YHN Privacy Notice Update 2020

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Privacy Notice At Your Homes Newcastle (YHN), we’re committed to protecting and respecting your privacy. General Statement This Notice explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure. Our Policy applies to information about applicants, leaseholders, customers and other service users. By giving YHN your information or by using our website you are confirming that you’re agreeing to be bound by this Policy. We will update this Notice on a regular basis so we recommend that you occasionally review this privacy statement to ensure you are aware of any changes that may be relevant to you. If you have any questions about this Notice and our privacy practices please contact us by emailing informationgovernance@yhn.org.uk, telephoning: 0191 278 8600, or in writing to: YHN House, Benton Park Road, South Gosforth, Newcastle Upon Tyne, NE7 7LX. Who are we? Your Homes Newcastle is an Arm’s Length Management Organisation (ALMO) of Newcastle City Council (NCC). We manage housing and leasehold on behalf of the council and housing on behalf of Leazes Homes. YHN is registered with the Information Commissioner’s Office as a Data Controller under reference 5076256. We have an appointed Data Protection Officer (DPO) to oversee our processing to ensure we respect your rights and follow the law. If you have any concerns or questions about how we look after your personal information, or you require this information in another format, please contact the DPO, Phil Slater at dataprotection@newcastle.gov.uk or by calling 0191 211 6500. Changes to this Privacy Notice We will review and update this Privacy Notice in accordance with any changes to our processing. If we make any significant changes which alter the terms upon which you have agreed, we will post notice of the change on our website and you will be deemed to have accepted such changes. This privacy notice was last updated September 2020.

Why do we collect and store personal information? We need to collect, process and store personal information about you and other household members or sometimes relatives* in order to fulfil our obligations as a landlord and to deliver efficient and effective services. *When you provide information about household members or relatives, it is your responsibility to ensure this is done with their full knowledge and consent. How do we collect information about you?


The methods by which we collect personal information are: 

Website

Call centre

Personal interviews

Application forms

Data from third parties

How do we manage your personal information? Processing of your personal information will be undertaken in accordance with the principles of the UK Data Protection Act 2018 and the General Data Protection Regulation. Access to personal information is restricted to authorised individuals on a strictly need to know basis. We will treat your personal information fairly and lawfully and we will ensure that information is:  Processed for limited purposes  Kept up to date, accurate, relevant and not excessive  Kept no longer than is necessary  Kept secure. We are committed to keeping your personal details up to date and we encourage you to inform us about any changes needed to ensure your details are accurate. To help us to ensure confidentiality of your personal information we may ask you security questions to confirm your identity when you call us and may be necessary when we call you. Anyone calling on your behalf will require prior written authorisation and may also be subject to security questions to ensure we’re taking adequate steps to protect your personal information. We will not discuss your personal information with anyone other than you, unless you have given us prior written authorisation to do so. We may apply markers to your information (for example, in relation to your vulnerability or health status) to enable us to tailor and deliver services to you. We only hold records during the period of our relationship with you and for a set period afterwards to allow us to meet our legal obligations including resolving any follow up issues between us. What information do we hold about you?


The information we hold on our records relates to our relationship with you. For example:  We hold names and dates of birth, photographic ID and information about your previous housing circumstances to assess housing applications  We hold your contact details so we can communicate with you, and keep you informed about other services we offer that may be useful to you  We record information about your needs and requirements to ensure our services are accessible; that we take into account any support needs.  We record information to help us deliver housing management services including reports of anti-social behaviour, complaints and change in circumstances, for example, if you need to move home.  We keep financial records about the amount of money you have paid us; any amount(s) outstanding and associated recovery action. Depending on your chosen method of payment we may hold your bank details  We may hold recordings of your telephone calls to us as some calls to our business are recorded for training and monitoring purposes. This is to ensure we’re delivering a good service and to assist in dispute resolution  We may capture your image on CCTV if you visit an estate, scheme, office or community venue which is covered by this facility  We may analyse data we hold and carry out insight and satisfaction surveys to help us monitor our performance and improve our services to customers.  Special category data such as health, sexual orientation, race and religion may be used for equality and monitoring purposes. This list is not exhaustive, as we hold records of most contact we have with you, or about you, and we process this information, so we can deliver services to you. Generally, the information we hold will have been provided by you (on application or enquiry forms or when we communicate with you), but we may also hold information provided by third parties where this is relevant to your housing circumstances for example from social workers and health professionals (such as doctors and occupational therapists). We will only ask for personal information that is appropriate to enable us to deliver our services. In some cases, you can refuse to provide your details if you deem a request to be inappropriate. However, you should note that this may impact our ability to provide some services to you if you refuse to provide information that stops us from doing so. The types of information collected from you can be categorised as: Personal information


This information could be used to identify you as an individual:  Name (including previous names)  Date of birth  Marital status  Nationality  Residential status  National insurance number. Sensitive personal information / special category information In order to access some of YHN’s services and for legislative purposes it may be necessary to collect your sensitive personal / special category information, which may include:  Gender  Race  Ethnicity  Physical or mental health needs  Income and outgoings  Bank details. Sensitive information about health, sexual orientation, race and religion is subject to particularly stringent security and confidentiality measures. Criminal convictions and offences To manage your tenancy, it may be necessary for applicants and existing tenants to disclose their unspent criminal convictions and offences. Personal contact information This is the information that you have given us in order that we are able to contact you, this includes:  Telephone numbers  Email address  Alternative postal addresses


 Next of kin or appointed representative. Customer feedback This is the information you voluntarily share with us about your experiences of YHN and includes unsolicited comments, suggestions and feedback which is typically collected in surveys, contact forms. What is the lawful basis for processing information? Our lawful bases for processing your information for all the above purposes: 

Contract: Processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.

Legal obligation: Processing is necessary for us to comply with the law (not including contractual obligations).

Vital interests: Processing is necessary to protect someone’s life.

Legitimate interests: Processing is necessary for our legitimate interests, or the legitimate interests of a third party, unless there is a reason to protect your personal data which overrides those legitimate interests.

Consent: You have given clear consent for us to process your personal data for a specific purpose.

Public task: the processing is necessary for us to perform a task in the public interest or for official functions, and the task or function has a clear basis in law. Under what circumstances will data be shared? Normally, only our employees will be able to see and process your personal information. However, there may be times when we will share relevant information with third parties. When sharing personal information, this will be done on a strictly need to know basis and we will comply with all aspects of the Data Protection Act and the General Data Protection Regulation. Where necessary or required, we may share your personal information as follows:  With our contractors to undertake some repairs, maintenance or improvement works


 With third party service providers in connection with services performed on our behalf. For example, if we use a mailing house to distribute our newsletters  Our relationships with such providers are governed by our contracts with them which include strict data sharing and confidentiality protocols  With other registered providers, trusts and landlords in connection with tenancy references and associated enquiries  With community partners in connection with the delivery of coordinated local services  With utility companies (and their representatives) and Council Tax Offices to ensure billing details are correct  With credit reference agencies and debt collection agencies in connection with housing sales and in relation to any outstanding charges  With local authorities and government departments as necessary for administering justice, or exercising statutory, governmental or other public functions  With police and other relevant authorities (for example: Probation Service, DWP, HMRC and Cabinet Office NFI.) in relation to the prevention or detection of crime and fraud; the apprehension or prosecution of offenders and the assessment or collection of tax or duty  With other statutory organisations, for example social services and health authorities as necessary for exercising statutory functions  With the Ministry of Housing, Communities and Local Government to comply with our regulatory obligations  With our insurers, in the case of public liability claims and similar  With our solicitors  With Banks, for example, to carry out payments through a secure system  With mediation and advocacy partner organisations This list is not exhaustive as there are other circumstances where we may also be required to share information, for example:  To meet our legal obligations  In connection with legal proceedings (or where we are instructed to do so by Court Order)  To protect the vital interests of an individual (in a life or death situation).


 With mediation and advocacy partner organisations. How will personal information be protected? We are committed to ensuring your information is secure. At all times YHN will take technical and organisational measures to protect the confidentiality and security of personal information, irrespective of the method of collection, transfer or storage. Will personal information be transmitted internationally? We do not envisage transferring any information about you or relating to you to any organisation who is located outside of the European Economic Area other than indicated above and we have a commitment from our business partners and data processors that they will honour this commitment. What about children's data Children’s data is collected and processed in accordance with the information above. Parents, guardians and adults acting in place of a parent are expected to ensure that children they are responsible for are aware of how their personal information will be processed by us. What rights do I have about my personal information and how it is used? You have rights under the Data Protection Act and the General Data Protection Regulation regarding the information YHN processes. These rights include: 

Marketing – If we ever perform any direct marketing, we will ask you when we collect your personal data if we can use your information for such purposes or if we can disclose information to any third party for such purposes. You can opt out of receiving such marketing at any time. Right of access – You have the right to access the personal information that we hold about you; to know what we hold, what format it is in, and have a copy of it if you wish. This is called a Subject Access Request (SAR)This is a more formal process than, for example, requesting something like a copy of your rent statement. Our staff will explain when your enquiry falls under the Subject Access Process.

Right to rectification– If the information we hold on you is incorrect you have the right to ask us to correct it quickly and free of charge. You can exercise this right at any time by contacting us. There may be occasions where we require additional information in order to process your request such as a name change needing proof of the change of home. You will be required to specify the information that is incorrect and what it is to be replaced with.

Right to erasure/Right to be forgotten – You have the right to request that all data held by YHN which identifies you is deleted. You can make this request at any time by contacting us but please be aware that we must retain some of your information due to specific legislative or regulatory requirements.


Consent – In some cases YHN will require your specified consent to process your information, in these occasions consent will be recorded, and you have the right at any time to withdraw consent. This will include photographs taken for use on our website or in our publications. How long will personal data be kept? We will only hold your data for as long as reasonably necessary and in line with our Data Retention Schedule. This does mean that your data, where necessary will be retained for a period of time after you have stopped using YHN’s services. Cookie Policy What Are Cookies Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests. For more general information on cookies see the Wikipedia article on HTTP Cookies. How We Use Cookies We use cookies for a variety of reasons detailed below. Unfortunately, in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case, they are used to provide a service that you use.

The Cookies We Set The cookies used on the Your Homes Newcastle website have been categorised based on the categories found in the ICC UK Cookie guide: Category 1: Strictly necessary cookies: These cookies enable services you have specifically asked for. These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided. WE DO USE THIS CATEGORY OF COOKIE ON OUR SITES Category 2: Performance cookies: These cookies collect anonymous information on the pages visited. These cookies collect information about how visitors use a website, for instance which pages


visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works. By using our website, you agree that we can place these types of cookies on your device. WE DO USE THIS CATEGORY OF COOKIE ON OUR SITES Category 3: Functionality cookies: These cookies remember choices you make to improve your experience. These cookies allow the website to remember choices you make (such as your username, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. By using our websites, you agree that we can place these types of cookies on your device . WE DO USE THIS CATEGORY OF COOKIE ON OUR SITES These are the cookies used on our site:

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These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and

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therefore anonymous. It is only used to improve how a website works.

Cookie Banner

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This cookie is created when a user has accepted the cookie policy so that the banner isn’t displayed again.

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Disabling Cookies You may be able block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon you visit our site. To opt out of being tracked by Google Analytics across all websites visit Google opt out More Information Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren’t surewhether you need or not it’s usually safer to leave cookies enabled in case it does interact with one of the features you use on our site.


However, if you are still looking for more information than you can contact us via the contact methods below. Further information For further information on how to request your personal information and how and why we process your information, you can contact us using the details below: Email: informationgovernance@yhn.org.uk Phone: 0191 278 8600 In writing: Information Governance Team, YHN House, Benton Park Road, South Gosforth, Newcastle Upon Tyne, NE7 7LX. The Information Commissioner (ICO) is also a source of further information about your data protection rights. The ICO is an independent official body and one of their primary functions is to administer the provisions of the UK Data Protection Act 2018 and the EU General Data Protection Regulation. You also have a right to lodge a complaint about any aspect of how we are handling your data with the ICO and can do so at the following address: Online: www.ico.org.uk Phone: 0303 123 1113 In writing: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF


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