General Data Protection Regulation and privacy notice
Silva Homes (the “Association” or "we") needs to collect and use certain types of information about the individuals or service users who come into contact with the Association in order to carry on our work.
The Association is a "Data Controller", which means that we make the decisions about how your information is used and have a responsibility to keep it safe.
Your personal information must be collected and dealt with appropriately whether it is collected on paper, stored in a computer database, or recorded on other material. The Association complies with all data protection legislation when using this information, including the General Data Protection Regulations (GDPR) from 25 May 2018.
If you would like to contact us about the way we use your information, please see the contact us section at the end of this notice.
This privacy notice tells you what to expect when the Association collects personal information. It applies to information we collect about:
- people who use our services including tenants, leaseholders, their families (including children) and households
- applicants for accommodation including their families (including children) and households
- applicants for other services provided by the Association
- people who visit our offices or contact us through email, by telephone or in writing.
We collect a range of information about you, including: contact details, family circumstances, financial and ID information, health information, equality information. Most of this information will have been provided by you, but we may also obtain information from other sources. For example, we may process or be provided with information about you from third parties which may include information about potential safeguarding issues, criminal convictions or investigations, or where information is required to protect your health in an emergency. However, these circumstances are rare and we do not routinely collect this information.
We collect information about you, your family (including children) and household when you make an application to apply for accommodation or when you use our services. We also collect information if you contact us (by visiting our offices, through email, by telephone or in writing) or if you voluntarily complete customer surveys, provide feedback or participate in competitions.
We use this information to enable us to consider any applications you make, to provide you with the services and to manage your tenancy, and to help improve our services. For example, your information may be used to administer waiting lists, carrying out research, and to provide housing, welfare services, advice and support.
Some of our premises also include CCTV systems which are used to collect and monitor visual images for the purposes of security and the prevention and detection of crime.
Where we do collect sensitive information about you, for example in relation to safeguarding, criminal investigations or concerns, or related health information, we will usually do so in order to discharge our statutory obligations, to protect the vital interests of individuals and / or to prevent or detect unlawful acts. We will always use your information in accordance with the law and in compliance with the relevant data protection legislation.
For example, we will use your information for the following purposes:
- to provide you with a tenancy or service agreement because the processing is necessary in order to comply with the obligations in your tenancy or service agreement, or to take steps at your request to enter into an agreement with you, for example when you apply to us for accommodation or to use our services
- not all of your processing will be necessary for the purposes of the tenancy agreement – but we will have legitimate interests to process your data such as sharing your information with rent collection agencies if required. We will always consider the impact on your privacy and our obligations under the data protection legislation.
There may be some information we require to enable us to provide you with services or to properly manage your tenancy. If you do not provide us with this personal information on request, we may be unable to provide you with those services or to allow you to continue with your tenancy. If that is the case, we will let you know the consequences of not providing us with that information.
In some circumstances we may need to share your personal information, for example when we are required to do so in order to comply with a legal requirement or to ensure that we can provide services to you.
The Association will ensure that formal written agreements are in place with any third parties or agencies where your information is shared to ensure the ongoing security and integrity of your information.
We may share your information with, and/or obtain information about you from, other organisations and bodies such as local authorities, including social services, and housing benefit departments, central government departments, our regulator, credit reference and debt management agencies, satisfaction monitoring organisations, the police and other law enforcement agencies or as otherwise permitted or required by law.
For example, we may share information with the local authorities regarding your housing benefit or social services if there are safeguarding concerns. Central governments can contact us for access to your data for statistical purposes. We may share your information with our maintenance provider to help us to comply with our contractual and statutory duties and keep your property in good condition of repair. We may share information with our regulator to comply with our regulatory responsibilities.
We do not transfer your data outside of the EEA / UK.
The Association will store and keep your personal information only for as long as it is needed or required by statute and will be disposed of appropriately.
We abide by the National Housing Federation best practice guidelines regarding document retention so, for example, we will keep your tenancy files until the length of the tenancy and up to six years post tenancy, for insurance claims we will hold this information for two years after settlement.
For housing benefit notifications we keep this information for two years. We are also obliged to keep certain information for a number of years to comply with statutory requirements.
The Association is committed to safeguarding your personal information by putting appropriate technical and other measures in place to ensure that your personal information is not accessed or used unlawfully and to protect against accidental loss, misuse or damage to your personal data.
If you use our online services please ensure that you keep your username and passwords secure and do not provide them to unauthorised people. You must ensure that any personal information you provide to us is accurate and update to date and let us know if your records should be updated or amended.
All individuals have the right to access the information that the Association holds about them. If you wish to find out what personal information the Association holds about you this should be done by making a “subject access request”. If we do hold information about you we will:
- give you a description of it
- tell you why we are holding it
- let you have a copy of the information in the way you wish (electronically/paper etc).
All personal information will be provided to you within one month of receiving the request (unless the request is complex, in which case we may require further time to consider your request but we will let you know if this is the case).
If you wish to make a subject access request please contact the data protection officer at firstname.lastname@example.org or write to the data protection officer at the Association’s registered office (please see the "Contact Us" section, below).
We have explained above that the vast majority of the information we process about you will be because we are required to process it in order to administer your tenancy and provide you with services.
However, on rare occasions, we may sometimes process your data for specific purposes which require your consent. If we do this we will always ask for your written consent and provide you with a copy. In those circumstances where we are processing your personal data based on your consent, you have the right to withdraw that consent at any time. This may affect the services that we can make available to you but this will be explained to you.
If you change your mind, or you are unhappy with our use of your personal data, please let us know by contacting our Data Protection Officer using the details in the contact us section below.
Alternatively, you have the right to raise any concerns with the Information Commissioner’s Office (ICO) via their website by clicking here.
In addition to the right to access information the Association holds about you and the right to complain or withdraw consent, you also have the following rights:
- to have your personal data rectified, if it is inaccurate or incomplete
- to request the deletion or removal of personal data where there is no compelling reason for its continued processing
- to restrict our processing of your personal data (i.e. permitting its storage but no further processing), although in some cases we will not be able to restrict our processing
- to object to certain types of processing
- not to be subject to decisions based purely on automated processing where it produces a legal or similarly significant effect on you
- in certain circumstances you have the right to data portability.
If you would like to exercise any of these rights, or have any queries about them, please contact our Data Protection Officer, using the details in the "Contact Us" section below.
The Association takes your privacy seriously and will only use your personal information to lawfully process your data.
This policy will be updated as necessary to reflect best practice in data management security and control and to ensure compliance with or amendments to the relevant data protection legislation.
In case of any queries or questions relating to this policy, Data.ProtectionOfficer@silvahomes.co.uk or in writing to:
Data Protection Officer
Berkshire RG12 1RF
Although Silva Homes has prepared the information on this website with all due care and attention, intention for accuracy, and updates the website regularly, we do not warrant or represent that the information may have changed or is free from errors or omission.
Whilst the website is considered to be true and correct at the date of publication, changes in circumstances after the time of publication may impact on the accuracy of the information. The information may change without notice and Silva Homes is not in any way liable for the accuracy of any information printed and stored or in any way interpreted and used by a user. If you see anything that you think is incorrect or a link that is broken, please contact us by clicking here.
This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.
We keep our privacy notice under regular review. This privacy notice was last updated in May 2018.
Not only will we be able to work with you more closely to manage your existing tenancy agreement, your track record as a tenant will enable Experian to use the information supplied to them to assist other landlords and organisations to:
- assess and manage any new tenancy agreements you may enter into
- assess your financial standing to provide you with suitable products and services
- manage any accounts that you may already hold, for example reviewing suitable products or adjusting your product in light of your current circumstances
- contact you in relation to any accounts you may have and recovering debts that you may owe
- verifying your identity, age and address, to help other organisations make decisions about the services they offer
- help to prevent crime, fraud and money laundering
- screen marketing offers to make sure they are appropriate to your circumstances
- for Experian to undertake statistical analysis, analytics and profiling
- and for Experian to conduct system and product testing and database processing activities, such as data loading, data matching and data linkage.
If you would like to see more information on these, and to understand how the credit reference agencies each use and share rental data as bureau data (including the legitimate interests each pursues) this information is provided at this link www.experian.co.uk/crain (Credit Reference Agency Information Notice (CRAIN)).
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