This privacy notice explains how we collect and use your personal information and who we share it with.
It applies to information about housing applications, residents, tenants, leaseholders, care and support services and any other customer of Hafod.
It explains why we may process your personal data and the legal basis for the processing. It also explains the choices you have about the data we hold on you.
This notice applies to personal data held by Hafod, whether the information is collected electronically, paper, website or through any other contact with Hafod.
Our Privacy Notice will tell you:-
• Who we are
• How we collect your information
• How we use your personal information and the legal basis for processing
• Sharing your personal information
• Experian and the Rental Exchange Programme
• Recording telephone calls
• Keeping your personal information
• Transferred outside the UK
• Your Privacy Rights
Who we are
Hafod is the data controller, our head office is located at St Hilary Court, Copthorne Way, Cardiff CF5 6ES. We are one of the largest housing, care and support providers across Wales.
Data Protection Officer
You can contact our Data Protection Officer at email@example.com or via our postal address: Data Protection Officer, St Hilary Court, Copthorne Way, Cardiff. CF5 6ES.
If you want to find out more about GDPR and how we use your personal data, contact Hafod’s Data Protection officer on firstname.lastname@example.org.
How we collect your information
We collect most of our information directly from you, including when you apply for one of our properties or services, complete one of our forms, when you write, email or meet with us, or respond to a survey.
We also collect information from other third parties where it is relevant to our relationship with you. This includes organisations that carry out maintenance and repair services on our behalf as well as:
• Local councils and central government departments such as the Department of Work and Pensions – for information about your benefits
• Local authorities, health and social care professionals, previous care providers – for information about your health, care and support needs, and those in your household (including your children)
• Previous landlords and credit agencies such as Experian – for your rental history, credit checks and information about your financial status/history
• Home Office, local authorities – for information about your immigration status, where relevant
• Police and other public authority fraud departments, local authorities – for information on criminal activity, but only where it is relevant to your tenancy or application
• Other residents – we may receive information in relation to complaints
How we use your personal information and the legal basis for processing
To assess your housing application and manage our contract with you.
We use the information we hold about you to manage your tenancy or leasehold. We need this to deliver our housing services to you. We collect most of this information because it is necessary in the performance of a contract. You will not be able to opt out of providing this type of information.
We also process some of your data because it is in our legitimate interest to do so. You can object to this processing if you think that you legitimate interests outweigh ours.
We consider that we have a legitimate interest to make sure that:
• Our services/properties meet the needs of our customers
• We can contact residents in the event of emergencies and to carry out essential repairs
• We communicate with residents to meet our business objectives, encourage social inclusion and help build communities
• We work with authorities and the police to support safer communities
• Hafod remains commercially viable and protects its commercial and social assets
• We have effective procedures for preventing, and managing, outstanding debt resulting from unpaid rents
• We make the most efficient use of our resources and we understand how we are performing
• We understand our resident’s experiences and views so that we can effectively influence and contribute to debates on future housing strategies
To provide care and support services
As a provider of care and support services, we process data about your health and social care to deliver our services and to safely meet your assed needs. We also process this information because it is necessary in the performance of a contract, to fulfil our legal and regulatory obligations, and because it is in our legitimate interest to do so.
Where we are providing care and support services as part of a local authority contract, we may share your information with the commissioning local authority or NHS trust.
To provide appropriate properties and services
We process personal information that relates to your health and social care, to help us make any reasonable changes to our properties and services, to make them fit for purpose and accessible for everyone. We also use this type of information to make sure we are protecting vulnerable individuals in our communities.
We do this to meet our legal and regulatory obligations, for example, The Equality Act 2010, and because there is a substantial public interest for us to do so.
Some of our processing is carried out to ensure we fulfil our legal and regulatory obligations in providing care and support services, for example under the:
Social Services and Wellbeing (Wales) Act 2014
Wellbeing of future generations (Wales) Act 2015
Mental Capacity Act 2005
Mental Health Act 1983
(This list is not an exhausted list)
We must also comply with Care Inspectorate Wales for quality and safety.
To promote community safety to safeguard individuals
We process personal data to promote a safer community environment; this can include information about anti-social behaviour, criminal activity and convictions. We process this information because it is in our legitimate interest to do so and to prevent and detect unlawful acts.
We process information about safeguarding individuals, to fulfil our legal obligations and because there is a substantial public interest for us to do so.
To contact you about your property and other services
We use your contact details (including telephone numbers and email address) to get in touch with you about issues relating to your tenancy or leasehold and to deal with any legal matters arising from it. This includes repairs and maintenance, rent collection, complaints and housing management issues, in the event of an emergency, or to enforce the terms of your tenancy or lease.
We may pass on your details to contractors that provide services on our behalf, so that they can contact you to carry out essential services related to your property. We do this because it is necessary in the performance of a contract. It is not possible to opt out of this type of data processing. Where we do not have the appropriate contact details for you, we may also try and source these externally from other third parties or public sources of information.
We’re constantly working to improve our services. One of the ways we do this is by listening to our residents and asking for feedback via surveys. These surveys are mostly carried out in house. There are occasions when we will use a third party to carry out surveys on our behalf. In such cases, we pass on your contact details to them so that they can contact you and ask about our performance. It is in our legitimate interests to use your contact details this way, however you may opt out of further contact by letting the person requesting the feedback know that you do not wish to take part in any further surveys.
We also use your contact details to keep you updated about Hafod events or other services which do not form part of our contractual landlord services, which may be of interest to you. This includes our e-newsletter and letting you know about things such as energy efficiency, housing options events and financial advice. It is in our legitimate interests to use your contact details this way, however you may opt out of further contact by simply selecting the opt out button in the email or text. You can also opt out in writing by sending your request to Hafod, St Hilary Court, Copthorne Way, Cardiff CF5 6ES.
To provide health and social care treatment
We process your information so that we can provide the service we have been asked to provide. Some of our processing is carried out to fulfil a contract or an agreement we have with you. Where we require information because it is necessary in the performance of a contract you will not be able to opt out of providing this information. This is because without it we would be unable to provide you with the service you have asked us to undertake.
To monitor equality, diversity and inclusion
We may ask you to provide us with your diversity data (ethnicity, religion, disability, sexual orientation). This information is not used to inform any decisions we make about you individually, but is gathered for statistical purposes to help us understand who is living in our communities. It helps us to ensure fairness and equality in the services we provide, and allows us to fulfil our legal and regulatory obligations. You do not have to provide this information but it helps us if you choose to do so.
To prevent and detect fraud and illegal subletting
We process some personal data to guard against fraud and illegal subletting, for example – proof of identity. Failure to provide any information we require in relation to this could put you application or tenancy at risk.
We process this type of information to fulfil our legal obligations and to prevent and detect unlawful acts.
For profiling purposes
We use some of your personal data to create a profile of you so that we can identify relevant Hafod services that might be of interest or helpful to you. For example, if information suggests that you may be having some difficulties with managing your finances, or we think you might encounter difficulties in the future, we can direct you to our Smart Money Team. Alternatively, if our information suggests that you might be a vulnerable tenant because of age, or ill health, we may offer you an enhanced service.
We do not use automated profiling or automated decision making to make any decisions on your application, tenancy or leasehold.
To support research and analysis
We may use your personal data to carry out internal research and analysis. We do this to develop and improve services and to help us understand trends within the housing sector. We process information based on our legitimate interests for these purposes.
We also share some information with our data processors, which are organisations that carry out a service on our behalf. This includes repairs and maintenance, gas servicing and debt collection. We only share information which is necessary for them to carry out the service they have been contracted to provide. All our contractors operate under the terms and conditions of a legally enforceable contract and will not use your information for anything other than carrying out a service on behalf of Hafod.
We do this based on our legitimate interests.
Welsh Government Housing Regulation
We share information about social housing letting data with the Welsh Government Housing Regulation. It is a regulatory requirement for all registered providers to supply this data as per The Regulatory Framework for Housing Associations Registered in Wales. The Regulation Framework is a non-statutory Code of Guidance which we are obliged to follow.
The data sets we share include information on lettings, type of tenancy, rents and charges, demographic information about tenants (including special category data and criminal convictions) and financial information. The data set does not include names or addresses but does include the unique property reference and the full postcode.
The information is used for research and statistical purposes to allow The Welsh Government to exercise their role in providing adequate social housing. The information cannot be used for any other purposes, such as making decisions in relation to specific residents.
We share information because it is necessary for the performance of a task carried out in the public interest and/or for reasons of substantial public interest. Individuals are not able to opt out of this process.
If you require further information please visit their website.
Other Organisations we may share your information with includes:-
• Local council and government departments
• Health and Care services
• Police and other law enforcement agencies
• Electricity, water and gas companies
• Social Housing Regulator
• MPs and Councillors acting on your behalf
Experian and the Rental Exchange Programme
We share some of your personal data with Experian, a consumer credit reporting agency. This is to help us prevent and detect fraud and illegal subletting and to manage out rental arrears. We also receive information about you from Experian and for the same purposes. We process this information to fulfil our legal obligations and to prevent and detect unlawful acts.
As part of the Rental Exchange Programme, we share your rental payment history with Experian. This programme allows tenants with a history or no credit, who are paying their rent on a regular basis, to build up a credit score. You can opt out of the Rental Exchange Programme at any time by contacting us. You can call Hafod and we will opt you out.
We exchange information as part of the Rental Exchange Programme because it is in our legitimate interest to do so.
Failing to keep up with your regular payments could affect your credit rating.
If you would like more information you can visit www.experian.co.uk/rental-exchange or call Experian on 0115 9410888 and ask for a copy of the Rental Exchange Programme.
We do not usually gather information directly from children as part of our core landlord or care services. We may process information relating to children in your household where it has been provided to us during our relationship with you. In such cases, we process that information based on our legitimate interest and to fulfil our legal and regulatory obligations.
Recording telephone calls
We may record your telephone calls to our Head Office, for training and monitoring purposes and to make sure we’re delivering a good service. We process data in this way because it is in our legitimate interests to do so.
Links to Other sites
Keeping your personal information
How long we keep your personal data for can depend on the type of data it is. We will not keep your information for any longer than is necessary for the purpose we need to use it for. We have a weeding and retention schedule and delete information according to our legal and statutory requirements.
Transfer outside the UK
We do not transfer or process data outside the European Economic Area unless we have specific consent or where the nature of the processing requires it (for example you have chosen to use an email or other communications service which routes data outside the EEA).
Your privacy rights
You can object or withdraw your consent to the use of your personal data at any time. In some cases we may not be able to provide your requested service where the information processing is an integral part of the service we provide. We will tell you if this is likely to be the case.
Subject to some legal exceptions, you have the right to:
• Request a copy of the personal information Hafod holds about you
• To have any inaccuracies corrected
• To have your personal data erased
• To place a restriction on our processing of your data
• To object to processing; and
• To request your data to be ported (data portability)
Please address any such requests to Hafod’s Data Protection Officer through email@example.com or write to The Data Protection Officer, Hafod, St Hilary Court, Copthorne Way, Cardiff. CF5 6ES.
If you are not happy with our response, you have the right to appeal directly to the regulator – the Information Commissioners’ Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone 0303 1231113 Email www.ico.org.uk
We make sure our privacy notice is kept up to date. You can find the latest version on our website (www.Hafod.org.uk). If you would like a hard copy please e-mail dataprotection@Hafod.org.uk or write to The Data Protection Officer, Hafod, St Hilary Court, Copthorne Way, Cardiff CF5 6ES.