Privacy Policy: Scotland

Do you know what personal information is?

Personal information can be anything that identifies and relates to a living person. This can include information that when put together with other information can then identify a person.

Information we may collect about you may include (but is not limited to):

• Name
• Address
• Telephone numbers
• Email addresses
• Data of birth
• National insurance number
• Bank details
• Employment details
• Communication formats
• Identification Documents
• Income and expenditure
• Next of kin details
• Health data
• Criminal data
• CCTV images
• Computer IP address
• Service needs and preferences
• Benefit Entitlement
• Photographs
• Your information on social media

We may also collect personal information from others with whom you live or receive service from us – this may include:

• Family and household members
• Friends and visitors
• Members of public
• Representatives
• Enquirers

Did you know that some of your personal information might be classified as ‘special’?

Some information is ‘special’ and needs more protection due to its sensitivity. It’s often information you would not want widely known and is very personal to you. This is likely to include anything that can reveal information relating to your:

• Sexuality and sexual health
• Religious or philosophical beliefs
• Ethnicity
• Physical or mental health
• Trade union membership
• Political opinion
• Genetic/biometric data

We will only collect this type of information if it is necessary to your contract so that we can provide the right services to you.

We may at times need to share this information we will only do this if we have your consent or if there are legal requirements for us to do so. We may receive information about you from other data controllers, such as to the police who might tell us about a crime they are investigating where this impacts on your contract with us or those who live in the same community. If you give us this information about yourself when communicating with us, you do so because you consider it forms part of a legitimate interest for us to hold this information on our records.

If we ask for any sensitive personal data about you, we will always tell you why we need it and ask for your consent to hold it.

We may need to use some information about you to:

• deliver services and support to you;
• manage those services we provide to you;
• service improvement
• prevention/detection of crime/fraud
• help investigate any complaints you have about your services;
• check the quality of services;
• to help with research and planning of new services.

How the law allows us to use your personal information

There are a number of legal reasons why we need to collect and use your personal information.

Generally, we collect and use personal information for the purposes of where:

• you are entering or have entered into a contract with us
• you, or your legal representative, have given consent
• it is necessary to protect someone in an emergency
• it is required by law
• you have made your information publicly available
• it is necessary for legal cases
• it is necessary for archiving, research, or statistical purposes
• it is in both ours and your legitimate interest to use your data.

Where we can, we’ll only collect and use personal information if we need it to deliver a service or meet a requirement.

If we don’t need personal information we’ll either keep you anonymous if we already have it for something else or we won’t ask you for it. For example in a survey we may not need your contact details so we’ll only collect your survey responses.

If we use your personal information for research and analysis, we’ll keep you anonymous or use a different name unless you’ve agreed that your personal information can be used for that research.

We won’t sell your personal information to anyone else.

We may share your information with other companies within our group, we will always ask for your consent to do this and you can ask us to stop at any time.

We will always provide an option for updating your marketing preferences on our communications with you.

Text messages and contact via telephone or email provide a direct way to contact and share information with you about the services we can deliver to you. It can also help you receive important messages about your tenancy or which may interest or a help to you such as new online services.

If you provide your telephone number or email address we may keep in contact with you by these methods.

Operational SMS/text/email messaging and calls

If you supply us with your telephone or email contact details, we may use them to call or send you operational text messages.

Examples of operational text messages include:

• Confirming a repair and/or a time and date for a repairs contractor to visit
• Confirming a home visit
• Rent Account updates, arrears actions
• Sending a reminder about an appointment
• Asking you to contact a named person or department
• Satisfaction surveys
• Checking that we have the correct contact details for you.

Sharing your telephone number with third parties

We may pass your telephone number to third parties so that we can meet our contractual obligations with you. We may also share your telephone numbers if we are required to by law.

We may supply the details to our approved third party contractors who are delivering or performing services on our behalf, and these companies must not use your information for any other purpose. We never share or sell your telephone numbers to telesales/marketing companies.

Communicating with you

We may monitor or record calls, emails, text messages or other communications in accordance with applicable laws for the purposes of improving our service to you.

We use a range of organisations to either store personal information or help deliver our services to you. Where we have these arrangements there is always an agreement in in place to make sure that the organisation complies with data protection law.

We may enter into partnerships with other organisations such as local authorities and the police. For example, we may join a partnership to help prevent and control anti-social behaviour. In order to protect your information, we will enter into a legally binding data sharing agreement with partner organisations before any sharing takes place. It is not always possible for us to tell you that personal information is being shared, for example when we are working with the police or other agencies to help the investigation or detection of a crime as to do so may prejudice that investigation.

We are likely to share your personal information with the following:

• Property Services and Repairs

Contractors and third supply chain service providers for the purposes of carrying out property related inspections and repairs. Generally we will only share your name, the property address and your contact details so that they can arrange an appointment with you. In some cases we may also share customer service information with them, for example where you have told us that you need longer to answer your door. We may also need to share information where we have recorded there is a potential risk to operatives or other representatives. We will tell you what we record about you and we have a review process in place.

• Local Authorities

We will share your personal information with local authorities usually for the purposes of providing services processed by that local authority such as Universal Credit purposes.

We may also share information with local authorities for the purpose of investigating tenancy fraud or other types of fraud or criminal investigations. You will not have a right be told about this type of sharing because to do so may affect those investigations we will take steps to protect your information and only share what is necessary for those investigations.

• Insurance

We may share your personal information with our insurers in the case of a public liability claim. We will only share data specifically related to the claim. Our Insurers will provide you or make available to you the Privacy Notice that is linked to our insurance policy.

• Government departments

We may share your personal data with the DWP for the purpose of assisting you with your benefit claims including UC and for the purposes of recovering outstanding debts owed to us.

• CCTV

We use CCTV systems in some locations. CCTV is installed for the purpose of preventing and detecting crime.

• Social Alarms Provider

We share your personal data with our social alarms company for those who receive this service for the purpose of them providing emergency backup. We only share the data that you have specifically provided for this purpose and it is shared via secure data transfer

• Mail out companies

We may share your name and address with external mail out companies who we have appointed to assist us with mail distribution

• Police

• Safeguarding, Support Agencies and Charities

We may share your personal information with these organisations where we suspect there may be safeguarding or welfare concerns. We will usually try to gain your consent in advance, but we may make a safeguarding referral without consent in situations where we feel there is a significant risk.

• Utility companies and local authorities

We may need to share your personal information with energy management companies, utility companies [gas, electric, water] and local authorities for the purpose of ensuring utility services and council tax to the property are correctly charged and supplied. We may pass on your details after you have left us if there are arrears with a utility or local authority for services received.

• Debt Recovery Agents

We may share your personal information with debt recovery agents for the purposes of recovering any outstanding charges owed to us.

• Legal Services and Partners

We may share your personal information with our legal services or solicitors if we are preparing or defending a legal claim.

• Places for People Group companies

We may share your information with shared service functions within the Places for People Group, such as for the purpose of financial transaction when making payments to us or the Insurance functions if you make a claim. Places for People Group shared services comply with and process personal information within the same privacy standards and procedures.

Where there is a high risk to your personal information we will complete a privacy assessment before we share personal information to make sure we protect privacy and comply with the law.

Sometimes we have a legal duty to provide personal information to other organisations, this is often because we need to give that data to the police, courts, local authorities or government bodies.

We may also share your personal information when we feel there’s a good reason that’s more important than protecting your privacy. This doesn’t happen often, but we may share your information:

• in order to detect and prevent a crime and fraud; or
• if there are serious risks to the public, our staff or to other professionals;
• safeguarding of vulnerable individuals
• to protect adults who are thought to be at risk, for example if they are frail, confused or cannot understand what is happening to them

If we’re worried about your physical safety or feel we need to take action to protect you from being harmed in other ways, we’ll discuss this with you and, if possible, get your permission to tell others about your situation before doing so.

For all of these reasons the risk must be serious before we can override your right to privacy.

We may still share your information if we believe the risk to others is serious enough to do so.

There may also be rare occasions when the risk to others is so great that we need to share information straight away.

If this is the case, we’ll make sure that we record what information we share and our reasons for doing so. We’ll let you know what we’ve done and why if we think it is safe to do so and will not cause harm, distress or further risks to you, our staff, other professionals and/or the public.

We store personal information both electronically and in paper form.

We implement security policies, processes and technical security solutions to protect the personal information we hold from:

• Unauthorised access
• Improper use or disclosure
• Unauthorised modification
• Unlawful destruction or accidental loss

We’ll do what we can to make sure we hold records about you (on paper and electronically) in a secure way, and we’ll only make them available to those who have a right to see them. Examples of our security include:

• Encryption, meaning that information is hidden so that it cannot be read without special knowledge (such as a password). This is done with a secret code or what’s called a ‘cypher’. The hidden information is said to then be ‘encrypted’
• Pseudonymisation, meaning that we’ll use a different name so we can hide parts of your personal information from view. This means that someone outside of the Places for People Group could work on your information for us without ever knowing it was yours
• Controlling access to systems and networks allows us to stop people who are not allowed to view your personal information from getting access to it
• Training for our staff allows us to make them aware of how to handle information and how and when to report when something goes wrong
• Regular testing of our technology and ways of working including keeping up to date on the latest security updates (commonly called patches)

When you contact us, we may ask you to provide us with some information so that we can confirm your identity. If other people (e.g. family members, support workers, solicitors) act on your behalf we will take steps to ensure that you have agreed for them to do so. This may include asking them to provide us with supporting information to indicate your consent. We do this to protect you and to make sure that other people cannot find things out about you that they are not entitled to know.

Employees and third parties who have access to, or are associated with the processing of, your personal information are obliged to make reasonable efforts to safeguard it.

Where in the world is your information?

Your personal information is stored on systems in the UK. But there may be some occasions as our technology services progress where your information may leave the UK either in order to get to another organisation or if it’s stored in a system outside of the EU.

We will always have additional protections on your information if it leaves the UK ranging from secure ways of transferring data to ensuring we have a robust contract in place with that third party.

We’ll take all practical steps to make your personal information is not sent to a country that is not seen as ‘safe’ either by the UK or EU Governments.

There’s often a legal or a contractual reason for keeping your personal information for a set period of time. We will keep your information for the duration of providing a service or product to you under the terms of a contract, such as your tenancy agreement. When your contract has ended we will keep your personal data for a set time for auditing and reporting purposes and for legitimate interest purposes, after that time we will either anonymise or destroy your information.

You can ask us for a copy of our retention periods by contacting us at contact us

Places for People and Places for People Group takes responsibility to protect the personal information we hold about those with whom we work seriously. We are accountable for our processing and take necessary technical and operational steps to information security protections.

If you suspect your personal information or that of others may have been at risk of a data protection breach please tell us.

We have a Data Protection Officer who makes sure we respect your rights and follow the law. If you have any concerns or questions about how we look after your personal information, please contact the Group Data Protection Officer at data.protection@placesforpeople.co.uk

For independent advice about data protection, privacy and data sharing issues, you can contact the Information Commissioner’s Office (ICO) at: ico.org.uk/make-a-complaint.

Information Commissioner's Office
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF

Telephone: 0303 123 1113 (local rate)