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Data Protection: Fair Processing Notice

Scottish Veterans Housing Association
GDPR Fair Processing Notice
(How we use your personal information)
This notice explains what information we collect, when we collect it and how we use this. During the course of our activities we will process personal data (which may be held on paper, electronically, or otherwise) about you and we recognise the need to treat it in an appropriate and lawful manner. The purpose of this notice is to make you aware of how we will handle your information.

Who are we?
Scottish Veterans Housing Association a Scottish Charity (Scottish Charity Number SC012739), a registered society under the Co-operative and Community Benefit Societies Act 2014 with Registered Number 1937 R(S)and having their Registered Office at 53 Canongate, Edinburgh EH8 8BS (“we” or “us”) take the issue of security and data protection very seriously and strictly adhere to guidelines published in the Data Protection Act of 1998 and the General Data Protection Regulation (EU) 2016/679 which is applicable from the 25th May 2018, together with any domestic laws subsequently enacted.

We are notified as a Data Controller with the Office of the Information Commissioner under registration number Z7524074 and we are the data controller of any personal data that you provide to us.

Any questions relating to this notice and our privacy practices should be sent to the Head of External Relations.

How we collect information from you and what information we collect

We collect information about you:
• when you apply for housing/support with us, become a tenant/resident, request services/ repairs, enter in to a support agreement with ourselves howsoever arising or otherwise provide us with your personal details
• when you apply to become a member;
• from your arrangements to make payment to us (such as bank details, payment card numbers, employment details, benefit entitlement and any other income and expenditure related information);

We collect the following information about you:
• name;
• address;
• telephone number;
• e-mail address;
• National Insurance Number;
• Next of Kin;
• Date of birth
• Details of your service in the UK Armed Forces
• Health information where it affects your support or allocation/adaptation of housing
• Information on the proceedings of any prosecution or pending prosecution
• Information relating to your support needs

We receive the following information from third parties:
• Benefits information, including awards of Housing Benefit/ Universal Credit
• Payments made by you to us;
• Complaints or other communications regarding behaviour or other alleged breaches of the terms of your contract with us, including information obtained from Police Scotland;
• Reports as to the conduct or condition of your tenancy, including references from previous tenancies, and complaints of anti-social behaviour
Why we need this information about you and how it will be used

We need your information and will use your information:

• to undertake and perform our obligations and duties to you in accordance with the terms of our contract with you
• to enable us to supply you with the services and information which you have requested;
• to enable us to respond to your repair request, housing application and complaints made;
• to analyse the information we collect so that we can administer, support and improve and develop our business and the services we offer;
• to contact you in order to send you details of any changes to our or supplies which may affect you;
• for all other purposes consistent with the proper performance of our operations and business; and
• to contact you for your views on our products and services.
Sharing of Your Information

The information you provide to us will be treated by us as confidential and will be processed only by our employees within the UK/EEA. We may disclose your information to other third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:
• If we enter into a joint venture with or merged with another business entity, your information may be disclosed to our new business partners or owners;
• If we instruct repair or maintenance works, your information may be disclosed to any contractor;
• If we are investigating a complaint, information may be disclosed to Police Scotland, Local Authority departments, Scottish Fire & Rescue Service and others involved in any complaint, whether investigating the complaint or otherwise;
• If we are updating tenancy/support agreement details, your information may be disclosed to third parties (such as utility companies and Local Authority);
• If we are investigating payments made or otherwise, your information may be disclosed to payment processors, Local Authority and the Department of Work & Pensions;
• If we are conducting a survey of our products and/ or service, your information may be disclosed to third parties assisting in the compilation and analysis of the survey results

Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.

Transfers outside the UK and Europe

Your information will only be stored within the UK and EEA

Security

When you give us information we take steps to make sure that your personal information is kept secure and safe.
Paper files are kept in locked cabinets in offices that are locked when not in use. Electronic files are kept on a server protected by a firewall and with access restricted by password control. Cloud based data (such as Better Futures) are held on secure servers and have access restricted by password. Our Data protection policy details our security measures and is available on request.

How long we will keep your information

We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you.
We will generally keep your information for the following minimum periods:
6 years for support plans and resident files
1 year for unsuccessful applications for accommodation
Complaints and some Health and Safety records that involve named residents/tenants are held permanently.
after which this will be destroyed if it is no longer required for the reasons it was obtained.
Our full retention schedule is available at each Residence Office and Head Office.

Your Rights
You have the right at any time to:
• ask for a copy of the information about you held by us in our records;
• require us to correct any inaccuracies in your information;
• make a request to us to delete what personal data of your we hold; and
• object to receiving any marketing communications from us.

If you would like to exercise any of your rights above please contact us at info@svronline.org
You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information. The Information Commissioner’s contact details are noted below:
The Information Commissioner’s Office – Scotland
45 Melville Street, Edinburgh, EH3 7HL
Telephone: 0131 244 9001
Email: Scotland@ico.org.uk

The accuracy of your information is important to us - please help us keep our records updated by informing us of any changes to your email address and other contact de