Privacy notice - applying for a home

When you make a housing options application and/or submit a housing application form to any RSL within the Highland Housing Register we will ask you for the following personal information:

• your full name (and proof of your identity/photo ID)
• date of birth
• national Insurance number (customers unique identifier)
• contact details (phone, email or correspondence address)
• details of anyone authorised to act on your behalf if applicable
• basic details (name and date of birth) of all household residents including any children
• banking details if you pay your rent by Direct Debit
• proof of housing eligibility, any interest or equity in other property from 2019
• other personal information that will vary on a case by case basis to help us resolve breach of tenancy, alleged anti-social behaviour or fraud, rent arrears
• other details - next of kin details and employment details
• equality, disabilities or vulnerabilities. We use this information to tailor our service to better meet your particular circumstances and needs. We may use this information for safeguarding of staff
• financial information. We may use this to help customers make a decision around affordability and resolve any housing debt/arrears and provide welfare benefits, fuel and debt advice as a free service to help customers budget and pay bills. We may use this to apply for funding on a customer’s behalf
• health information when we require this to make decisions on the property type customers may require and support funding for adaptations made to the property a customer is living in. More specific details are provided if you use this service.

We may transfer information about you to other HHR landlords for purposes connected to your tenancy application or the management of the company’s business.

We do not usually process children’s information as part of the housing options or housing application process, as all applicants are adults. However, we record children’s basic information if they are to be resident in one of our properties, including their name and date of birth. This is required for checking the property is not overcrowded and to assess other tenancy management issues where all householders and ages are required to be known.

We may at a later stage receive children’s information if we are involved in the housing and tenancy aspects of a welfare case as part of a multi-agency working solution.

We need to collect your personal information so that we can assess your eligibility for and manage your housing application, if successful. We will use your personal information to assess your housing application for a home with us and award priority for housing.

We are also under a legal obligation to process certain personal information relating to our tenants and applicants for the purposes of complying with our obligations under:

• Housing (Scotland) Acts 1987, 2001, 2006, 2010 and 2014
• Homelessness etc. (Scotland) Act 1987 and 2003
• Antisocial Behaviour etc. (Scotland) Act 2004
• Matrimonial Homes (Family Protection) (Scotland) Act 1981
• Matrimonial Homes (Family Protection) (Scotland) Act 1981
• Children Scotland Act 1995
• Children and Young People (Scotland) Act 2014
• Civil Partnership Act 2004
• Immigration and Asylum Act 1999 and Immigration Act 2014
• Protection from Harassment Act 1997
• Management of Offenders etc. (Scotland) Act 2005.

If you do not provide us with all of the personal information that we need to collect then this will affect our ability to assess process your Housing Options Application and/or Housing Application.

We also process your personal information in pursuit of our legitimate interests to:

• issue communications to our applicants regarding Housing services, including letters, newsletters, emails and texts
• carry out customer segmentation research to allow us to help us better understand our customers’ characteristics and prioritise, tailor and target services to you
• undertake research and statistical analysis to help improve our business processes and the services offered to our customers, as well as to evaluate our performance against other benchmarks.  Where possible, statistical information is anonymised or pseudonymised,  and
• we may also conduct surveys regularly and periodically relating to our services in order to gauge satisfaction and make improvements based on feedback.

As part of the housing application process we request your national insurance number in pursuit of our legitimate interest to future proof our services. You may choose not to provide this information to us.

Where we process your personal information in pursuit of our legitimate interests, you have the right to object to us using your personal information for the above purposes. If you wish to object to any of the above processing, please contact us on informationrequests@albynhousing.org.uk. If we agree and comply with your objection, this may affect our ability to undertake the tasks above for your benefit.

We are required to use your personal information relating to your health, racial or ethnic origin for equality monitoring purposes as required by government departments and agencies, Scottish Housing Regulator and auditors, with other organisations and agencies where we are legally allowed to do so.

We will process such personal information to identify and keep under review the existence or absence of equality of opportunity or treatment between groups of people within the same categories to promote or maintain equality within our Group.

We may ask you if we can process your personal information for additional purposes. For example we may share your information with a language translation service if it is necessary to translate any information into or from a foreign language for you.

Where we do so, we will provide you with an additional privacy notice with information on how we will use your information for these additional purposes.

We share limited personal data with our contractors who are carrying out services on our behalf for example to carry out research, survey and segmentation on our behalf to help us to improve the services we offer to you. Our contractors are required to comply with the law and our own Data Processing Agreement or Data Processing Clauses within our contracts to ensure data is managed appropriately and for specified purposes.

We may be required to share personal information with statutory or regulatory authorities and organisations to comply with statutory obligations. Such organisations include Health and Social Care Partnerships, Homelessness services, Health services or care and support organisations that we work with for the purposes of ensuring we have the necessary information to make an assessment of your Housing Application and ensure that you will be able to access a range of wraparound supports to help you mange in your new tenancy. We will only share information on the basis of your consent or another lawful basis in UK data protection legislation.

We may also share personal information with our professional and legal advisors for the purposes of taking advice.

In the event that we do share personal information with external third parties, we will only share such personal information strictly required for the specific purposes and take reasonable steps to ensure that recipients shall only process the disclosed personal information in accordance with those purposes.

The housing options and housing application process uses automated decision making to prioritise your housing application. We do this because it is necessary to assess your housing circumstances to award priority in terms of our Housing Information, Advice and Letting Framework and Policy.

This is of advantage to you as it allows for greater consistency or fairness in the decision-making process (for example it might reduce the potential for human error, discrimination and abuse of power), reduces the risk of you failing to meet payments for goods or services and enables us to deliver tenancy decisions within a shorter time frame. More frequent human involvement is also impractical due to the sheer quantity of personal data being processed.

In accordance with data protection legislation, we provide you with a way to express your views, obtain human intervention and challenge our decision. We always explain in our decision letters why we assign you to a particular category, explain the decision process and signpost you to a way to request a review of our decision. The review will be carried out by a member of staff who has the appropriate authority and capability to challenge the decision.

We will also carry out frequent assessments of any data sets used in the housing options and housing application process to check for any bias and to develop ways to address any prejudicial elements.

Your personal information is stored on our paper and IT filing systems which may be copied for testing, backup, archiving and disaster recovery purposes. Access to your information is limited to those who require it to provide services to you. All data is held within the UK.

If any of your personal information is transferred out with the European Union or the European Economic Area by any of our contractors we will ensure that there are adequate safeguards in place to protect your personal information in accordance with UK Data Protection Legislation.

We request customer re-register their Housing Application every year, unless you are offered a home with us, to ensure that your information is up to date and you still wish to stay on our housing list. We will send you two reminders to re-register with us. If you chose not to re-register then we will retain your information for a further six months.

We have a data retention policy that sets out the periods for retaining and reviewing all information that we hold. This sets out different retention periods and you can request a copy by contacting us at informationrequests@albynhousing.org.uk

You can exercise any of the following rights by writing to us at informationrequests@albynhousing.org.uk

Your rights in relation to your personal information are:

• you have a right to request access to the personal information that we hold about you by making a Subject Access Request
• if you believe that any of your personal information is inaccurate or incomplete, you have a right to request that we correct or complete your personal information
• you have a right to request that we restrict the processing of your personal information for specific purposes, and
• if you wish us to delete your personal information, you may request that we do so.

Any requests received by The Albyn Group will be considered under applicable UK Data Protection Legislation. If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner's Office.

The accuracy of our information is important to us - please help us keep our records updated by informing us of any changes to your personal information.

Our privacy notice is regularly kept up to date.