Privacy

Policy

Data Protection at Watermans Housing Co-operative

Watermans Housing Co-operative is a housing co-operative and a controller of personal information for the purposes of the General Data Protection Regulation (‘GDPR’) and Data Protection Act 2018.

Identity and Contact Details of Controller

Data Protection Officer Details

Address: 15 Jenner Road, London, N16 7SB
Tel: 020 8193 0840
Email: admin@watermanscoop.org.uk

Watermans is registered with the Information Commissioners Office as a Data Controller.

Under the Data Protection Act 2018, Watermans has a legal duty to protect any information we collect from you or have about you from other sources.

GDPR as defined in the Data Protection Act 2018 as a set of rules and guidelines we must follow when handling your personal information. These are referred to as Data Protection Principles.

How we Use and Store your Personal Information

This privacy notice tells you what to expect when Watermans collects and stores personal and sensitive information.

It tells you the purposes for which we will process your personal information and the legal basis for the processing (‘processing’ includes us keeping your personal information). It applies to information we collect about:

Residents, or occupants of our homes
Contractors, suppliers, partners, or agents
Staff and recruitment applicants
Care and support customers
Members of the public
Legal basis for processing

We have four main legal bases for processing personal data:

Where it is necessary for the performance of a contract (i.e. provision of services set out in the tenancy agreement)
Where it is necessary for the purposes of the legitimate interests pursued by Watermans or by a third party to process your information. We can do that as long as we do not interfere with your fundamental rights or freedom.
Because we have your consent (i.e., agreement) to us processing your personal information. You can withdraw your consent at any time. This is explained further below in the section entitled ‘Your rights under GDPR’.
Where processing is necessary to comply with the law or a statutory obligation.

Other reasons we can rely upon to process your personal information under GDPR are as follows:

Where we are under a legal obligation or an obligation under a contract to process/disclose the information.
Where we need to protect the vital interests (i.e. health and safety) of you or another person.

Some personal information is treated as special category data, specifically health, sexuality, racial or ethnic background, political opinions, religion, beliefs, trade union membership, or genetic and biometric data. The legal basis for processing these special categories of personal data is more limited. To lawfully process special categories of personal data, we must identify a lawful basis for the processing and meet a separate condition for the processing.

The bases we can use are:

With your consent
Where we need to protect the vital interests (i.e. the health and safety) of you or another person
Where you have already made your personal information public
Where we or another person need to bring or defend legal claims; and/or
Substantial public interest grounds

To process personal data about criminal convictions or offenses we must have both a lawful basis for the processing and either legal authority or official authority for the processing.

How we Manage your Personal Information

We expect you to look after your home, carry out minor repairs and regularly decorate it. For a list of repairs that the tenant is responsible for and how to.

We process your personal information in accordance with the principles of GDPR.

We will treat your personal information fairly and lawfully and we will ensure that information is:

Processed for the limited purpose
Kept up-to-date, accurate, relevant, and not excessive
Not kept longer than is necessary
Kept secure

Access to personal information is restricted to authorised individuals on a strictly need-to-know basis.

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 ensure the confidentiality of your personal information we may ask you security questions to confirm your identity when you call us. We will not discuss your personal information with anyone other than you unless you have given us prior authorisation to do so.

a repair that is our responsibility, go to our Guidance on repairs and responsibilities.

Who might we share your Personal Information with?

Normally, only Watermans' staff will be able to see and process your personal information. However, there will be occasions when we will need to share personal information with third parties for the purposes as outlined or where we are legally required to do so.

When sharing personal information, we will comply with all aspects of the GDPR. Special categories of personal data about health, sexual life, race, religion and criminal activity, for example, are subject to particularly stringent security and confidentiality measures.

We also share information:

To allow us to tailor our services to you
For detecting possible fraud (e.g. as part of the National Fraud Initiative)
To deal with rent arrears (e.g. tracing and/or debt collection agencies)
To deal with unpaid bills (e.g. utility or council tax bills – we may need to pass on your forwarding address)
To help us communicate with you (e.g. we sometimes use external printers, translators etc.)
To assist the Police in solving crime and investigating anti-social behaviour

As part of the government’s reform of welfare benefits, new regulations have been introduced on information sharing. This means we can now share limited information about our residents and their properties with local authorities, for example, name, address and National Insurance Number.

The new regulations will help us identify and support those who could be affected by welfare reform.

We will also disclose your personal details, if required to do so, by law or by any Government body.

Watermans contracts external companies to manage certain areas of our business to fulfil our obligations as a landlord.

We share limited personal information of our residents with external contractors, such as name, address and telephone number.

Examples include:

Repairs and maintenance contractors
Out-of-hours call centre service
Health and safety compliance checks (i.e. gas servicing etc)

We will only share the minimum information necessary for the contractor to carry out their services on behalf of Watermans. If you have any concerns about a company operating on behalf of Watermans, or information that has been shared with an external company, please contact us using the details below.

How long do we keep Information

We have a data retention schedule, which sets out how long we keep different types of information. We follow legal requirements and best practice.

Fraud Detection

We may use data disclosed for the purpose of preventing and detecting fraud. This includes information provided on the Watermans' website.

The data collected may be used for the purpose of data matching and further investigations. This involves comparing the data we hold on you with that held by third parties solely for the purpose of detecting and preventing fraud. We might also use your data to further investigate fraud that we think might have been committed.

This involves checking with various third parties, such as the Land Registry, banks, schools, and utility companies.

Your Rights under GDPR

You have a number of rights under the GDPR.

Access to Personal Information

Under GDPR, you have a right to ask us what personal information we hold about you, and to request a copy of your information. This is known as a ‘subject access request’ (SAR).

You can submit your request by emailing us at admin@watermanscoop.org.uk or contacting us at 0207 193 0840. We will require photo identification.

We will usually respond to your request with all the information we are legally required to provide within 30 days.

Your right to certain information may be restricted. For example, information relating to a third person or information relating to a police investigation.

Rectification

If you need to correct any mistakes contained in the information, we hold about you; you can let us know by contacting Watermans on 0207 193 0840

Erasure/ The Right to be Forgotten

You have the right to ask us to delete the personal information we hold about you. You can do this where:

The information is no longer necessary in relation to the purpose for which we originally collected/processed it
You withdraw consent
You object to the processing and there is no overriding legitimate interest for us to continue the processing
We unlawfully processed the information
The personal information has to be erased in order to comply with a legal obligation

We can refuse to erase your personal information where the personal information is processed for the following reasons:

To exercise the right of freedom of expression and information
To enable functions designed to protect the public to be achieved, e.g. government of regulatory functions
To comply with a legal obligation or for the performance of a public interest task or exercise of official authority
For public health purposes in the public interest
Archiving purposes in the public interest, scientific research, historical research, or statistical purposes
The exercise or defence of legal claims
Where we have an overriding legitimate interest in continuing with the processing.

Restriction on Processing

You have the right to require us to stop processing your personal information. When processing is restricted, we are allowed to store the information, but not do anything with it. You can do this where:

You challenge the accuracy of the information (we must restrict processing until we have verified its accuracy)
You challenge whether we have a legitimate interest in using the information
The processing is a breach of the GDPR or otherwise unlawful
We no longer need the personal data, but you need the information to establish, exercise, or defend a legal claim

If we have disclosed your personal information to third parties, we must inform them about the restriction on processing, unless it is impossible or involves disproportionate effort to do so. We must inform you when we decide to remove the restriction giving the reasons why.

Objection to Processing

You have the right to object to processing where we say it is in our legitimate business interests.

We must stop using the information unless we can show there is a compelling legitimate reason for the processing, which overrides your interests and rights or the processing is necessary for us or someone else to bring or defend legal claims.

Withdrawal of Consent

If the basis on which we are using your personal information is your consent, we will seek your consent to contact you for non-essential services.

Examples of this include to gather feedback following community events or permission to use photographs taken (i.e. at events). You have the right to withdraw your consent to us processing your information at any time. We must stop using the information. We can refuse if we can rely on another reason to process the information such as our contractual obligations or legitimate interests.

Visitors to our Website

We may collect the following information from visitors to our website

Details collected through online forms
Surveys and polls about the website
Site usage information from session cookies and log files

Links to other Websites

This privacy notice does not cover links within our website to other websites. We encourage you to read the privacy statements on other websites you visit.

Changes to this Privacy Notice

We keep our privacy notice under regular review.

Further Information

This privacy notice does not provide details on all aspects of Watermans’ collection and use of personal information. We are happy to provide any further information or explanation if needed.

Watermans aims to meet the highest standards when collecting and using personal information. You can raise a complaint with us if you think that our collection or use of information was unfair, misleading, inaccurate or inappropriate.

If you are still not happy with our response, you have the right to appeal directly to the regulator – the Information Commissioners’ Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303 123 1113.