We are committed to protecting the privacy and security of the personal information of people we work with and who we provide services for. This privacy notice describes what and how we collect and use personal information about these people, in accordance with the General Data Protection Regulations (GDPR) and the Data Protection Act 2018.
Coastal Housing Group Limited, (“Coastal”), is a “data controller”. This means that we are responsible for deciding how we hold and use people’s personal information. We are required under data protection legislation to issue this privacy notice to explain things such as: what information we hold, how we use it, how long we hold it for and importantly, what rights data subjects have in respect of our use of their information.
This privacy notice does not form part of any contract or occupation agreement and we may update this notice at any time. This policy was last updated in October 2020.
A separate notice exists for employees of Coastal Housing Group Limited.
It is important that you read this privacy notice and associated documents, together with information in Coastal’s data protection policy so that you are aware of how and why we are using people’s personal information.
Coastal Housing Group Limited
3rd Floor Urban Village
220 High Street
Tel: 01792 479200 Email: email@example.com
Our Data Protection Officer is Jamie Saunders. He can be contacted via firstname.lastname@example.org
Most of the personal data we process is information that has been provided to us by the people themselves, or has been provided in connection with existing tenancies, or new housing or job applications. This could include information like people’s name, address, telephone numbers, date of birth and bank account details etc.
Where Coastal offers additional services, such as housing related tenancy support or a City Wheels scheme, the information we need to hold and why, will be explained at the commencement of the process. Sometimes we will obtain information from 3rd parties about people in the course of providing these and other services, and when we do we will be more than happy to explain this and where possible we will make this information available for the relevant people to see.
We collect personal information in a variety of , for example:
Much of the information we collect and process is detailed in the Information Asset Register which is available as part of the data protection policy. Any specific questions in this respect should be directed to the Data Protection Officer.
If anyone ever has questions about what information we hold on them that has been received from 3rd parties, we will be happy to discuss this further.
All personal data will be stored securely.
We process your personal information, including any special categories of personal information for reasons, including but not limited to:
We process this information either because it’s necessary for us to do so or because there are laws that allow us, or require us, to process it. Our legal basis for storing and processing your data will vary depending on the situation but will normally be one of the following:
This is where we would be unable to meet the terms of our contract with you without processing your data. Examples of this would be where you are applying to be, or are already renting a home from us and we need your details in order to collect rent payments.
Coastal is continually working to improve the services it offers to residents. Often in order to do this we process and analyse a lot of data relating to our current services. This could be things like how long it took to let a property, to carry out a repair or how our services are rated. We may also use this basis to make you aware of services, events or initiatives that we think may be relevant to you unless this represents direct marketing.
We also use the Legitimate Interest basis for processing access to CCTV recordings.
In some instances we may require your consent in order to process your personal information. When this applies we will make this clear to you and will not process your information unless you consent. You can withdraw your consent at any time. Examples of when we might use your consent could be when taking photographs or video for use across Coastal’s communications.
Resident / 3rd party data may be shared internally by the Housing teams, Finance, and managers in the relevant business areas only when there is a genuine business need to do so.
We will also sometimes share your data with specific third parties where appropriate such as DWP, the local authority or the Police. Your data is shared with these companies in line with the GDPR and where relevant the Data Protection Act 2018.
We also share some of your personal data with third parties who help us provide our services to you. These 3rd parties are called ‘data processors’ and we only do this when we are sure we are working with reputable companies who are obliged to keep your data safe and secure. Examples of this could include repairs operatives or credit reference agencies, and IT vendors who help us to store our data in secure data centre locations.
There may be situations where it’s necessary for us to share some of your information with external, (non data processor) organisations. Where this is the case, we will only make such disclosures when they are in line with our powers or obligations under the GDPR or where they’re required by law. Some of the organisations that we may share personal information with include, but are not restricted to:
We ensure the organisations above and any others we might share information with understand that personal information provided must be used only for the reasons specified and must be kept safe and secure. Our relationships with some of these organisations are also bound by contractual data sharing agreements.
In some cases we may be legally required to provide information to one of these other organisations – for instance, in certain circumstances we may be required to provide information about housing benefits to a local authority or central government departments.
We will never sell your personal information to third parties and we’ll do our best never to send out marketing information if people do not wish to receive it.
Data transfer to from the UK to the EEA and other countries, post Brexit.
The UK left the EU on 31 January 2020. The transition period ended on 31 December 2020. This has changed the rules on how data can leave and enter the UK lawfully and appropriately.
Coastal is monitoring the guidance issued by the Information Commissioner’s Office on this matter from time to time.
Should anyone have any questions or concerns regarding their data leaving the UK via Coastal, then please contact the DPO at your convenience, to discuss further.
We take the security of your data seriously. We have internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is only accessed by staff when carrying out their role. Staff training is provided. We limit access to your personal information to those who have a genuine business need to know, and those who process your information are subject to a duty of confidentiality. Where we use third parties to process personal data on our behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of your data.
Should there be a personal data breach that is likely to result in a high risk of adversely affecting a person’s rights and freedoms, we will inform them, without undue delay. If required, we will also report any personal data breach to the Information Commissioner’s Office, in accordance with their guidance on these matters.
In connection with managing a housing application, if you are unsuccessful, we hold your personal information for a period of up to 1 year after submission.
If you are successful in your application and take up a tenancy we retain your information during that time and for a period 6 years after you cease to be a tenant of Coastal. After 6 years, we’ll dispose of your personal information securely. Should we have to hold any of your personal information for longer than this, for example, on some of our computer systems, we’ll make every effort to anonymise it.
If you have consented to your data being processed and this is our lawful basis for processing, you can withdraw this consent at any time.
We will tell you in clear and plain language when we are collecting, using, or sharing information about you.
You have the right to know and see what information we hold on you. A written request is called a “Subject Access Request”. Usually, we must provide information within one month of your request.
You have the right to have incorrect or incomplete information corrected within one month. This includes any information we have shared with other companies processing data on our behalf.
You can request to be forgotten, but this would not be upheld where we have a right to hold information.
You can ask us to stop using your personal information if you are contesting the accuracy or use of the information. We have to stop processing this information until we have corrected it or established, we have a legal right to use it.
You can request certain information is shared with another organisation. This only applies to information that is carried out by automation and does not apply to the information we process.
You can object to us using your information, for example, residents objecting to direct marketing.
This applies to decisions made entirely by computers rather than staff and so does not really apply to Coastal at present.
If you would like to exercise any of these rights, please email: email@example.com
We do not make any decisions about you, using automated means and we do not envisage this changing in the near future. If the situation does change, we will notify you in writing.
Coastal has appointed Jamie Saunders as its Data Protection Officer to oversee compliance with this privacy notice.
If you have any questions about this privacy notice or how we handle your personal information, please email firstname.lastname@example.org .
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), who is the UK supervisory authority Information Commissioner’s Office
Information Commissioner’s Office – Wales
2nd floor, Churchill House
Cardiff CF10 2HH.
(t) 0330 414 6421 (e) email@example.com
We reserve the right to update this privacy notice at any time. We may also notify you in other ways from time to time about the processing of your personal information.
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This information can be provided to you via other means if you would prefer.
Implications of the United Kingdom’s departure from the European Union, (Brexit)
The European Union General Data Protection Regulation, (“GDPR”) is a European Union regulation and it no longer applies to the UK.
The GDPR has now been incorporated into UK data protection law as the UK GDPR so in practice there is little change to the core data protection principles, rights and obligations found in the UK GDPR.
The Data Protection Act 2018 continues to apply.
Coastal will continue to closely monitor guidance from the ICO to ensure any data transferred outside of the UK is done so appropriately.
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