance brokers;
- utility companies, when updating tenancy details;
- printing and mail distribution;
- auditors, solicitors, banks;
- third parties assisting in the compilation and analysis of the survey results if we are conducting a survey of our products or services;
- Police Scotland, Local Authority departments, Scottish Fire & Rescue Service and others involved in any complaint we are investigating;
- payment card, direct debit and billing solutions; and
- any other third parties as necessary to comply with our legal and statutory obligations with third party organisation.
- How we manage your personal information
We process your information in accordance with data protection principles.
We will keep your personal details for no longer than necessary. Once the information is no longer required for the lawful purpose for which it was obtained it will be destroyed.
We are committed to keeping your personal details up to date and ask that you inform us about any changes needed to ensure your details are accurate.
We may ask you security questions to confirm your identity when you call us. This is to help us to protect the confidentiality of your personal information.
- Your rights and how to contact us
The law gives you the following rights in relation to your personal information – the right to:
- be informed about what we do with your personal information (which is why we have published this Customer Privacy Notice);
- get a copy of the information we hold about you (this is known as a subject access request);
- ask us to correct information that is incorrect;
- stop us doing certain things with your information, for example when you think the information is incorrect;
- object to us using it for marketing;
- get us to delete your information in certain circumstances;
- get an electronic copy of your information so that you can send it to another company;
- object to the personal data we hold on you; and
- be informed of and object to any important decisions being taken about you automatically.
If you have any questions about this privacy notice or you would like to exercise any of the above rights, please contact us on DataProtection@riverclydehomes.org.uk , 0800 013 2196 or write to us at: Data Protection, River Clyde Homes, Roxburgh House, 102-112 Roxburgh Street, Greenock, PA15 4JT.
We aim to resolve all queries or concerns internally but you do have the right to complain to the Information Commissioner’s Office at any time or to claim compensation, through the courts, if we misuse your information.
The Information Commissioner’s Office – Scotland
45 Melville Street, Edinburgh, EH3 7HL
Telephone: 0131 244 9001
- Changes to this Privacy Notice
We keep this notice under regular review and will place any updates on our website; you will be notified of any major changes to this notice.