Homes for Change
GDPR Privacy Notice
|First written – 2018|
|Last update – 2018|
|Next update due – 2020|
If this information is too long or hard to understand, you can contact us by email to email@example.com and we can explain this to you face-to-face or over the telephone, or respond over email to any queries you have.
This privacy notice explains how Homes for Change Housing Co-operative (“we”, “us” or “our”) handle any personal information about you. Homes for Change Housing Co-operative is registered under the Industrial and Provident Societies Act 1965, register number: 27159R/ HC Reg Number C389. Details on how to contact us are in Section 10 below.
Homes for Change Housing Co-operative is committed to protecting your personal information and being transparent about what information we hold, whether you are a tenant, volunteer, visitor or you connect to us in another way.
The purpose of this notice is to give you a clear explanation about how Homes for Change Housing Co-operative collects and uses the personal information you provide to us, whether online, via phone, email, in letters, in any other correspondence or from third parties.
We ensure that we use your information in accordance with all applicable laws concerning the protection of personal information. This notice explains:
- What personal information Homes for Change Housing Co-operative may collect about you
- How we might use that information
- Our legal basis for contacting you and using your personal information
- How we protect the privacy of children and vulnerable people
- Whether we disclose your details to anyone else
- Your rights and choices regarding personal information you provide to us
2. When do we collect personal information?
We may collect personal information about you when you:
- Ask about our activities, resources or tenancies
- Register with us for information
- Begin the process of becoming a member
- Attend our activities
- Purchase services or hire our space(s)
- Sign up for publications or newsletters
- Become a Member
- Volunteer with us
- Apply to be or become a contractor to work with us
- Telephone, write, contact us online, text us, or otherwise provide us with your personal information.
We may collect information about you directly whenever you interact with us. We may also receive information about you when you interact with third parties with whom we work e.g. Mosscare who support us in managing rent collection.
We may supplement what we know about you with information that is available to the public. For example, in order to ensure that our communication with you is relevant and tailored to you.
3. Why do we collect this information?
The main purposes for which we use your personal information are:
- To enable us to carry out the work of Homes for Change Housing Co-operative as specified in our Fully Mutual Rules (also known as our constitution);
- Promoting the interests of Homes for Change Housing Co-operative;
- Creating materials for stakeholders (such as Members, tenants and partner agencies) about Homes for Change Housing Co-operative’s activities;
- For legal and regulatory compliance purposes, for example, to ensure compliance with safeguarding, health and safety requirements and other legal obligations, or in connection with litigation, an internal investigation or audit, and to ensure compliance with laws, as well as equal opportunities monitoring;
- To manage our Members, contractors, freelancers, employees and volunteers;
- To maintain our own accounts and records;
- To inform individuals of news, events, activities or services running at Homes for Change Housing Co-operative and partner organisations;
- For administrative purposes (for example, we may contact you regarding an event for which you have expressed interest, to provide information requested from us);
- To carry out any contractual obligations we may have to you;
- To process payments we may receive from you;
- For internal record keeping relating to Membership, payments, tenancies, feedback, or complaints;
- To contact you where you have been identified as a contact person for an organisation with whom we do or may work (if we obtain your contact details in this way, we will only use them to contact you in your capacity as a representative of that organisation);
- For our ‘legitimate business interest’, which means a reasonable use in line with what the aims and activities of Homes for Change Housing Co-operative are.
- To obtain information about new members housing situation. This is in order to award them housing points to determine their position on the waiting list for a flat.
4. What information do we collect?
Personal information we collect can include information such as your name, communication preferences, email address, postal address, telephone number, mobile number, date of birth, details of your current housing situation, details of your life circumstances that give you points on our housing list, (including health information or details of domestic issues), bank account details so we can process payments and information as to whether you are a taxpayer for the purposes of paying staff or contractors. We may also collect and record any other relevant information you share with us about yourself, for example your employer if you work for a contractor we work with.
We may also collect and process information about your interactions with us, including details about our contacts with you for example through email on the phone or in person (such as the date, time, and method of contact), details about events or activities that you register for or attend, number of hours you spend being active with us each month. Under data protection law, certain categories of personal information are recognised as sensitive, including information regarding race, religious beliefs sexuality, gender, health information, whether you have been looked after through the local authority (‘in care’), or other characteristics relevant to the purpose for which we hold your data e.g. health and safety. In limited cases, we may collect sensitive personal data about you. We would only collect sensitive personal data if there is a clear reason for doing so, such as where we need this information to ensure that we provide appropriate facilities or support to enable you to participate in the activities of the Cooperative.
With your consent, we might also gather from you and hold case studies or stories of you and your life/ work with us, e.g. through films/videos for social media or through written case studies. This is usually for promotional purposes (e.g. for our newsletter), or for funders (e.g. if we receive a donation towards our Gardening Group activities).
We do not collect sensitive personal information about you unless there is a clear reason for doing so, for example, relating to your health/access needs if you are visiting us or applying for Membership. We will only collect sensitive personal data with your consent, and clear notices will be provided on applications and other relevant forms and communications, so you know what information we need and why we need it.
In some cases, we may also collect information about you from publicly available sources.
We keep your personal information only for as long as required to carry out the functions of Homes for Change Housing Co-operative in accordance with legal requirements, as well as tax and accounting rules. Where your information is no longer required, we will ensure it is disposed of in a secure manner.
5. When do we collect personal information?
Generally, our processing of your personal information as described in this notice is allowed by applicable data privacy laws because we have a legitimate need to carry out the processing for the purposes described above. Some processing may also be necessary so that we can undertake contracted work with you, or because it is required by law. We only use your information to send you marketing communications by email, post or text with your consent, and you can always opt out of receipt of marketing communications as explained below.
When you sign up to a newsletter or opt-in to our communications using our forms (e.g. a registration form or online form) or in person, then you are giving us your consent to send you information, or marketing materials by the methods you have chosen, (e.g. email or phone call). Also, we will collect information on application forms and by home visits when you are applying for a flat. We will never send you marketing by email or SMS without your consent, and you can withdraw your consent at any time.
If you have provided us with your postal or telephone contact details, but haven’t specifically opted-in to receive our communications, then we will carry out an assessment of whether it would be fair and reasonable to use them to send marketing information to you without your explicit consent, (i.e. it is in the interests of our aims as a Housing Co-operative and will not cause undue prejudice to you). This is called a “legitimate interests assessment”.
In all cases, we balance our legitimate interests against your rights as an individual, and make sure we only use personal information in a way or for a purpose that you would reasonably expect in accordance with this notice, and that does not intrude on your privacy or previously expressed marketing preferences.
You can opt out of our marketing communications at any time, (e.g. through clicking on ‘unsubscribe’ when you receive our online bulletin or by contacting firstname.lastname@example.org).
6. Children and Vulnerable Adults
We place great importance on the safety of people we work and interact with and we are committed to protecting the privacy of children and vulnerable adults we interact with Homes for Change Housing Co-operative.
Our activities may request specific information about family members of Members or potential Members. We will seek the consent from a parent, guardian or carer before collecting personal information about young people under 18.
7. Your debit and credit card information
We do not collect payment or other banking information from you directly apart from in limited scenarios if we need to pay you expenses or if you are an employee or contractor so that we can pay you. We use third parties for rent collection e.g. Mosscare. For information about their data protection policies and procedures please visit their website.
If we receive an email containing any credit or debit card details, it will be immediately deleted, no payment will be taken and you will be notified about this.
8. Your rights and choices
This section gives more detail about the following rights related to your personal information:
- The right to request that inaccuracies be corrected
- The right to request a copy of personal information held about you
- The right to request us to stop processing your personal data
- The right to withdraw consent
- The right to lodge a complaint with the Information Commissioner’s Office
You can help us keep our records up-to-date by telling us when your contact details or other personal information changes.
For Membership related matters please do this through: email@example.com
For general enquiries please email firstname.lastname@example.org
If you are part of a working group, please notify the Coordinator of that group.
You can also change your mind at any time about how we contact you or ask us to stop contacting you altogether. Where you have provided your consent for our use of your personal information, you have a right to withdraw your consent at any time. Please contact us on email@example.com to request this or at the postal address below.
It is important to be aware that some information you have given us will be in the public domain if you have consented to this, e.g. if you participate in promotional activity, filming or if you feature in our marketing materials. This may mean that it may not be possible to withdraw this material from circulation, so please think carefully about the consequences of consenting to your information being used in this way.
You have a right to request a copy of the personal information we hold about you, and to have any inaccuracies corrected.
You also have the right to request us to erase your personal information, request us to restrict our processing of your personal information or to object to our processing of your personal information.
We will comply with our legal obligations in relation to such requests, but please be aware that some information may need to be retained by us for legal reasons, for example if there is ongoing litigation or a reasonable prospect of law enforcement action.
Should you wish to exercise the above rights, please provide as much information as possible about the nature of your contact with us, to help us locate your records, including ‘nicknames’/aliases that you might have been known by, and details of in what ways you have had contact with us. We may request confirmation of your identity before we release the information if we reasonably believe this is necessary to safeguard the personal information. In certain situations, we may also charge a small fee.
Please address requests to:
Homes for Change Housing Co-operative
Unit 25, 41 Old Birley Street,
Or to: firstname.lastname@example.org
If you have concerns about the way in which we have handled your personal information, we ask that you contact us in the first instance by post or email (to the addresses above). If you are still dissatisfied, you have the right to complain to the Information Commissioner’s Office (www.ico.org.uk) which oversees the protection of personal data in the UK. Alternatively, you may choose to contact the Information Commissioner directly about your complaint, regardless of whether you have raised it with us first.
9. How do we protect your personal information?
We take appropriate physical, electronic and managerial measures to ensure that we keep your information secure, accurate and up to date, and that we only keep it as long as is reasonable and necessary.
Although we use appropriate security measures once we have received your personal information, the transmission of information over the internet is never completely secure. We do our best to protect personal information, but we cannot guarantee the security of information transmitted to our website, so any transmission is at the user’s own risk.
10. Sharing your personal information
We promise to make all reasonable efforts to keep your details secure. We will only share them with suppliers or professionals working on our behalf, or on a need to know basis for legal reasons e.g. health and safety concerns. We carefully select suppliers and professionals and will only share information with them if we are confident that they will protect it, and we have an agreement in place with them that assures this.
We will only ever share your details with other organisations to use for their own purposes if:
- We are required to by law or by a regulator;
- We deem it necessary and appropriate to respond to a legitimate request of assistance from law enforcement agencies;
- We are seeking legal or financial advice e.g. in connection with litigation or suspected fraud;
- Where appropriate, to enforce the rights of Homes for Change Housing Co-operative and its Members;
- To our underwriters so that we can maintain appropriate insurance coverage.
We will not, under any circumstances, share with or sell your personal information to any third party for marketing purposes, and you will not receive offers from other companies or organisations as a result of giving your details to us.
Where you have given consent to do so, we may disclose your personal information:
- to any stakeholders such as Members and volunteers;
- to the press for reporting purposes;
- to the general public where we use materials for promotional purposes.
We may also share your personal information where you ask us to, for example where we make a referral to another agency.
11. Where personal information is stored
Your personal information may be transferred to, and stored at, a destination outside Europe in countries which have less strict, or no data protection laws, when compared to those in Europe e.g. a third party website such as Facebook.
We store our data in line with data protection law, using secure physical safeguards (e.g. in locked filing cabinets in lockable offices) and secure IT systems, (e.g. password protected computers and systems).
12. Changes to this privacy notice
We may update the terms of this notice at any time, so please do check it from time-to-time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address you have provided to us, by placing a prominent notice on our website, and through arrangements in our General Meetings. By continuing to use our website and participating in the Co-operative, you will be deemed to have accepted such changes.
Notice adapted from a range of sources.