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Data Protection: Fair Processing Notice

Data Protection: Privacy Notice
(How we use your personal information)

At Scottish Veterans Residences, we're committed to protecting and respecting your privacy.

This privacy notice explains when and why we collect personal information about you, how we use it, the conditions under which we may disclose it to others, how we keep it safe and secure and your rights and choices in relation to your information. We have additional Fair Processing Notices for our Tenants/Residents and our Employees.

Any questions regarding this privacy notice and our privacy practices should be sent to the Head of External Relations at Scottish Veterans Residences, Chief Executive Office, 53 Canongate, Edinburgh, EH8 8BS or Email: info@svronline.org.

• Who are we?
• How do we collect information from you?
• What type of information is collected from you?
• How and why is your information used?
• How long is your information kept for?
• Who has access to your information?
• Lawful Processing
• Your Rights
• Keeping your information safe
• Keeping your information up to date
• Use of 'cookies'
• Links to other websites
• Transferring your information outside of Europe
• Fundraising and Marketing Communications
• Your choices
• Changes to this privacy notice
• Review of this privacy notice

Who are we?

We’re Scottish Veterans Residences 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 our Registered Office at 53 Canongate, Edinburgh EH8 8BS.

We are a registered Data Controller with the Information Commissioner. Our registration number is Z7524074.

As a Registered Social Landlord in Scotland, Scottish Veterans Residences is a Public Authority for the purposes of Freedom of Information in regard to the following public functions:
• the prevention and alleviation of homelessness
• the management of social housing accommodation (i.e. where an RSL has granted a Scottish secure tenancy or short Scottish secure tenancy)
• supplying information to the Scottish Housing Regulator in relation to its financial well-being and standards of governance

Our Data Protection Officer is RGDP LLP who can be contacted at - info@rgdp.co.uk

How do we collect information from you?

We obtain information about you in the following ways:

Information you give us directly

For example, we may obtain information about you when you apply to become a tenant or resident, apply to become a member or visit our website.

If you apply for a job with us, we collect information about you from your job application. If you are successful in joining our team, we will also collect information from you in relation to your employment.

We will also collect contact details from our business partners, suppliers and contractors when we begin our business relationship with you.

Information you give us indirectly

Your information may be shared with us by third parties, which might include:
• subcontractors acting on our behalf who provide us with technical, payment or delivery services and our business partners.
• 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.

You should check any privacy policy/notice provided to you where you give your data to a third party, for example, when you post to our Facebook page.

We may collect your image from our CCTV cameras which are located in our premises.

When you visit our website

When you first enter our site we place analytics cookies on your device to help us understand how customers use our site. Our analytics cookies are provided by Google.

Google analytics collects the following types of information:

• technical information, including the type of device you’re using, the IP address, browser and operating system being used to connect your computer to the internet.
• information about your visit to this website, for example we collect information about pages you visit and how you navigate the website, i.e. length of visits to certain pages, products and services you viewed and searched for.

This information may be used to improve the services we offer.

For more information about how we use cookies please see the ‘Use of Cookies’ section below.

Social Media

When you interact with us on social media platforms such as Facebook and Twitter we may obtain information about you (for example, when you like or post on our Facebook page). The information we receive will depend on the privacy preferences you have set on those types of platforms.

What type of information is collected from you?

As well as protecting personal information about you, data protection laws recognise certain categories of personal information as sensitive and therefore requiring greater protection, for example information about your health, ethnicity and religion or any criminal convictions.

The personal information we collect, store and use depends on your relationship with us and might include:

If you are our tenant:

• 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

We may collect the following sensitive information:
• 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

Please also see above for details of how to access our separate Fair Processing Notice for tenants and residents.

If you are a member of our Board:

Your contact details and PVG disclosure.

If you volunteer with us:

Your contact details and PVG disclosure.

If you make a donation to our charity:

Your contact details and financial details relating your donation

If you are a Stakeholder:

Your contact details

If you apply for a job with us:

• your contact details, previous employment history and qualifications
• we may collect details of criminal records disclosure; your eligibility to work in the UK; ethnicity and health details – to comply with our legal obligations, for equalities monitoring and so that we can make any appropriate adjustments to your workplace

If you work for us:

• your contact details, previous employment history and qualifications; details relating to your pay, pension, attendance at work, and work performance, including any disciplinary or grievance records.
• we may collect details of ethnicity, disability and health – for equalities monitoring and so that we can make any adjustments to your workplace and manage your employment

Please also see above for details of how to access our separate Fair Processing Notice for employees.

If you are a business contact:

• We may collect your business contact details such as your name, business address and business e-mail and your company’s bank account details. If you are a sole trader this may be your personal details.

When you visit our website:

• information about your activities on our website and about the device used to access it, for instance your IP address and geographical location;
• any other personal information shared with us.

When you visit our premises:

• Your image may be captured by our CCTV cameras and static cameras (for example, when you sign in at our Head Office reception). Notices are available where the cameras are in operation.

How and why is your information used?

We may use your information for a number of different purposes, which may include:

• providing you with the services, or information you asked for;
• carrying out our obligations under any contracts entered into between you and us;
• keeping a record of your relationship with us;
• notifying you of changes to our services;
• seeking your views or comments on the services we provide;
• processing job applications.
• CCTV images - for security of our staff and residents and to assist with the prevention and detection of crime.
• For any legal obligations which apply to us
• To perform our task carried out in the public interest or in the exercise of official authority vested in us.

How long is your information kept for?

We keep your information for no longer than is necessary for the purposes it was collected for. The length of time we retain your personal information for is determined by operational and legal considerations. For example, we are legally required to hold some types of information to fulfil our statutory and regulatory obligations (e.g. health/safety and tax/accounting purposes).

We review our retention periods on a regular basis.

Who has access to your information?

We do not sell or rent your information to third parties.

We do not share your information with third parties for marketing purposes.

We may disclose your information to third parties in order to achieve the other purposes set out in this privacy notice. These third parties may include:

Third parties working on our behalf

We may pass your information to our third party service providers, suppliers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to carry out repairs to our buildings). However, when we use these third parties, we disclose only the personal information that is necessary to deliver the services and we have a contract in place that requires them to keep your information secure and prevents them from using it for their own direct marketing or any other purposes. Please be reassured that we will not release your information to third parties for them to use for their own purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

Other third parties we may work with

We may transfer your personal information to a third party as part of a sale, of some or all of our business and assets, to any third party or as part of any business restructuring or reorganisation, or if we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or to enforce or apply our terms of use or to protect the rights, property or safety of our staff, customers, users of the website or others. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

Lawful Processing

Data protection law requires us to rely on one or more lawful grounds to process your personal information. We consider the following grounds to be relevant:

Performance of a contract

Where we are entering into a contract with you or performing our obligations under it, such as when you sign up to a tenancy or purchase agreement with us.

For our employees we are processing for the contract of employment.

Legal obligation

Where necessary so that we can comply with a legal or regulatory obligation to which we are subject, for example where we are ordered by a court or regulatory authority like HMRC.

Vital interests

Where it is necessary to protect life or health (for example in the case of medical emergency suffered by an individual on our premises) or a safeguarding issue which requires us to share your information with the emergency services.

Specific consent

Where you have provided specific consent to us using your personal information in a certain way, such as to send you email, text and/or telephone marketing.

For the performance of a task carried out in the public interest or in the exercise of official authority vested in us .

When we are performing our public task in relation to the following functions:
• the prevention and alleviation of homelessness
• the management of social housing accommodation (i.e. where an RSL has granted a Scottish secure tenancy or short Scottish secure tenancy)
• supplying information to the Scottish Housing Regulator in relation to its financial well-being and standards of governance

When we use sensitive personal information (known as Special Category Data), such as health or ethnicity, we require an additional legal basis to do so under data protection laws, so will either do so on the basis of your explicit consent or another route available to us at law (for example, if we need to process it for employment, social security or social protection purposes, your vital interests, or, in some cases, if it is in the public interest for us to do so).

Your Rights

Under UK data protection law, you have certain rights over the personal information that we hold about you. Here is a summary of the rights that we think apply:

Right of access

You have a right to request access to the personal data that we hold about you.
You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply.

If you want to access your information, please send a description of the information you would like to see to the contact details below. We may ask for proof of your identity before proceeding with your request.

Right to have your inaccurate personal information corrected

You have the right to have inaccurate or incomplete information we hold about you corrected. The accuracy of your information is important to us so, if you change email address, or if you believe any of the other information we hold is inaccurate or out of date, please contact us via email or post (see below).

Right to restrict use

You have a right to ask us to restrict the processing of some or all of your personal information if there is a disagreement about its accuracy, or we're not lawfully allowed to use it.

Right of erasure

You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions; we will do so as far as we are required to. In many cases, we will anonymise that information, rather than delete it.

Right for your personal information to be portable

If we are processing your personal information (1) based on your consent, or in order to enter into or carry out a contract with you, and (2) the processing is being done by automated means, for example, via you completing a form on our website, you may ask us to provide it to you or to another service provider in a machine-readable format.

Right to object

You have the right to object to processing where we are using your personal information (1) for the performance of a task carried out in the public interest or in the exercise of official authority vested in us, (2) for direct marketing or (3) for statistical/research purposes.

If you want to exercise any of the above rights, please email us at info@svronline.org or write to Head of External Relations at Scottish Veterans Residences, Chief Executive Office, 53 Canongate, Edinburgh, EH8 8BS: i.

We may be required to ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.

Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK’s Information Commissioner’s Office.

Keeping your information safe

When you give us personal information, we take steps to ensure that appropriate technical and organisational controls are in place to protect it.

We undertake regular reviews of who has access to information that we hold to ensure that your personal information is only accessible by appropriately trained staff, volunteers and contractors.

Keeping your information up to date

We take reasonable steps to ensure your information is accurate and up to date; however we really appreciate it if you let us know when your contact details change.

Using our website

Use of ‘cookies’

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets us know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use Google Analytics traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Google Analytics collects the following types of personal data:
• Online identifiers including cookie identifiers
• internet protocol addresses and device identifiers
• client identifiers

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. You can find out how to disable cookies at the Information Commissioner’s website https://ico.org.uk/your-data-matters/online/cookies/.

Links to other websites

Our website may contain links to other websites run by other organisations. This privacy notice applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other websites even if you access those using links from our website.

In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the privacy notice of that third party site.

Transferring your personal information outside of Europe

As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Economic Area (“EEA”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EEA. You should be aware that these countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this privacy notice.

If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.

Fundraising and Marketing Communications

Email, text, phone

We will only send you marketing communications by email, text and telephone if you have explicitly provided your prior consent. You may opt out of our marketing communications at any time by clicking the unsubscribe link at the end of our marketing emails.

Post

We may send you marketing and fundraising communications by post unless you have told us that you would prefer not to hear from us.

Your choices

You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us then you can select your choices by ticking the relevant boxes situated on the form used to collect your information.

We’re committed to putting you in control of your data so you’re free to change your marketing preferences (including to tell us that you don’t want to be contacted for marketing purposes) at any time using: info@svronline.org or write to Head of External Relations at Scottish Veterans Residences, Chief Executive Office, 53 Canongate, Edinburgh, EH8 8BS:

We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted and will retain your details on a suppression list to help ensure that we do not continue to contact you. However, we may still need to contact you for administrative purposes like where we are processing your payment or notifying you of changes to your tenancy agreement.

Changes to this privacy notice

Any changes we may make to this privacy notice in the future will be posted on this website so please check this page occasionally to ensure that you're happy with any changes. If we make any significant changes to the way we process your personal data, we'll make this clear on this website.

Review of this privacy notice

We keep this privacy notice under regular review. This privacy notice was last updated in November 2019.