Privacy Policy

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1. Summary

This Privacy Notice is a public document available to anyone and applies to customers of Grŵp Cynefin to explain how the organisation collects and processes personal information in order to conduct normal business activities as a UK charitable housing association. We are a Registered Social Landlord (RSL) regulated by Welsh Government. Normal activities can be summarised as:

1. Providing social and other types of housing.
2. Property and grounds maintenance and repair.
3. Managing your housing, tenancy/lease and account as your landlord.

We also provide additional optional services including:

4. Organizing and assisting community events.
5. Offering opportunities to be involved.
6. Providing welfare and benefits advice.
7. Adaptations made to the properties we manage.
8. Selling properties.
9. Support to Service Users

Our mission is to ‘Provide excellent homes and services, develop sustainable communities where people want to live’.

2. Who we are

Grŵp Cynefin is the Data Controller whose head office is located at Tŷ Silyn, Y Sgwâr, Penygroes, Caernarfon, Gwynedd LL54 6LY Tel: 0300 111 2122. The company Data Protection Officer can be contacted via post@grwpcynefin.org.

3. How we collect your information

Grŵp Cynefin collects information from you via a variety of sources, including when you apply for one of our properties or services, complete one of our forms, when you call, write, e-mail or meet with us or respond to a survey. We may also collect information when you use our social media sites and websites.

Our landline phone calls are recorded for training and monitoring purposes and our recordings are usually held for a period of 36 months.

We operate a CCTV system at Grŵp Cynefin office premises for the detection and prevention of crime.

From time to time we may operate CCTV / sound recording and / or use photography to capture evidence of breach of tenancy, alleged anti-social behaviour or crime.

We may also take photographs at our events, at our properties and in our communities to use for general marketing and publicity. However, photographs of individuals will only be used for those purposes with your consent.

We may receive information about you from third parties including:

• Your council or benefits office relating to your housing.
  
• Previous landlords and credit agencies when you apply for housing.
  
• Police, welfare or support organisations dealing with you.
  
• Councillors, MPs or other representatives acting on your behalf/instruction.
  
• Financial institutions when you apply for our services.
  

4. What information we collect about you

The information we require from you, the tenant(s) or leaseholder(s), includes:

• Full name (and proof of your identity / photo ID).
  
• Date of birth.
  
• National Insurance number (your unique identifier).
  
• Contact details (phone, e-mail or correspondence address).
  
• Details of anyone authorised to act on your behalf if applicable which includes the contact details of your next of kin.
  
• Basic details (name and DOB, gender and preferred language of communication) of all household residents.
  
• Banking details if you pay your rent by Direct Debit.
  
• Card details if you pay by card (however card details are not stored).
  
• Proof of housing eligibility, any interest or equity in other property.
  
• Other personal information that will vary on a case by case basis to help us resolve breach of tenancy, alleged anti-social behaviour or fraud.
  
• If you provide us with a mobile phone number or email address, we will use these methods to communicate with you.
  

The information we may collect from you includes:

• Disabilities or vulnerabilities and protected characteristic information. We use this information to tailor our service to better meet your particular circumstances and needs. We may use this information for safeguarding of staff or to provide appropriate support to tenants or service users.
  
• Financial information. We may use this to help resolve arrears payments and optionally to provide welfare, benefits and debt advice as a free service to help you budget and pay your bills.
  
• Health information when we require this to support funding for adaptations made to the property you are living in. More specific details are provided if you use this service.
  
• Bank statements, payslips or income details when we require this information for processing a house sale or purchase.
  
• Information about your support needs to help you remain living in your home.
  
• To participate in initiatives to assist in the prevention of financial and social exclusion.
  

If you do not provide the information we need then we may not be able to provide all our services to you, and ultimately you may not be able to hold a tenancy or lease
with us, or sell or purchase a property through us.

5. What processing we do with information collected

The information we require from you is used to manage your tenancy or leasehold agreement or other contract between you and Grŵp Cynefin. Please read your contract carefully for specific details as ‘performance of a contract’ is usually the legal basis for processing your information and carrying out our activities.

The processing activities we conduct can be summarised as:

• Managing your account charges and payments, including arrears.
  
• Managing the repairs, maintenance and adaptations of our properties.
  
• Ensuring tenancy (or contract) conditions are complied with, such as dealing with anti-social behaviour or fraud.
  
• Complying with relevant legislation and regulation.
  

Grŵp Cynefin conducts research and statistical analysis to help improve our business processes and the services offered to our customers, as well as to evaluate our performance against other benchmarks. When possible, statistical information is anonymised or pseudonymised.

Grŵp Cynefin conducts surveys regularly and periodically relating to our services in order to gauge satisfaction and make improvements based on feedback.

Grŵp Cynefin operates a range of information and communications systems and technologies for efficient operation of the business. Personal information is stored and managed within those systems which are maintained to achieve a high level of confidentiality including following best practice cyber security standards.

We hold information in IT systems which may be copied for testing, backup, archiving and disaster recovery purposes.

6. Additional services

Grŵp Cynefin conducts a number of additional voluntary services including organising community events, providing welfare benefit advice, adapting the property you live in, selling properties and gathering information to improve our services.

For these voluntary services, where your personal information is needed, we will always notify you about the service being offered, explain the service and obtain your consent to proceed, usually by way of a sign up / consent form for that service.

For the additional voluntary services, much of the information contained in our Privacy Notice is still relevant, such as details about Grŵp Cynefin as the Data Controller, contact information for the Data Protection Officer and the rights you have under the legislation, including the right to withdraw your consent and the right to complain.

7. Children’s and other residents of the property information

Grŵp Cynefin does not normally process children’s information as part of a tenancy, as all tenants are adults. However, we record children’s basic information if they are resident in one of our properties, including their name, gender and date of birth. This is required for checking the property is not overcrowded and to assess other tenancy management issues where all householders and ages are required to be known.

We may receive children’s information if we are involved in the housing and tenancy aspects of a welfare case as part of a multi-agency working solution.

We also may record children’s and young people’s information for support planning and providing support to the household.

This is also applicable for any other adults who live with you as a household.

8. Property information

Much of the data we use relates to our properties and their maintenance and repair. We do not consider property information used in conjunction with the property address to be your personal information. For example, the age of the kitchen, results from an asbestos survey, planning to replace windows or a repair to a tap.

We are usually happy to provide you with answers to questions you may have about the property you are living in and work done to it.

As soon as your name, contact details or other personal information is used in conjunction with property information, such as to complete a property repair visit, then this is treated as personal information.

9. How we will communicate with you

Grŵp Cynefin needs to communicate with our customers and this will usually be in writing or by telephone, but is more commonly becoming electronic and paperless. We are moving many of our services on-line as this is usually more convenient for you and more efficient for us.

Our tenants receive our newsletter ‘Calon’ with information about what is going on within the organisation.

We will only discuss or communicate your tenancy or lease details with those named on the agreement or those authorised (temporarily or permanently) by you. You can authorise someone temporarily verbally over the phone or permanently in writing.

10. Who we share data with and how long we keep information

Grŵp Cynefin shares limited personal data with our contractors who are carrying out services on our behalf. Our contractors and suppliers who provide services to you and to us are required to comply with the law and our own Data Processing Agreement to ensure data is managed appropriately and for specified purposes, including to run our out-of-hours telephone service or to complete emergency, responsive or planned property repairs.

We may share your information with a language translation service if it is necessary to translate any information into or from a foreign language for you.

Grŵp Cynefin may need to share personal information with government departments and agencies, with our regulator and auditors, with local authorities, with other housing associations and support organisations, with mediation and advocacy partner organisations with utility companies or with other organisations and agencies where we are legally allowed to do so.

Information relating to a tenancy or lease agreement will be kept for as long as the agreement is active or where money is owed on the account, and for a period not exceeding six years afterwards. The basic history of who held a tenancy at which property and when will be held forever.

We may need to share information with solicitors, insurers, agents, mortgage brokers, financial advisors, credit reference agencies,court agents, surveyors, valuers relating to a property sale and training providers or learning institutions.

In some cases we may have a duty to disclose your information by law to:

• Our partner organisations whose purposes are combatible to ours
  
• Other housing associations
  
• Local Authorities, regulators and government departments
  
• Police, fire services or the health authority or medical staff
  
• Others who may need information from us for their own puroses (for crime prevention or detection, for the prevention and detection of fraud.
  

11. What we will not do

We will not send you unsolicited marketing material.

We will not sell your personal data on to third parties.

We will not pass on your personal data to unrelated third parties unless we are allowed or required to do so by law or we have your explicit permission to do that.

12. Your rights, the right to complain and the ICO

You have the right to request a copy of the data we hold about you. Please contact post@grwpcynefin.org if you wish to request access to any of your personal data and we will always endeavour to answer your questions as part of our friendly, helpful service.

We will respond within 30 calendar days.

It will always help if you can be as specific about what personal data you want to see, what it relates to and within what timeframe, as that will assist our search. You have the right to correct information that we hold. Please advise us of any changes or corrections by contacting our Customer Services team on 0300 111 2122 or via e-mail to post@grwpcynefin.org.

You may withdraw your consent to use any information that was previously provided with your consent. Please advise us if you wish to withdraw any consent previously given to post@grwpcynefin.org.

You also have other rights which can be seen by visiting the Information Commissioner’s Office (ICO) website and reading about Data Protection law at https://ico.org.uk

You have the right to complain about any matter relating to our service, including how we use your personal data:

• In the first instance please contact our Customer Services team on 0300 111 2122 or e-mail post@grwpcynefin.org.
  
• If you are still not happy with our service you may complain to the Public Services Ombudsman Service at http://www.housing-ombudsman.org.uk/.
  
• If you wish to complain about our use of your personal data you may complain to the UK Information Commissioner’s Office (ICO) at https://ico.org.uk/.
  

13. Further Information

For further information about Grŵp Cynefin, please see our website at www.grwpcynefin.org or contact our Customer Services team.

14. Changes to our Privacy Notice

Our Privacy Notice is regularly kept up to date and this version was updated on 25 May 2018. The latest full version is always available from our website at www.grwpcynefin.org

 

Privacy Policy (PDF)