Privacy Notice – Fair Processing

This privacy notice sets out who we are, what data we collect about you and how we use the data we collect. It will provide you with information about your rights under the General Data Protection Regulation (EU) 2016/679 [GDPR] and the Data Protection Act 1998 (as amended) [the Data Protection Legislation]. It will also tell you how to action these rights.

In order to register your need for housing we need to process the personal information (data) that you provide in your application. This information will be held either on paper or electronically. 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.

1. Who we are

Homehunt Partners is a group of individual landlords, consisting of the following:

Berwickshire Housing Association, a Scottish Charity (Scottish Charity Number SCO42342), a registered society under the Co-operative and Community Benefit Societies Act 2014 with Registered Number 2482R(S) and having its Registered Office at 55 Newtown Street, DUNS TD11 3AU.

Castlehill Housing Association, a Scottish Charity (Scottish Charity Number SCO13584), a registered society under the Co-operative and Community Benefit Societies Act 2014 with Registered Number L0968 and having its Registered Office at 4 Carden Place Aberdeen.

Castle Rock Edinvar Housing Association, a Scottish Charity (Scottish Charity Number SC006035) and part of the Places for People Group.

Eildon Housing Association, a Scottish Charity (Scottish Charity Number SCO15026), a registered society under the Co-operative and Community Benefit Societies Act 2014 with Registered Number 1757R(S) and having their Registered Office at The Weaving Shed, Ettrick Mill, Dunsdale Road, Selkirk TD7 5EB

East Lothian Housing Association, a Scottish charity and registered social landlord under the Housing (Scotland) Act 2001 (Scottish Charity Number SC028900). Registered under the Co-operative and Community Benefit Societies Act 2014 No. 2266R(S)

Grampian Housing Association Limited, a registered society under the Co-operative and Community Benefit Societies Act 2014 (Registered Number 1769R(S)), a recognised Scottish Charity (Charity Number SC042023) and having its registered office at Huntly House, 74 Huntly Street, Aberdeen, AB10 1TD.

Link Housing Association Limited, part of Link Group Limited. Link Group Limited is a registered society under the Co-operative and Community Benefit Societies Act 2014, Registered Number: 1481 R(S), Registered Office: Link House, 2c New Mart Road, Edinburgh, EH14 1RL. It is a Charity registered in Scotland, Charity Number: SC001026 and a Registered Social Landlord with the Scottish Housing Regulator, Registration Number: HAL 148

Ochil View Housing Association Ltd, a Scottish Charity (Scottish Charity Number SC033130, a registered society under the Co-operative and Community Benefit Societies Act 2014 with Registered Number 2310R(S) and having their Registered Office at Ochil House, Marshill, Alloa FK10 1AB.

Sanctuary Scotland Housing Association Limited, a Registered Social Landlord - HEP 302 and a Property Factor registered in Scotland (No PF000124) and having their Registered Office at Sanctuary House, 7 Freeland Drive, Glasgow G53 6PG. Registered Society No 2508RS and a charity registered in Scotland No. SC024549. Sanctuary Scotland Housing Association Limited is a subsidiary of Sanctuary Housing Association.

Each landlord is registered as a data controller with the Information Commissioner’s Office [ICO]. The terms “we” and “us” in this document refer to any or all of these partner landlords.

Homehunt is the operating name for our choice based lettings system that is provided by Housing Partners Limited. Housing Partners Limited is also registered as a data controller with the Information Commissioner’s Office.

As all of the landlords may have access to your data, dependant on your selections, each landlord in the list and Housing Partners Limited has entered into Data Processing Agreements with the others. This agreement sets out how and why information may be shared. This ensures that we can provide you with the services you expect from us at the same time as meeting our data protection obligations.

The data protection principles set out how your personal data should be managed.

Principle	What Homehunt Partner landlords have to do
1. Lawfulness fairness and transparency	We need to be clear and upfront about what we use your data for.
2. Purpose limitation	We will only use your data for specific reasons which are set out in this guide.
3. Data minimisation	We will only collect data which is necessary for us to provide a service to you and will delete data when it becomes out of date.
4. Accuracy	We will ensure that any personal data we collect is correct and up to date.
5. Storage limitation	We will keep only what’s necessary in line with our Data Retention Schedule.
6. Integrity and confidentiality	We will ensure we have appropriate security to protect the data we process about you.

We aim for this privacy notice to be clear but comprehensive and provide you with all the information you need to understand how we will manage your data.

2. What is Data

Personal Data means any identifiable information about a living person. This can include:

- Name
- Address
- Telephone Number
- Date of birth
- Household composition

Special categories of personal data are defined as personal data relating to a person’s:

- Racial or ethnic origin
- Political opinions
- Religious or other beliefs
- Trade Union membership
- Health
- Sex life or sexual orientation
- Genetic or biometric data used to uniquely identify a person

As Homehunt Partner landlords are controllers of your personal data, they are responsible for the safeguarding of the data you provide. When you register you will be asked to identify which landlord you want as your ‘lead’ landlord.

What are the conditions of processing?

The conditions of processing mean that there needs to be a lawful reason for processing your data. We have to make it very clear why we process your data and the reason must fall into one of the following conditions.

For Personal Data

Consent	You have given your consent to the processing of your personal data.
Contractual	Processing of personal data is necessary for the performance of a contract with you or for Homehunt Partners to take pre contractual steps at your request.
Legal Obligation	Processing of personal data is necessary for Homehunt Partners to comply with a legal obligation.
Vital Interests	Processing of personal data is necessary to protect your vital interests or another individual's vital interests (this means life or death situations).
Public Task	Processing of personal data is necessary for the performance of a task carried out in the public interest or in the exercise of official authority conferred on Homehunt Partners
Legitimate Interests	Processing is necessary for Homehunt Partners’ legitimate interests or a third party's legitimate interests, unless these interests are overridden by your interests or fundamental rights.

For Special Categories of Personal Data

Explicit Consent	You have given your explicit consent to the processing of your personal data.
Employment Law	Processing is necessary for carrying out obligations under employment, social security or social protection law.
Vital Interest	Processing is necessary to protect your vital interests of or another person's vital interests where the data subject is physically or legally incapable of giving consent.
Legal Claims	Processing is necessary for the establishment, exercise or defence of legal claims.
Public Interest	Processing is necessary for reasons of substantial public interest, under law.
Medical Diagnosis and Treatment	Processing is necessary for the purposes of the provision of health or social care or treatment or the management of health or social care systems.

3. Your Rights

You have a number of rights under the Data Protection Legislation which are outlined and explained below.

The right to be informed how your personal data is processed

This guide informs you how your data will be processed and sets out clearly Homehunt Partners’ lawful basis for processing.

The right to access your personal data

You can submit a Subject Access Request to access the personal data that any Homehunt Partner landlord holds about you. You can do this by writing to your nominated lead landlord at the following address:

Berwickshire Housing Association: The Data Protection Officer, Berwickshire Housing Association, 55 Newtown Street, DUNS TD11 3LS. Email: data@berwickshirehousing.org.uk

Castlehill Housing Association: Gail Robertson (Director of Housing Services), Castlehill Housing Association, 4 Carden Place, Aberdeen AB10 1UT. Email: info@castlehillha.co.uk

Castle Rock Edinvar Housing Association: Data Protection Officer, Castle Rock Edinvar, 1 Hay Avenue, Edinburgh EH16 4RW. Email: dataprotection@castlerockedinvar.co.uk

East Lothian Housing Association: Data Protection Officer, East Lothian Housing Assoiation, 18-20 Market Street, Haddington EH41 3JL. Email: enquiries@elha.com

Eildon Housing Association: Data and Information Officer, Eildon Housing Association, The Weaving Shed, Ettrick Mill, Dunsdale Road, Selkirk TD7 5EB. Email CorporateServicesTeam@eildon.org.uk

Grampian Housing Association: Data Protection Officer, Grampian Housing Association, 74 Huntly Street, Aberdeen AB10 1TD. Email: dataprotection@grampianhousing.co.uk

Link Housing: Data Protection Officer, Link House, 2c New Mart Road, Edinburgh EH14 1RL. Email: datamanagement@linkhaltd.co.uk

Ochil View Housing Association: Head of Finance and Corporate Services/Depute Director, Ochil View Housing Association, Ochil House, Marshill, Alloa FK10 1AB. Email: customerservices@ochilviewha.co.uk

Sanctuary Scotland Housing Association: Data Protection Officer, Sanctuary Scotland, Sanctuary House, 7 Freeland Drive, Glasgow G53 6PG. Email: Data.Protection@sanctuary-housing.co.uk

The landlord will then have 30 days to respond to your request. As part of the subject access request process we will ask for two forms of identification to be submitted before any information is released.

The right to rectification

If any of the personal data we hold about you is wrong, you have the right to ask us to correct it.

The right to erasure

You may request that Homehunt Partners erase any of your personal data that is processed by us. This is also known as the ‘right to be forgotten’. Please note that this is subject to a number of exemptions and so is not an absolute or automatic right and will be considered under the processing principles.

The right to restrict processing

If you believe that we are processing personal data unlawfully, where it is no longer needed or think that the personal data held is inaccurate you can ask us not to process that personal data.

The right to data portability

If you wish to move to another landlord, you can ask us to pass on the personal data we hold about you to the new landlord, where you have provided that personal data to us and we have been processing it to perform a contract with you.

The right to object

You have the right to object to our processing of your personal data. However, if Homehunt Partners can demonstrate that there is an appropriate ‘condition of processing’ in place then we may refuse to stop processing your personal data.

Rights in relation to automated decision-making and profiling

You have the right not to be subject to a decision solely based on automated processing. If a decision is made by an automated process you may ask to have the decision investigated by a member of staff.

How to action your rights under the Data Protection Legislation

If you wish to object to the use of your personal data, would like to restrict processing or have data rectified, please contact your lead landlord.

Reporting a data breach

A personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data. If you think there has been a data breach please contact your lead landlord.

The right to complain to the Information Commissioner’s Office

If you have a concern about the way Homehunt Partners is processing your personal data, you can raise a complaint with the Information Commissioner’s Office.

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Telephone 0303 123 1113

Website www.ico.org.uk

Marketing

We will never share or sell your personal data to a third party for marketing purposes.

Keeping your information secure

We store personal information both electronically and in paper form. We implement security policies, processes and technical security solutions to protect the personal information we hold from:

• Unauthorised access
• Improper use or disclosure
• Unauthorised modification
• Unlawful destruction or accidental loss

We’ll do what we can to make sure we hold records about you (on paper and electronically) in a secure way, and we’ll only make them available to those who have a right to see them. Examples of our security include:

• Encryption, meaning that information is hidden so that it cannot be read without special knowledge (such as a password). This is done with a secret code or what’s called a ‘cypher’. The hidden information is said to then be ‘encrypted’.
• Pseudonymisation, meaning that we’ll use a different name so we can hide parts of your personal information from view. This means that someone outside of Homehunt Partner landlords could work on your information for us without ever knowing it was yours.
• Controlling access to systems and networks allows us to stop people who are not allowed to view your personal information from getting access to it.
• Training for our staff allows us to make them aware of how to handle information and how and when to report when something goes wrong.
• Regular testing of our technology and ways of working including keeping up to date on the latest security updates (commonly called patches)

When you contact us, we may ask you to provide us with some information so that we can confirm your identity. If other people (e.g. family members, support workers, solicitors) act on your behalf we will take steps to ensure that you have agreed for them to do so. This may include asking them to provide us with supporting information to indicate your consent. We do this to protect you and to make sure that other people cannot find things out about you that they are not entitled to know.

Employees and third parties who have access to, or are associated with the processing of, your personal information are obliged to make reasonable efforts to safeguard it.

Where in the world is your information?

The majority of personal information is stored on systems in the UK. But there may be some occasions as our technology services progress where your information may leave the UK either in order to get to another organisation or if it’s stored in a system outside of the EU.

We will always have additional protections on your information if it leaves the UK ranging from secure ways of transferring data to ensuring we have a robust contract in place with that third party.

We’ll take all practical steps to make sure your personal information is not sent to a country that is not seen as ‘safe’ either by the UK or EU Governments.

4. What data we need

To allow us to provide the service you would expect from us, we process the personal information you provide which includes:

• Your name
• Address and previous address(es)
• telephone number(s)
• e-mail address
• Date of birth
• Names and dates of birth of those currently living in with you
• Names and dates of birth of those who will be moving with you
• Previous tenancy history including landlord contact details
• Information about your health or disability
• Information about your current housing circumstances
• Information about any criminal convictions
• Information about any complaints of anti-social behaviour made against you or a member of your household
• Information about your income in relation to affordability of a private let
• Arrears information for current or previous tenancies
• Employment details where relevant to any priority application
• Details of anyone you nominate to act on your behalf

Why we need it

As Registered Social Landlords we are guided by legislation in who we allocate houses to and need to assess housing need to do that effectively. The information you provide allows us to make that assessment. It also identifies your housing requirements and enables you to bid for appropriate housing. We will also on occasion ask for your opinion of the service.

Other ways that your information is used are;

• to ensure that information is available to partner landlords should you want to bid for properties in their areas.
• for reporting anonymised statistical information including Annual Return Charter and Committee reports
• to enable us to respond to queries or complaints you have about your housing application
• to communicate with you regarding your application and provide information to help you to bid for suitable available properties

Where we store your data

We store your information in the ‘Homehunt System’ – this is basically a large database, an electronic web based information storage system. We also receive some information on paper based forms, these are scanned into the Homehunt System and stored with your individual registration. It’s also possible, if you have contacted us by email, that some information will be held in the email system.

How long we will keep your information

We will keep your data for as long as you have an active application for housing. We will write to you annually to ensure that you are still looking for a property. If we cannot contact you or if you indicate that you do no longer want to be registered, we will withdraw your housing application and anonymise your data for reporting purposes.

If you are successful in being allocated a home we will anonymise your data and use it for reporting purposes.

You can find more information on each landlord’s Data Retention periods by going to the relevant landlord’s website, or by contacting them directly.

There are a number of pieces of legislation that require us to collect the information from you

Data Type	Condition of Processing
Personal Data	The Housing (Scotland) Act 1987 (as amended) The Housing (Scotland) Act 2001 The Housing (Scotland) Act 2006 The Housing (Scotland) Act 2014 (once enacted)
Special Category Data	The Housing (Scotland) Act 2001, section 105 The Scotland Act 1998, Schedule 5, section L2 The Equality Act 2010

Sharing your Information

The information you provide to us will be treated by us as confidential. When verifying the information you have provided we will contact those third parties that you have listed in your application.

Receiving data about you

Where appropriate we will also receive the following information from third parties:

• Medical information from Occupational Therapist, hospital and GPs or any other medical professional to support your application;
• Social Work or any other supporting agencies in relation to your application for housing
• References from previous or current tenancies which will include information about rechargeable repairs, outstanding debt and complaints of anti-social behaviour.

Updating your information

If your details change, please contact your lead landlord to inform us so that all of the information we hold about you is up to date.