Privacy Notice (ASB complainants)

What is the purpose of this privacy notice:

Six Town Housing Limited is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. You are being given a copy of this privacy notice because you have made a complaint about anti-social behaviour (ASB) relating to one of our tenants. It makes you aware of how and why your personal information will be used, namely for the purposes of carrying out our duties as a landlord, and how long we will usually keep your personal information for. It provides you with certain information that must be provided under the General Data Protection Regulation (EU) 2016/679 (‘the GDPR’) and the Data Protection Act 2018 (‘DPA’).

The types of information we collect and store:

In connection with your complaint about ASB, we will collect, store, and use the following types of personal information about you:

• Personal details such as your name, date of birth, address, contact details and contact preferences;
• Personal details of other members of your household;
• Personal details of any other witnesses of the ASB;
• Details of your complaint of ASB; and
• Any other information you provide to us as part of our investigation.

We will also collect, store and use the following types "special categories" of more sensitive personal information:

• Information about your race or ethnicity, religious beliefs, sexual orientation, trade union membership and political opinions;
• Information about your health, including any physical or mental health condition or disability; and
• Information about criminal convictions and offences.

How we collect personal information:

We collect and hold personal information relating to complaints of ASB from the following sources:

• You, the complainant;
• Other complainants, neighbours and witnesses;
• Other agencies such as the local authority, the police, emergency services, probation, other RPs, the NHS, health professionals, drug and alcohol services and charities.

How we use personal information:

We use this information to carry out our duties as a landlord. This includes:

To ensure that we meet our legal obligations efficiently and effectively, including those relating to the prevention and detection of crime and ASB, equality and diversity and health and safety;

• To ensure we protect individuals from the risk of harm or injury;
• To prevent and detect crime, fraud and ASB;
• To carry out our tenancy enforcement functions efficiently and effectively;
• To allow us to communicate with you effectively; and
• To monitor and improve our performance and delivery of services in tackling ASB.

The legal basis’ we rely on for processing personal information in this way are as follows:

• Consent has been obtained;
• Processing is necessary for the performance of a contract;
• Processing is necessary for compliance with a legal obligation; or
• Processing is necessary for our legitimate interests.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

How we share information relating to complaints of ASB:

We will not normally share your personal information with anyone else without your consent to do so.

However, there a certain circumstances where we will be required to share your information with other organisations and will comply with the GDPR and the DPA when disclosing this information.

Where it is required or necessary in accordance with current UK data protection legislation, we may share your personal information with:

• Family, associates and representatives of the person whose personal data we are processing;
• Suppliers and service providers;
• Central government;
• Auditors;
• Survey and research organisations;
• Other housing associations, trusts or local authorities;
• Health authorities;
• Enquirers and complainants;
• Security organisations;
• Health and social welfare organisations;
• Professional advisers and consultants;
• Homes England;
• Ministry for Housing, Communities and Local Government;
• Probation services;
• Charities and voluntary organisations;
• Police forces;
• Emergency services;
• Courts and tribunals;
• Professional bodies;
• Insurers.

How long we keep personal information:

We will keep the personal information you provide whilst we are investigating your complaint and we will also retain your personal information even after the end of the tenancy of the person you are complaining about if this is necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud or to enforce any outstanding debts owed to us.

A copy of our Records Management Schedule which details the retention periods for tenant information is available upon request.

Your right to access personal information:

You can find out if we hold any personal information about you by making a ‘subject access request’ under the GDPR.

If we do hold information about you, we will:

• Give you a description of it;
• Tell you why we are holding;
• Tell you who it has been disclosed to; and
• Let you have a copy of the information in an intelligible form.

You may also have the right for your personal information to be transmitted electronically to another organisation in certain circumstances. You can request access to the information we hold about you at any time by contacting us (please see contact details section below). Please mark your request for the attention of our Data Protection Officer.

Your rights:

If you believe that any of the personal information we hold about you is incorrect, you have the right to ask us to rectify that information at any time. You may also have the right, in certain circumstances, to request that we delete your personal information, to block any further processing of your personal information or to object to the processing of your personal information.

There are some specific circumstances where these rights do not apply and we can refuse to deal with your request. If we are processing your personal information based upon your consent, you have the right to withdraw your consent at any time. If you require any further information about your right to rectification, erasure, restriction of or object to processing or you wish to withdraw your consent please contact us (please see contact details section below).

Complaints:

We take any complaints we receive about the collection and use of personal information very seriously. We would encourage you to bring it to our attention if you think that our collection or use of information is unfair, misleading or inappropriate. You can make a complaint at any time by contacting us (see contact details section below).

If you think our collection or use of personal information is unfair, misleading or inappropriate or if you have concerns about the security of your personal information, you also have the right to make a complaint to the Information Commissioner’s Office. You can contact the Information Commissioner’s Office at the following address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Contact us:

You can e-mail us at enquiries@sixtownhousing.org or write to us at the following address: Six Town Housing, 6 Knowsley Place, Angouleme Way, Bury, BL9 0EL. We have appointed a Data Protection Officer to oversee our compliance with this privacy notice. Our Data Protection Officer is Claire Rybczynski. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO using the details above.