Quays Housing and Your Data
Quays Housing is a Data Controller and therefore has a duty to keep the information we collect about you safe and comply with data protection law when we use it.
Why we need your information
When you’re a customer of Quays Housing, we need information about you because:
- When you apply to live in one of our properties, we need to check that you are eligible for it and that you can afford the rent.
- When you request support services from us, we need to know about you and your circumstances so that we can provide the right services and support which suit your needs.
- We have responsibilities as a landlord and need your information to make sure we can carry those responsibilities out. This includes:
- Carrying out maintenance work for example gas servicing, electrical testing, replacing kitchens, bathrooms or roofs.
- Carrying out repairs.
- Informing you about matters which are relevant to your tenancy/licence or where you live.
- We need to collect rent from you or from the local authority who pays rent on your behalf.
- If we believe you aren’t complying with the responsibilities set out in your tenancy agreement or licence, we’ll contact you to find out what’s happening and make sure you understand what those responsibilities are. If you continue not to uphold your responsibilities we might take legal action against you, for example if you’ve been causing serious anti-social behaviour, have behaved in a threatening manner or caused harm to someone we might request the court to evict you.
Information we collect and why
Tenancy or Licence related
We collect information about you in relation to your tenancy agreement or licence so that we can make sure we’re carrying out our responsibilities under the agreement and you’re yours.
The types of information we collect in relation to your tenancy agreement or licence are:
- Name, address and date of birth, National Insurance Number and other formal identification, so we can identify you.
- Contact details so we can get in touch with you when we need to.
- Your financial circumstances including information about benefits, earnings and any other income or savings. If you’re going to live in one of our properties, we need to confirm you are eligible for it and can afford to pay the rent, or it will be paid on your behalf by the local authority.
- Communication preferences – it is helpful for us to know information about you which helps us to communicate with you in the way you prefer. We might therefore ask you to share information about:
- Disabilities – for example if you are deaf we can use a hearing loop or other technologies to talk to you; if you have mobility issues we will make sure we wait patiently for an answer when we contact you; if you have learning difficulties you might prefer us to contact a support worker or advocate.
- Your preferred language, for example if English is not your first language we can access translation services.
- [Do we need this one?] We collect the name, age and if appropriate contact details of the people who live with our tenants. We use this information to:
- Confirm that you aren’t sub-letting your home
- Identify any overcrowding issues
- Contact someone in the house if we can’t get hold of the you or have concerns for your safety
- Identify potential tenancy fraud
- Your rent and service charge payments, so that we have accurate records of what you have paid, and take action if you are in arrears. If you are in arrears, we will ask you to pay them back and potentially take legal action if you don’t. Please do get in touch if you are struggling to pay as we may be able to suggest support services for you to access and we will always seek to agree a reasonable repayment plan for you.
- When you contact us, we will keep a record of that contact on our electronic system. We may record calls for training and monitoring purposes.
- If someone reports or complaints about anti-social behaviour to us and it involves someone living in or visiting your property, we will investigate this and keep records of the outcome.
Support Services
If you receive support services from us, we will ask you for information about your circumstances and support needs so that we can provide the right services. The information may come from you, or it may come from a local authority or commissioner who is making a referral on your behalf. The information will include:
- How you would like to be supported
- A risk assessment which will tell us what risk you pose to yourself and others.
- Health information
- Criminal convictions
- Financial position
- Preferred language
- Other agencies working with you
When you move on, we will record your reason for leaving and any other relevant details.
Health, safety, wellbeing and the law
There might be situations when we are concerned about someone’s health, safety or wellbeing. Health and safety law says we must make sure that we don’t put people at risk if we can avoid it. We will also take action when we think someone has committed a crime.
- If we have evidence that you threaten to or actually cause harm to someone else, we will call the Police if we observe this happening. We may also put a note about this on your file and advise anyone we ask to visit you to take extra precautions. These notes will be reviewed regularly to ensure they are up to date.
- If we see or have evidence that you may have committed a crime, we will provide information including CCTV footage to the Police or other relevant statutory bodies to help them investigate it.
- Sometimes we observe situations or behaviour which means we are concerned for a person’s wellbeing. For example we might be concerned that someone will commit suicide, or a vulnerable person might be suffering neglect. When this happens our colleagues will do what they can to safely support the individual and if urgent action is needed, we will call the emergency services. If non-urgent action is needed, we will report the situation to the local council’s Safeguarding Team. We will usually tell you when we make a report to the Safeguarding Team, but please note that it is the law that we report our concerns so you cannot stop us from doing it.
- We have CCTV cameras in many of our offices and buildings because they help us to prevent and detect crimes. Where an incident has occurred, we will share information with law enforcement agencies so that they can investigate the matter.
Information we collect which you can request we stop at any time
Here is the information we collect about you which you have a choice about whether or not to agree to:
- We will sometimes contact you in person, by letter, email or text to ask you what you think of our services. It’s really important to us that we understand what our customers think or our services so we can change and improve them. If you don’t want to receive these communications, you can either ignore them, or you can ask us not to contact you about this at all.
- If you’ve asked us to send you information about our products and services, we will keep your name and contact details on a marketing database. You can opt out of this at any time by emailing info@quayshousing.org.uk.co.uk
We won’t ever sell your information to other companies for marketing purposes.
These are the ways in which we might receive information about you:
- We collect information from you when you apply for a property or services from us.
- We may receive a referral from a local authority or other agency which includes your details.
- We will keep records of any contact we have with you. Please always let us know when any of your details change, so we can keep our records up to date.
- There are times when we ask other organisations to carry out work on our behalf, for example surveys, so they will give us information about their interactions with you.
- Other agencies could give us information about you, for example a support worker, healthcare professional or HMRC.
We use your information to:
- Check that you are eligible for a tenancy, licence or support service.
- Enter into a tenancy or licence agreement with you.
- Contact you about matters relating to your tenancy, licence or support service.
- Deliver services to you in accordance with your needs and preferences.
- Check that you are complying with any agreement you have with us.
- Support yours and other people’s health, safety and wellbeing.
- Investigate and respond to complaints.
- Review and improve our services including training staff.
- Provide information to the Police or other statutory agencies in investigating potential crimes.
- Create new products and services.
We will sometimes anonymise your information for statistical purposes. We might do this for example to measure our performance or to better understand demand for our products. We will make sure that it is not possible to see or deduce your personal information from these statistics.
Who will my information be shared with?
Colleagues
We need to share your information with the colleagues who work for our organisation, in order to provide the services you’ve asked for and make sure that these services are provided to a good standard. We will review and learn from our interactions with you, so that our services remain appropriate and good value.
Working with others
We sometimes share information with other organisations. Sometimes we will need to ask for your permission to do this but data protection law does not always require that we ask your permission.
Here are some examples of when your data will be shared with an organisation outside of Quays Housing:
- Some of our repairs and maintenance services are carried out by our colleagues, but there are times when we will appoint an external contractor to work on the property you live in. When we do, we will provide them with your contact details or those of your advocate/support worker if you prefer. We will inform the contractor if they need to knock and wait longer than average for you to answer and if you have any communication preferences.
- We use an out of hours service provided by an external contractor so will share relevant information with them so that they can provide this service.
- If there is a note on your file which indicates that you have threatened or harmed visitors in the past, we will inform anyone visiting the property on our behalf of this so that they can take steps to keep themselves safe.
- If you will be responsible for paying utility bills direct to the supplier, we will provide your contact details to the relevant utility companies.
- When we carry out surveys, we sometimes ask an external company to carry out the surveys on our behalf. We will provide your contact details to them, and have a contract in place which makes it clear that they can only use your data for the purposes we tell them and it must be deleted once the work is complete.
- Where we provide a service which is commissioned by a local authority or healthcare provider, our contract with them will often require us to share information about the support services you receive and any changes, incidents or other matters in relation to those services. We will send information to them by secure means (emails will be encrypted).
- If your account is in arrears and payments are usually made by the local authority Housing Benefit department, we will contact them to investigate the arrears and seek recovery.
- As described in the sections above, we will share information with the Police and other law enforcement agencies in order to prevent and detect criminal activity.
- As described in the sections above, where we have concerns for the health, safety or wellbeing of an individual we will contact the emergency services or local Safeguarding Team as appropriate. In the event of an emergency, we may share relevant health details with paramedics or other healthcare professionals, where this could save a life.
- If any of our customers need assistance with evacuating the building in the event of an emergency, we will share this with the security providers and with the emergency services.
Sharing information about complaints
Complaints can take many forms and sometimes they involve other people, for example complaints about anti-social behaviour. When this is the case, we will need to share information about your complaint in order to investigate it properly and therefore we can’t guarantee that you will remain anonymous. We will always explain what we are going to do when we investigate your complaint and if you aren’t happy with the approach, you can tell us to stop. Please note that this might stop us from being able to resolve it to your satisfaction.
We will always tell you about the outcome of your complaint. Where this involves other people, we may not be able to tell you everything about their involvement because we need to protect their privacy too.
Can my family member or advocate speak to you on my behalf?
Yes this is fine, you just need to let us know who they are, give us their contact details, and confirm what they are authorised to talk to us about. We prefer for this permission to be given in writing, but if this is not possible, please talk to us and we can agree how to organise it. Some people might have a power of attorney in place which legally allows another person to act on their behalf, once we have a copy of this we can add the details to our system so we know who to get in touch with.
How long do we retain your personal data for?
Most of your information is kept for a period of 6 years after your tenancy agreement, licence or service agreement comes to an end. This allows us to respond to any legal or insurance claims which might arise, deal with complaints and other queries.
CCTV footage is stored for 30 days and then deleted. Where an incident is reported, we will download the relevant footage and share it with law enforcement if appropriate – they will have their own retention periods. We will keep downloaded footage for twelve months in case of any queries or complaints.
[Do we record telephone calls?]
How do we store information?
Our computer systems are hosted on servers or cloud based systems in the UK. We have contracts in place which ensure this remains the case and the service providers keep the information safe.
There are a small amount of paper records stored securely at our office. These are confidentially shredded when we no longer need them.
Keeping information safe
Our computer systems are hosted in a secure environment and each colleague needs their username and complex password to access them.
Access to personal data is restricted to colleagues who need to know it in order to do their job.
Colleagues receive training on their data protection responsibilities and are prohibited from sending personal information outside of the business unless it is sent securely (encrypted or via secure portal) to an authorised recipient.
The IT department has a Leavers Policy in place which ensures anyone who leaves the business has their access rights removed promptly.
Access to information
If you would like to receive a copy of the information we hold about you, please email info@quayshousing.org.uk.co.uk
Complaints
You can make a complaint about the way we have handled your personal data by emailing info@quayshousing.org.uk.co.uk [or can they do this on the website?]
You can also contact the Information Commissioner through their website ico.org.uk/ or by calling 0303 123 1113. They will get in touch with us to check we’re using your information properly and complying with the law.