Adullam Homes Housing Association Ltd, generates records from our contact with you, including records of some personal information which is subject to the General Data Protection Requirements – GDPR.
Our privacy notice covers the following areas, to explain our approach to GDPR.
How Adullam collects personal information
This privacy notice tells you what to expect when Adullam Homes collects personal information. Adullam Homes collects information from you via a variety of sources, contractually as part of supporting people via forms and data sharing protocols locally and regionally, phone calls, emails, written communication, verbally or via other digital methods.
We operate a continuous CCTV system at our office premises for the detection and prevention of crime and recordings are held for a minimum of 2 weeks with a maximum of 4 weeks. CCTV / sound recordings and / or use photography may be used to capture evidence of breach of tenancy, alleged anti-social behavior or crime.
Photographs may be taken and used for general marketing providing individuals give consent for business related purposes.
Who visits our websites and uses our services?
- people who use our services, such as our tenants, residents and service users
- people who notify or send us information protected by GDPR
- job applicants and our current and former work colleagues
- external providers/stakeholders
- complainants and other individuals in relation to data protection or who seek to file a Subject Access Request (SAR) or enquiry
Visitors to our website
When someone visits the website, we may collect standard internet log information and details of visitor behaviour patterns. We may do this to find out things such as the number of visitors to the various parts of the site. We may collect this information in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting our website. We will not associate any data gathered from this site with anything personally identifying information from any source. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it and always ask for consent.
Our website search is powered by a tool that is part of our website – queries and results are logged anonymously to help us improve our website and search functionality. No user-specific data is collected by either Adullam Homes or any other third party.
People who email us
Any email sent to us, including any attachments, may be monitored and used by us for reasons of contract compliance, security and support. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
People who make a complaint to us
On receipt of a formal complaint, we record the details of the complaint. This normally contains the identity of the complainant, the organisation they represent, and any other individuals involved in the complaint.
Adullam will use personal information disclosed to record the complaint and to progress any investigation. We do compile reports and publish statistics for complaints we receive, but not in a form which identifies anyone.
We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our retention policy. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us, we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
People who use Adullam’s services
We have to hold the details of the people who have requested the service in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who have requested support or to carry out a survey to find out if they are happy with the level of service they have received.
What personal information Adullam collects and how we use it
We may collect the following information about you:
- Contact details including title, name, postal and email addresses, postcode, contact telephone numbers.
- Economic status
- Primary needs
- Date of birth
- National Insurance number
- Demographic information.
Sharing your personal information with third parties
Adullam Homes shares limited personal data with our contractors who are carrying out services on our behalf. Our contractors are required to comply with the law to ensure data is managed appropriately and for specified purposes, including emergency, responsive or planned property repairs.
Adullam Homes may need to share personal information with our commissioners, government departments and agencies, with our regulator and auditors, with utility companies or with other organisations and agencies where we are legally required to do so. We may disclose your personal information to:
- Any third party where we are under a legal duty to do so, or in order to enforce or protect any of our rights, property or safety (or those of our customers). This includes exchanging information with other companies and organisations for the purposes of fraud
Where personal information is processed on our behalf by third parties, we put measures in place to keep your information secure such as local data sharing protocols bound by contracts, email encryption and the use of password protected emails.
Security – Adullam Homes takes the security of any personal information we hold very seriously. Where necessary, and in common with other websites and apps, we state what encryption devices we use to ensure that personal information provided to us is not visible to anybody else.
In addition, our web server is hosted by an external party giving us a true barrier to our file server and databases. All of our servers are hosted in a Tier 3 Datacentre in a secure environment with high levels of physical security. We also operate a routine (daily) check on the whole infrastructure making sure we operate efficiently at all times.
Job applicants – When individuals apply to work at Adullam Homes, we will only use the information they supply to us to process their application and to monitor recruitment statistics. Where we want to disclose information to a third party, for example where we want to take up a reference or obtain a ‘disclosure’ from the Criminal Records Bureau we will not do so without informing them beforehand unless the disclosure is required by law.
Personal information about unsuccessful candidates will be held for twelve months after the recruitment exercise has been completed, it will then be destroyed or deleted. We retain de-personalised statistical information about applicants to help inform our recruitment activities, but no individuals are identifiable from that data.
Employees – we have a privacy statement for employees and workers which provides further details. If you require access to this, please contact our HR department on 0121 500 2823
Complaints/Compliments and other queries
Adullam Homes tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any compliments you may have about the services we provide and suggestions for improving what we do to be the best we can.
Access to personal information
Adullam tries to be as open as it can be in terms of giving people access to their personal information. Individuals can ask for this personal information by making a ‘subject access request’ under GDPR. If we do hold information about you, we will:
- give you a description of it.
- tell you why we are holding it.
- tell you who it could be disclosed to; and
- let you have a copy of the information in an intelligible form.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove personal information you think is inaccurate by contacting us.
You have the right to request a copy of the personal information that we hold about you. There will be no charge for this service. To make a request to Adullam Homes for any personal information we may hold you need to put the request in writing addressing it to our Data Protection Officer or writing to the address provided below. We will respond within one month of receiving your request. 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.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
Disclosure of personal information
In many circumstances we will not disclose personal data without consent. However, when we investigate a complaint, for example, we may need to share personal information with the organisation concerned and with other relevant bodies. For example:
- agreements we have with other organisations for sharing information.
- circumstances where we can pass on personal data without consent for example, to prevent and detect crime and to produce anonymised statistics.
- our instructions to staff on how to collect, use and delete personal data; and
- how we check that the information we hold is accurate and up to date.
You may withdraw your consent to use any information that was previously provided with your consent. Where your data is no longer required for the purpose for which it was originally collected, you have the right to request that we delete your data. This is sometimes known as ‘the right to be forgotten.’ If you believe this applies to your data and you would like us to delete it, please contact Adullam Homes.
Where you contest the accuracy of the data that we hold about you, where you have objected to the processing that we carry out in pursuit of our legitimate interest, or where we no longer require your data but you do need it for a legal claim, you have the right to block or suppress our processing of your data. This means that we will cease our normal processing of your data and process only the minimum to ensure that the restriction is respected going forwards. We will continue to store your data. If you believe this applies to your data and you would like us to restrict our use of it, please contact Adullam Homes.
You have the right to a structured, commonly used and machine-readable copy of your personal data. You have the right to have this data delivered to you or to a third party of your choice.
You can find more information about your rights, and data protection in general, on the website of the Information Commissioner’s Office here: https://ico.org.uk
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.
We will not transfer or store your personal data outside of Europe (the European Economic Area) outside of the control of the UK / European regulations.
Please be advised that we may need to collect data about your health status in regard to Coronavirus/Infection Control as we have a public duty to ensure we contain/delay the spread of virus and bacterial borne diseases. We will store this data securely on our housing system for residents and in our system-based storage files in relation to employees and we will keep it for a period of six months or in line with the UK government guidance if longer. We may also need to share this data with the government or relevant contractors but will only do so when necessary to carry out our role as a responsible landlord and employer, in line with current government advice.
Links to other websites
This privacy statement does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.
Changes to this privacy notice
We keep our privacy notice under regular review and has been reviewed in line with the General Data Protection Requirement which came into effect in May 2018.
If you want to request information about our Data Protection Policy, or make a Subject Access Request (SAR) you can contact your local office direct or write to:
Data Protection Officer
Adullam Homes Housing Association Ltd
Walter Moore House
34 Dudley Street
This privacy notice was produced by following information on the Information Commissioners website.
Regulator of Social Housing – LH1388
VAT Registration number – 238944764
Information Commissioners Office number – Z5338327