We collect and process personal information about our residents, Under the Data Protection Act (1998) (DPA), in order to provide housing management and other related services. Tower Hamlets Homes is a registered data controller with the Information Commissioners Office (ICO), our registration number is Z1261726.
This notice explains how we use your data and how we protect your privacy. As our services develop we will continue to update and review this statement to comply with both the law and customer feedback.
What is personal data?
Personal data is data related to a living individual who can be identified from that data, for example name and date of birth. Sensitive personal data is data which includes more specific information about the individual such as ethnicity or sexual orientation.
What data do we collect?
Tower Hamlets Homes collects data from you via a wide variety of sources including when you view one of our properties, sign a tenancy or licence agreement, purchase a leasehold, complete one of our forms, or when you call, write, email, or meet us, or respond to a survey. We may also collect information about you when you interact with us via social media, through our websites or via our MyTHH portal.
We hold information about every tenant and leaseholder of the properties we manage. We also hold information about the members of tenants’ households. This includes both personal data and sensitive data to ensure Tower Hamlets Homes can comply with the Public Sector Equality Duty under the Equalities Act 2010.
We record some telephone conversations with customers. This supports staff training and allows us to better respond to complaints and helps with learning. It will always be announced if the phone call is being recorded before you are connected with an advisor. We automatically keep recordings for one year after the phone call took place unless we need to keep a copy for a specific purpose; once the recording is no longer needed we will delete any and all copies.
Our email correspondence may be kept as a record of contact. If we need to share confidential information with external organisations such as Tower Hamlets Council, the police or social services we will ensure that information is appropriately protected.
CCTV is installed on some of our estates, offices, and customer service locations; they are fitted to monitor building security and crime prevention and detection. The main estate based CCTV is operated by Tower Hamlets Council for us and is stored by them. We operate our CCTV in accordance with the practice issued by the ICO. The DPA covers images of people and information about people derived from CCTV, for example a vehicle registration plate. Therefore, we will not hold images for longer than necessary and will dispose of them securely.
We also hold information about our employees, including prospective, current and former employees. All personal information is held securely, we have security measures and protocols in place to prevent it being accessed by any unauthorised person.
Why do we collect this information?
We collect and process your information so we can deliver effective housing services, statutory and otherwise. We do not want to be intrusive and will only collect the necessary information needed to effectively and efficiently run our services. The information you provide will not be accessed by or disclosed to anyone who shouldn’t see it.
Unless specifically advised otherwise, we will only collect and process your information in order to carry out these functions:
- Managing your tenancy or lease and the London Borough of Tower Hamlets or Tower Hamlets Homes property it relates to;
- Monitoring compliance in terms of your tenancy agreement;
- Delivering support to you or any member of your household within an agreed support plan;
- Collecting information in order to monitor our performance;
- Administering community grants;
- Providing associated welfare services, advice and support;
- Maintaining our accounts and records;
- Recruiting, supporting and managing our board, employees, agents and contractors;
- Promoting the services we provide;
- Carrying out surveys and conducting research;
- Local fraud initiatives;
- Corporate administration and all activities we are required to carry out as a data controller;
- Ensuring we meet our legal obligations.
Who we share with?
From time to time we may need to provide or obtain personal information relating to you or members of your household from third parties. However, this will only occur so we can achieve the purposes detailed above and deliver the best possible services. Furthermore, we may have to disclose your personal details if required by law or any Governmental body.
If we do share your information with other services we will have sharing protocols in place to ensure the organisation’s compliance with the DPA. We will not use your personal information for third-party marketing purposes without your prior express consent.
We try to deal with instances of rent or service charge arrears without the involvement of third parties. However, in cases of unresolved arrears, and cases where arrears remain outstanding after the termination of a tenancy agreement, we may disclose personal details to tracing and/or debt collection agencies.
How we store information?
We take our responsibility to the DPA very seriously and will adopt and maintain high standards in respect of handling personal information. Your personal information will only be collected if it is necessary and proportionate to do so. We have a number of safeguards in place to ensure your data is kept secure and safe. Methods such as encryption, access controls and staff security training are all designed to ensure that your data are only made available to those who have a right to see them.
With regard to disposal of your information, we follow local government recommend guidelines around retention periods. We will not hold your information for longer than we need to and when we dispose of it we will destroy paper and electronic copies in a secure way.
We aim to make our information easily accessible. For more information about our organisation check our publication scheme.
You are legally entitled to request access to any of your records that we hold about you. Information about how to request a Freedom of Information (FOI) or Subject Access Request (SAR) can be found here.
You have a right to request us to stop processing your data although we can refuse your request where you continue to be bound by the terms of your tenancy agreement and/or lease. There may also be some specific reasons, for example in the case of a crime occurring, where we are obliged under the law to hold your data.
For more advice or to make a complaint about the way in which Tower Hamlets Homes has processed your data you can contact the ICO.