Privacy Notice – Board members
Effective 10 October 2023
At Plymouth Community Homes (PCH) we are committed to ensuring that your privacy is protected, and that data is used in accordance with the data protection legislation in force in England and Wales.
This privacy notice sets out why we collect personal information from you, how we use it and who we may share it with. It also explains your individual rights under the current data protection legislation.
If we ask you to provide information which can identify you, then we will only use it in accordance with this privacy notice.
We may change this notice by updating it on our website. You should check the notice from time to time to ensure that you are happy with any changes.
Any queries regarding this notice and our privacy practices can be sent to the company Data Protection Officer by email using governance@plymouthcommunityhomes.co.uk or by writing to the Head of Governance, who is also the Data Protection Officer at -
Plymouth Community Homes
Plumer House
Tailyour Road
Crownhill
Plymouth
PL6 5DH
Alternatively, you can telephone us on 0808 230 6500.
Who we are
Plymouth Community Homes Limited is a registered housing provider. Our registration number is 30637R. Our registered office is Plumer House, Tailyour Road, Crownhill Plymouth, PL6 5DH.
At the time of issuing this Notice, Plymouth Community Homes Ltd has two wholly owned subsidiaries, Plymouth Community Homes Regeneration Company Ltd (PCHR), company number 7272688 and Plymouth Community Homes Energy Ltd (PCHE), company number.
For the purposes of data protection legislation, Plymouth Community Homes Limited is a Data Controller.
Why we collect information
We collect and process your information because you have entered into or wish to enter into a contractual agreement (Terms of Appointment) with PCH as a Board member (this includes co-optees and independent Board or Committee members on PCH or PCHR Boards). This is usually the legal basis for processing your information and carrying out our activities.
We require the information to assess your suitability for the role. If successful in your application, so we can assist you in carrying out the full responsibilities of a Board member as effectively as possible and to meet our legal and regulatory obligations.
What information we collect about you
· Name
· Address
· Contact details
· Date of Birth
· Educational data
· Employment/personal history
· References
· Equality & Diversity information
· Health information
· Socio-economic data
· Bank details
· National Insurance number
· Driving licence/passport
· Security identification photograph
· Declarations of Interest
· Photographs of PCH events at Plumer House and offsite in our communities that you may attend
· Individual biographies for the PCH website
· Skills audit information
· Appraisal forms/notes
· Dietary requirements
· Monitoring information with regard to your access to board portal software
In addition to the above, we may collect the following:
· Emergency contact details – please see separate Emergency Contact Details Privacy notice
· Tax and pension information
· CCTV video footage
· Door access controls data
· Electronic signature
· Expenses forms
Most of this information will be supplied by you directly.
How we collect your information
PCH collects information from you via a variety of sources; in the first instance information is provided to PCH by you as a prospective Board member on an application form. This information will be added to throughout the induction process and as appropriate throughout your time as a Board member, either formally through data collection on forms, in discussions with staff or volunteered by yourselves.
We operate a CCTV system at Plumer House and our other sites in pursuit of our legitimate interests of building security and the detection and prevention of crime. For more information refer to the separate Privacy Notice for CCTV and Door /Barrier Access control at Plumer House and Brest Road, or request copies from the Governance Team
Photographs are used on PCH identity cards for the purposes of identification and security. ID cards are required for access to Plumer House and its car park for building security. This access data may also be used for monitoring purposes including tracking individual movements. It is in PCHs legitimate interest to use your photo for your ID security pass.
We may take photographs at our events and in our communities to use for general marketing and publicity. We may also publish your photo in connection with any information about the role of PCH
Board members. Photographs of board members will only be used for those purposes with your consent. We ask you to complete a consent at the start on your Board membership and you can update or withdraw your consent at any time on request. We may continue to use your photograph and any group shots in which you feature after your board membership ends, unless you specifically request to opt out when you leave.
Board portal software is used to publish Board reports and other documents of interest to Board members and is accessed by a unique username. The software app permits the monitoring of access by individual Board members to meeting reports.
Information relevant to the Rules of PCH
Our Rules do not permit an individual to become or remain a Board member in certain circumstances, including where they are disqualified from acting as a director of a company, where they have been convicted of an indictable offence and where they have been declared physically or mentally incapable of acting as a Board member.
The above information, if relevant would be processed in connection with your Terms of Appointment and in order to assess your fitness to perform your role as a Board member.
Special Category Information
Under data protection legislation certain personal information is classed as special category. This is information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, data about sexual orientation and criminal convictions.
We minimise our holding and use of special category personal information but, we will collect special category information:
· About your physical and mental health or any medical conditions in order to enable us to effectively support you to perform your duties as a Board member
· About you that may be relevant to ensuring equality of treatment in line with our Equality, Diversity, and Inclusion Policy and in compliance with equalities legislation
We will usually be processing this information to allow us to comply with our obligations under employment, social security and social protection law, or as a matter of public interest.
What we do with it
We may use the information you give us:
· To manage the performance of your Terms of Appointment (contract)
· To comply with our legal obligations
· To comply with our regulatory obligations
· To understand your needs and provide you with a better and more supported service
· For internal record keeping
How long we keep your information
We shall only store your information for as long as is reasonably necessary for us to fulfil the purposes set out in this guide, or for a maximum of six years after you cease to have a relationship with us, or if we are in dispute with you until legal proceedings have ended, whichever is longer.
Payroll information, including bank details, is retained for six years after the year you cease to be a PCH Board member.
In some instances, we will retain your information permanently in order to comply with the law, for example, copies of company registrations and shareholder information.
CCTV - we will retain CCTV video footage of Plumer House for no more than 6 weeks unless the footage is being used to investigate an alleged crime or incident in which case it may be retained for up to 2 years following the conclusion of any investigation.
Door access controls - We will retain door access control data for 42 months.
We will securely dispose of all information.
Sharing your information
We will only share your information where we are legally entitled to do so, for example:
· to comply with the law
· to seek legal advice or in connection with court proceedings
· where there is a clear health and safety risk
· where there is a clear risk to yourself, staff and others
· to provide you with support in your Board member role
· for the detection and prevention of crime, prosecution of offenders and for the detection and prevention of fraud
We may therefore share your information with third parties from time to time, such as:
· Other Board members
· Members of Plymouth Community Homes staff; typically, members of the Executive Management Team or the Senior Management Team
· The Regulator of Social Housing
· Companies House
· Homes England
· Financial Conduct Authority
· HMRC
· Security firms acting for PCH
· Local authorities
· Partner landlords
· Legal Advisors, the courts and our insurers and auditors
· Consultants providing services to us
· Charities and voluntary organisations
· Banks to carry out payment of fees through a secure service
· Lenders
· Companies that help us mail out newsletters etc.
· National Housing Federation
· Taxi companies
· Training providers or learning organisations
How we store your information
We are committed to ensuring that your information is secure. Some information is stored on paper, but most is stored electronically. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information.
Your Rights in relation to your personal data
In certain circumstances, Data Protection legislation gives you a number of individual rights in relation to your personal data. These are as follows:
· The Right to be Informed about how your data is managed – this right is met by this privacy notice and a range of other notices which relate to specific aspects of PCH, such as the CCTV privacy notice and the website privacy notice.
· The Right of Access to your personal information – so that you can be aware of and verify what personal data we hold. Click here for details on how to apply for this right or ask us for more information.
· The Right of Rectification - to have any personal data corrected if it is inaccurate, incomplete or out of date.
· The Right of Erasure of your personal data – this only applies in certain circumstances, such as where you have given consent for us to hold information and you withdraw that consent.
· The Right to restrict processing – in certain circumstances you have the right to block or restrict how we process your data.
· The Right to data portability – which in certain circumstances allows you to obtain obtain and reuse your personal data for your own purposes across different services
· The Right to object - in certain circumstances, to the processing of personal data. In particular you have the right to object to being sent direct marketing information.
· The Right not to be subject automated decision making - Plymouth Community Homes does not do this.
More information on the individual rights and how they apply can be obtained by clicking here, by requesting a paper copy of our individual rights guidance information or you can visit the ICO website (ico.org.uk)
If you wish to exercise any of the above rights, please contact:
Governance Team
Plymouth Community Homes
Plumer House
Tailyour Road
Crownhill
Plymouth
PL6 5DH
Alternatively, you can make a request electronically, by email, to governance@plymouthcommunityhomes.co.uk. or telephone the Governance Team on 01752 388134 or 388152
Making a complaint
If you believe that Plymouth Community Homes has not handled your personal information correctly you have the right to make a complaint. You can raise a complaint in a number of different ways:
· To the Chair of PCH
· To the Chief Executive
· To the Director of Corporate Services
· To the Head of Governance
You also have the right to complain to the Supervisory Authority (ICO at ico.org.uk) about our data processing activities.
You can also contact the Information Commissioner’s Office (ICO) at:
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Plymouth Community Homes collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests should be sent to the PCH Data Protection Officer at the above address.
If you or someone you know would like this information in large print, braille, or translated into another language, please contact our Communications Team on 0808 230 6500 or email info@plymouthcommunityhomes.co.uk
Legal Status:
Plymouth Community Homes Ltd is a registered society under the Co-operative and Community Benefit Societies Act 2014 (which consolidates the Industrial and Provident Societies Acts) and is registered with the Financial Conduct Authority (registration 30637R) and The Regulator of Social Housing (registration L4543).
At the time of issuing this Notice, Plymouth Community Homes Ltd has two wholly owned subsidiaries, Plymouth Community Homes Regeneration Company Ltd (PCHR), company number 7272688 and Plymouth Community Homes Energy Ltd (PCHE), company number 8028170. Both subsidiaries are incorporated under the Companies Act 2006.
