This Privacy Notice tells you what to expect when Bristol Charities processes personal information. It applies to information about applicants, residents and other service users.
Why Do We Collect and Store Personal Information?
Bristol Charities needs to collect, process and store information about you and other household members in order to:
- Operate as a registered provider of affordable housing and an Almshouse Charity
- To provide you with the services, products or information you have requested
- To administer your donation including processing Gift Aid
Information We May Hold About You and How We Use It
The information we hold on our records concerns our relationship with you.
We hold names and dates of birth, photographic I.D. and information about your previous housing circumstances to assess housing and applications and help us prevent illegal subletting and fraud.
We hold information about your right to reside including passports and residency status in order to comply with the Immigration(EEA) Regulations 2006(amendment)
We hold information about you that is needed for the assessment of a grant which may include financial, family, education and employment information, your income and expenditure.
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 assist us in delivering housing management services including reports of anti-social behaviour, complaints, change in circumstances e.g. if you have a medical need which means you need to move.
We keep financial records about the amount of money you have paid us any amounts outstanding and associated recovery action. Depending on your chosen method of payment, we may hold your bank account details.
We may capture your image on our CCTV systems if you visit our Head Office or our schemes which are covered by this facility. CCTV recordings will be hold in accordance with our retention policy.
We may carry out market research and customer satisfaction surveys to help us monitor our performance and to improve our services.
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, the service being delivered or a grant application e.g. from Social Workers, Doctors, Occupational Therapist etc.
We will only ask for personal information that is appropriate to enable us to deliver our service or to assess an application for housing or a grant. 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 Data Protection Act 1998. 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
To help us to ensure confidentiality of your personal information we will ask you security questions to confirm your identity when you call us and as may be necessary when we call you.
We will not discuss your personal information with anyone other than you, 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 are taking adequate steps to protect your personal information.
We may apply markers to your information (for example: in relation to your vulnerability or health status) to enable us to tailor and deliver services to you. Bristol Charities only keeps 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 between us.
Sharing Your Personal Information
Normally only Bristol Charities staff and volunteers will be able to see and process your personal information. However, there may be times when we share relevant information with third parties for the purposes as outlined in section two (2), or where we are legally required to do so. When sharing personal information, we will comply with all aspects of the Data Protection Act.
Sensitive information about health, sexual life, race, religion and criminal activity for example is subject to particularly stringent security and confidentiality measures.
Where necessary or required we may share your personal information as follows:
- We will share information on grant applications with Grant Committee members. We will also publish data on grant recipients for committees/groups/organisations (amounts/purpose) but we anonymise details for any individual grantees.
- We will provide information to HMRC on Gift Aided donations as we have a legal obligation to provide this information.
- With our contractors, in order to undertake repairs, maintenance or improvement works with third party service providers performed on our behalf. For example: where we use another company to carry out a resident satisfaction survey or if we use a mailing house to distribute our newsletters. Our relationships with such providers are governed by our contract with them which include strict data sharing and confidentiality protocols.
- With other housing providers and landlords in connection with tenancy/licence references and associated enquiries.
- With community partners in connection with the delivery of coordinated services.
- With utility companies (and their representatives) and Council Tax offices to ensure billing details are correct.
- With credit reference agencies and debt collection agencies in connection with some housing applications and in relation to any outstanding charges.
- 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 (e.g. Probation Service, Department of Work and Pensions, H.M 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 e.g. Social Services and Health Authorities, as necessary for exercising statutory functions.
- With our regulator, the Homes and Communities Agency (HCA)O to comply with regulatory obligations.
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)
Access to Your Personal Data
Under the Data Protection Act you have a right to ask us what personal information we hold about you and to request a copy of your information. This is known as a “subject access request” (SAR).
SAR’s need to be made in writing and we ask that your written 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 I.D. (both yours and theirs).
We have 40 calendar days within which to provide you with the information you have asked for (although we will try to provide this to you as promptly as possible).
In response to SARs, 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”.
If you need to correct any mistakes contained in the information we hold about you, you can do this by contacting us at: firstname.lastname@example.org
Security of Your Data
Non-sensitive details (your email address etc.) when transmitted normally over the internet cannot be guaranteed to be 100% secure. Whilst we take all possible means to protect your personal information, we cannot guarantee the security of any information you transmit electronically to us, and you do so at your own risk.
Once received we keep your data secure on our server with appropriate security mechanisms in place.
The law requires us to tell you the basis on which we process your data.
Some activities (for example sending you emails to tell you about the charity and its objectives) require your consent. If the law requires your consent to process data in a certain way, then we will obtain it before carrying out that activity.
Other activities are carried out to fulfil a contract or agreement e.g. providing support to individuals in their homes. This requires us to know who you are and to process your information in order to do the thing you have asked us to do. If a contract is in place, then we will process your data based on that contract.
In all other cases the law allows us to process your data if it is in legitimate interest to do so, but only as long as we need to and your “interests or your fundamental rights and freedoms are not overriding”. This means we carry out an exercise to check that we will not cause you harm by processing your data, that the processing is not overly intrusive and that we will only do so in a way which is described in this Privacy Notice.
We will keep data for as long as is needed to complete the task for which it was collected, and for a specific period after this according to our Retention Policy or to fulfil statutory obligations.
The law requires us to tell you that you have certain rights about the way we process your data. They are as follows:
- Where our use of your data requires consent, you may withdraw this consent at any time
- Where we rely on our legitimate interest to process data, you may ask us to stop doing so
- You may request a copy of the data we hold about you
- You may change or stop the way in which we communicate with you or process data about you, and if it is no required for the purpose you provided it, then we will do so. Some activities may mean that we cannot entirely stop processing your data. We will always endeavour to comply with such a request however.
If you are not satisfied with the way we have processed your data, then you can complain to the office of the Information Commissioner.
We keep our Privacy Notice under regular review and we will place any updates on our website. Whilst we recommend that you keep up to date via the website, any major changes will be brought to your attention.
This Privacy Notice was written in January 2018.
For further information on this Privacy Notice, or about the way in which we process your data, or if you wish to change the way in which we process your data, including how we communicate with you, then please contact us on: email@example.com
17 St Augustine’s Parade
Tel: 0117 9300 301