Privacy Notice - Plymouth Community Homes Tenants
Plymouth Community Homes Tenants
Effective 11 June 2019
At Plymouth Community Homes (PCH) we are committed to ensuring that your privacy is protected, and that data is used in accordance with the data protection legislation in force in England and Wales.
This privacy notice sets out why we collect personal information from you, how we use it and who we may share it with. It also explains your individual rights under the current data protection legislation.
If we ask you to provide information which can identify you, then we will only use it in accordance with this privacy notice.
We may change this notice by updating it on our website. You should check the notice from time to time to ensure that you are happy with any changes.
Any queries regarding this notice and our privacy practices can be sent to the company Data Protection Officer by email using firstname.lastname@example.org or by writing to the Head of Governance, who is also the Data Protection Officer at -
Plymouth Community Homes
Alternatively you can telephone us on 0808 230 6500
Who we are
Plymouth Community Homes Limited is a registered housing provider. Our registration number is 30637R. Our registered office is Plumer House, Tailyour Road, Crownhill Plymouth, PL6 5DH
For the purposes of data protection legislation, Plymouth Community Homes Limited is a Data Controller
Why we collect information
We collect and process your information because you have entered into, or wish to enter into a contract (tenancy agreement) with us. This is generally the legal basis for processing your information and carrying out our activities. We need the information to help us assess and manage your tenancy and to provide the services you have requested from us.
There will also be times when processing personal information is necessary for a legitimate interest pursued by PCH or a third party. Where processing is being carried out because of a legitimate interest, this will be set out in the privacy notices. Some of the information that we hold will be with your consent – we will always make it clear when this is the case, and also explain how you can withdraw your consent.
What information we collect about you
We will collect the following information from you when it is needed to manage your tenancy. If you do not provide the information we need then you may not be able to hold a tenancy with us.
- Name and date of birth
- Similar details of people who occupy the property with you
We may also hold other information which is necessary to the management of your tenancy agreement that will vary on a case by case basis. This would be to help us resolve a tenancy management issue such as arrears of rent, alleged or actual anti-social behaviour, criminal activities or fraud. This information may also potentially be used to safeguard our staff or any risks to other people including children.
To help us to manage your tenancy and /or provide services to you we may also hold the following information about you:
- Contact details, such as telephone numbers and email addresses to help us communicate with you
- Marital status
- Information to confirm your identity, including photographic identification. We will add your photograph to your tenancy agreement in line with our tenancy fraud policy. Should your application not be successful, all photographs will be destroyed.
- Diversity information such as gender, ethnicity, cultural or religious beliefs/ needs and sexual orientation, to assist us with equality and diversity monitoring
- Information about disabilities, vulnerabilities and health and any other support needs. With your consent we use this information to tailor our service to better meet your particular circumstances and needs. We will also use the information when assessing the need for any adaptations within your property.
- Current financial information. With your consent 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. With your consent we may use this to apply for funding on your behalf.
- We may send you customer satisfaction surveys, which we will use to make improvements to our services. It is optional for you to respond to these surveys, and the information that you provide will be anonymised.
- We will collect demographic information such as preferences and interests, with your
- We will also ask for emergency contact details if you live in one of our Housing with Support properties and may ask for emergency contact details if you attend resident involvement meetings with us on a regular basis.
- We may ask for additional information, with your consent, in connection with resident involvement activities.
Most of this information will be supplied by you directly, although we may sometimes receive information from outside agencies
If you apply for a property with us, in addition to the above information, we need the following information before we will confirm the allocation of a property:
- Current address, previous address, and forwarding address
- Your application for rehousing, and confirmation that the details on it are correct
- Information to confirm your identity, including photographic identification
- National Insurance number
- Details of your financial circumstances, including employment details and welfare benefit entitlements
- Bank or building society details
- Other organisations who are involved with your household
- Details of criminal convictions or cautions against you or anyone on your application
If you move to a different property we will retain information as follows:
- If you move to another PCH property and start a new tenancy with us it is in our legitimate interests to retain all your previous tenancy information to assist with managing your current tenancy.
- If you move to a property which is not owned or managed by PCH we retain basic tenancy information as part of your contract in order that we can provide information in the event of you making an application under the right to buy or the right to acquire.
- If you purchase your property under the Right to Buy or Right to Acquire, we will retain the information used to confirm your identity and undertake anti-fraud and anti-money laundering checks
- If you move to a property which is not owned or managed by PCH it is in our legitimate interests to;
- Continue to hold details of any outstanding debt against your tenancy
- Your new contact details so we can discuss repayments with you
- Keep records of any anti-social behaviour that occurred during the course of your tenancy
How we collect your information
Plymouth Community Homes collects information from you via a variety of sources, including when you apply for one of our properties, complete one of our forms, write, call, email or meet with us or respond to a survey.
Telephone calls – telephone calls made to Plymouth Community Homes where a call management system is in place are recorded. A recorded message will tell you if your call will be recorded before the call starts.
Recordings of calls may be used, in pursuit of our legitimate interests, for the following reasons:
- For staff training to develop confidence and potential of staff and to improve services
- To check and measure whether we meet standards agreed with customers
- For use in appraisals with staff to develop better customer service
- As evidence where there are disputes
- As evidence in investigations concerning either our customers or staff
Access to call recordings is through sampling apart from training purposes or when abusive or threatening behaviour has occurred or a complaint has been made and requires investigation.
We may collect information when you use our social media sites, websites or self-service portal ‘MyPCH Account’. For more information refer to the separate Privacy Notice for PCH website users.
CCTV - We will also operate CCTV / sound recording in and around some properties in pursuit of our legitimate interests to provide a safe and secure environment for residents and to protect the general interests and well-being of all building users. For more information refer to the separate Privacy Notice for CCTV on PCH Estates.
We operate a CCTV system at Plumer House in pursuit of our legitimate interests of building security and the detection and prevention of crime. For more information refer to the separate Privacy Notice for CCTV at Plumer House
Photographs - We may take photographs at our events 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 also on occasion take photographs of our properties (including the interior). It is in the legitimate interest of PCH to record any issues within our properties, including where it is in a poor condition, to assist both the management of property and potentially your tenancy.
We may receive information about you from third parties including:
- Devon Home Choice in relation to your application for rehousing
- Your council or benefits office relating to your housing
- Credit agencies and Previous landlords when you apply for housing
- Police, welfare or support organisations dealing with you
- Councillors, MP’s or other representatives acting on your behalf or with your instruction
- Financial institutions when you apply for our services
Special Category Information
Under data protection legislation certain personal information is classed as special category. This is information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, data about sexual orientation.
We minimise our holding and use of special category personal information but, given the services we provide, there are times when we use it to understand our customers and their needs better.
We will normally only hold special category data with your explicit consent and you have a right to withdraw this consent at any time. However, if you do not wish us to process this data, it may have an impact on the services we provide to you.
On occasion we may also hold information about criminal convictions that are relevant to the management of your tenancy.
What we do with it
We may use your personal information as follows:
- To provide a service that you request as part of your tenancy agreement, for example, to provide a repairs service
- To understand your needs and provide you with a better and more supported service
- To comply with our legal obligations
- For internal record keeping
- To provide statutory statistical information
- To assess your application should you wish to purchase your home under the Right to Buy or Right to Acquire schemes.
- To survey you or undertake market research about our delivery of services for quality improvement and monitoring purposes
- To send you information about the work of Plymouth Community Homes and events in your area that might be of interest
- To customise the PCH website according to your interests
- We may also use this information for safeguarding our staff and residents
We may use your personal information to help decide whether the property you have bid for with Plymouth Community Homes is right for you in your current circumstances by:
- Undertaking tenancy reference checks
- Undertaking affordability checks
- Undertaking risk assessments
When you are no longer a tenant of Plymouth Community Homes we may use your personal information as follows:
- To confirm your occupancy of a property in the event of you making an application to buy a property under the Right to Buy or Right to Acquire
- To assess your suitability for housing with Plymouth Community Homes should you apply for one of our properties in the future
How long we keep your information
We will only store your information for as long as is reasonably necessary for us to fulfil the purposes set out in this notice. We will then securely dispose of your information.
- This is normally a maximum of six years after you cease to hold a tenancy with us.
- If when you leave a PCH tenancy there is an outstanding debt your information will be retained in pursuit of our legitimate interests in recovering that debt.
- We will retain basic tenancy information if required to do so by law, for example to assist with Right to Buy /Right to Acquire applications.
- Recorded telephone conversations are usually kept for up to 6 months. Recorded calls that are deemed abusive or threatening are kept until any investigation action is completed.
- CCTV footage is normally kept for a period of 28 days unless it is to be used in relation to allegations of anti-social behaviour or criminal activity, when it may be retained for a period of up to two years after any legal proceedings have finished.
If you have consented to having your photograph taken, consent given is valid for three years, after which the images and recordings will be either securely destroyed or archived. Group shot photographs will be archived and photographs of individuals securely destroyed. If we’d like to use any individual material after three years, we will contact you to ask if you would be willing to renew your consent.
Sharing your information
We will only share your information where we are legally obliged and able to do so, for example:
- To provide you with the services you require
- To comply with the law (e.g. police, health authorities, inland revenue, government departments)
- Where there is a clear health and safety risk
- Where we are requested to do so by another organisation in pursuit of its legitimate interests
- Child protection and safeguarding issues
- Where there is a clear risk to yourself, staff and others
- To seek legal advice or in connection with court proceedings or statutory action to enforce compliance with tenancy conditions
- For the detection and prevention of crime, prosecution of offenders and for the detection and prevention of fraud.
We may therefore share your information with third parties from time to time such as:
- Contractors providing maintenance and other housing related or support services
- Utility companies (water, electricity, gas)
- Consultants providing services to us
- Local Authorities (e.g. PCC)
- The NHS and Primary Care trusts
- Health professionals
- Partner landlords
- Ministry for Housing Communities and Local Government
- Legal advisors, the courts
- Solicitors for property conveyancing purposes
- Our insurers and auditors
- Language translation services
- Mediation partner organisations
- External assistance where you have agreed to a referral, e.g. to help with money problems
- Regulatory bodies, such as the Regulator of Social Housing
- Credit checking agencies and debt recovery agents
- Charities and voluntary organisations and our support partners
- A nominated third party where you have given us permission
- Banks to carry out payments through a secure system
- Companies that help us mail out newsletters etc.
- Training providers or learning organisations
We will share your name and address with Utility companies at the beginning of your tenancy. This is because we have a legitimate interest in ensuring that charges are directed to those responsible. We may also share information if you move, such as a forwarding address if requested to do so by the utility company.
We also share personal information with the Government for research and statistical purposes. For more information on what we share and why please see the Privacy notice for tenants/buyers of social housing (new) or Privacy Notice for all social housing tenants (existing)
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect and process.
Whilst the majority of the IT systems that we use are based within the UK, PCH does use the following, which means that your data may be stored electronically outside of Europe.
- Survey Monkey
- Microsoft Cloud
- Cloudview Mobile CCTV
Your Rights in relation to your personal data
In certain circumstances, Data Protection legislation gives you a number of individual rights in relation to your personal data. These are as follows:
- The Right to be Informed about how your data is managed – this right is met by this privacy notice and a range of other notices which relate to specific aspects of PCH, such as the CCTV privacy notice and the website privacy notice.
- The Right of Access to your personal information – so that you can be aware of and verify what personal data we hold. Click here for details on how to apply for this right.
- The Right of Rectification - to have any personal data corrected if it is inaccurate, incomplete or out of date.
- The Right of Erasure of your personal data – this only applies in certain circumstances, such as where you have given consent for us to hold information and you withdraw that consent.
- The Right to restrict processing – in certain circumstances you have the right to block or restrict how we process your data;
- The Right to data portability – which in certain circumstances allows you to obtain obtain and reuse your personal data for your own purposes across different services
- The Right to object - in certain circumstances, to the processing of personal data. In particular you have the right to object to being sent direct marketing information.
- The Right not to be subject to automated decision making – Plymouth Community Homes does not do this
If you wish to exercise any of the above rights, please contact:
Plymouth Community Homes
Alternatively you can make a request electronically, by email, to email@example.com. or telephone the Governance Team on 01752 388134 or 388152
Making a complaint
If you believe that Plymouth Community Homes has not handled your personal information correctly you have the right to make a complaint. You can raise a complaint in a number of different ways:
- To a PCH staff member
- At our offices at Plumer House, Tailyour Road, Crownhill, Plymouth, PL6 5DH
- Through our website
- Using social media
- At our shop at Frankfort Gate
- By telephone
- In writing
You also have the right to lodge a complaint with the Information Commissioners Office at.
Wycliffe House, Water Lane, Wilmslow,
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Plymouth Community Homes collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests should be sent to the PCH Data Protection Officer at the above address.
If you or someone you know would like this information in large print, braille, or translated into another language, please contact our Communications Team on 0808 230 6500 or email firstname.lastname@example.org
Plymouth Community Homes Group
Registered Office: Plumer House, Tailyour Road, Plymouth, PL6 5DH
Plymouth Community Homes Ltd is a registered society under the Co-operative and Community Benefit Societies Act 2014 (which consolidates the Industrial and Provident Societies Acts) and is registered with the Financial Conduct Authority (registration 30637R) and the regulator of Social Housing (registration L4543).
At the time of issuing this Notice, Plymouth Community Homes Ltd has three wholly owned subsidiaries, Plymouth Community Homes Manufacturing Services Ltd (PCHMS), company number 07001677, Plymouth Community Homes Regeneration Company Ltd (PCHR), company number 7272688 and Plymouth Community Homes Energy Ltd (PCHE), company number 8028170. All three subsidiaries are incorporated under the Companies Act 2006.
Tel: 0808 230 6500 / 01752 237990