Plymouth Community Homes Tenants

Privacy Notice  

Plymouth Community Homes Tenants  

Effective 05 March 2025

We keep our Privacy Notice under regular review and will update it if we undertake any new or amended processing. If there are any significant changes, we will bring these to your attention.

If you or someone you know would like this information in large print, braille, or translated into another language, please contact Customer Services.

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.

As part of the housing and support services we offer, we are required to process personal data about our tenants, which may include basic information on children living in a household, and, in some instances, the friends or relatives of our tenants.

‘Processing’ can mean collecting, recording, organising, storing, sharing or destroying data.

This Privacy Notice tells you what to expect when PCH collects and stores data containing personal information. It tells you why we process your personal information and the legal basis for doing so. It will also explain your rights when it comes to your data.

The information provided in this notice gives an overview and examples of data processing, it does not necessarily provide exhaustive detail of all aspects of PCH’s collection and use of personal information.

If you have any concerns or questions, please contact our Data Protection Officer or our Customer Services Team:

• Contacting Customer Services: 0808 230 6500 or email
• Contacting our Data Protection Officer: 0808 230 6500, email or Plymouth Community Homes, Plumer House, Tailyour Road, Crownhill, Plymouth, PL6 5DH

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.

For the purposes of data protection legislation, Plymouth Community Homes Limited is a Data Controller.

What is personal information?

Personal information can be anything that identifies and relates to a living personal. This can include information that, when put together with other information, will identify a person.

How we collect your information:

Plymouth Community Homes collects information about you from a variety of sources.

We collect most of our information directly from you, including when you apply for one of our properties, require our services, complete one of our forms, when you write, email or meet with us, or respond to a survey.   We may collect information when you use our social media sites, websites or self-service portal. For more information refer to the separate Privacy Notice for PCH website users.

Most of the information we hold comes directly from you, however we may from time to time collect information from third parties such as:

• Devon Home Choice / Cornwall Home Choice in relation to your application for rehousing
• Your local authority or government departments such as the DWP to check information relating to your housing
• Credit reference agencies and previous landlords when you apply for housing
• Support and social workers, GP’s, mental health teams
• Police, Probation Service, welfare or support organisations dealing with you
• Councillors, MP’s or other representatives acting on your behalf or with your instruction
• Family and neighbours
• Financial institutions when you apply for a tenancy or one of our services

We may also collect information about you that has already been made public, such as the local newspapers etc.

PCH staff may occasionally use body worn cameras where there is a need to capture images and speech for evidential purposes, to protect employees in situations where they are particularly vulnerable to abuse. Any use of body worn cameras is governed by internal policies and is conducted in accordance with the law. PCH will never continuously record using body worn cameras and will only utilise such technology where there is a legitimate need to do so (i.e. they are threatened). If body worn cameras are in operation, will take all reasonable steps to make sure those captured in such footage are made aware that recording is taking place.

Photographs – We may take photographs at our events and in our communities to use for general marketing and publicity. However, photographs of individuals will only be used for those purposes with your consent. We may also take aerial images of our estates to be used on our channels, including the PCH website, social media, newsletters, publications, presentations and in videos.

We may also on occasion take photographs of our properties, both internally and aerially. It is in the legitimate interest of PCH to record any issues within our properties, including where it is in a poor condition, to assist both the management of property and potentially your tenancy.

Video calls (Remote Assist) - We may, on occasion, ask you to participate in a live video call to evidence and diagnose a repair in your property prior to a visit, or as preparatory viewing for routine inspections such as asbestos electrical or gas work, or for the purpose of property viewing.

How we use your information:

We may use your personal information as follows:

Existing tenants

• To provide the services you request and expect as part of your tenancy agreement, for example, providing a repairs and maintenance service or an adaptation
• To understand your needs and provide you with a better and more supported service
• To manage complaints and instances of anti-social behaviour
• To highlight health and safety or wellbeing issues
• To comply with our legal obligations
• For internal record keeping
• To provide statutory statistical information
• For equality and diversity monitoring
• To assess your application should you wish to purchase your home under the Right to Buy or Right to Acquire schemes.
• To survey you or undertake market research about our delivery of services for quality improvement and monitoring purposes
• To send you information about the work of Plymouth Community Homes and events in your area that we think you may find interesting
• To customise the PCH website according to your interests
• We may also use this information for safeguarding our staff and residents
• To help detect and prevent fraud

Former tenants

If you move to another PCH property and start a new tenancy with us, it is in our legitimate interests to retain all your previous tenancy information to assist with managing your current tenancy.

If you move to a property which is not owned or managed by PCH, it is in our legitimate interests to:

• Continue to hold details of any outstanding debt against your tenancy
• Your new contact details so we can discuss repayments with you
• Keep records of any anti-social behaviour that occurred during your tenancy

When you are no longer a tenant of Plymouth Community Homes, we may use your personal information as follows:

• To confirm your occupancy of a property. If you move to a property which is not owned or managed by PCH, it is in our legitimate interests to retain basic tenancy information. This is to ensure you can obtain the appropriate discount in future should you be eligible to exercise your Right to Acquire and / or Right to Buy.  It is therefore in your interests for PCH to continue to hold this information.

• If you purchase your property under the Right to Buy or Right to Acquire, we will retain the information used to confirm your identity and undertake anti-fraud and anti-money laundering checks

• To assess your suitability for housing with Plymouth Community Homes should you apply for one of our properties in the future

Types of personal data we collect and our lawful basis:

Below lists the type of information we collect, the purpose of collecting and the legal basis for doing so:

• Contact details: current and previous address. forwarding address (former tenants), email address and telephone numbers.

Purposes of processing - more detail in section above 'How we use your information': To enter into a contract with you (tenancy agreement). To manage all aspects of a tenancy and/or support agreement, provide customer service and appropriate communications regarding our services.

Lawful basis (Article 6 UK GDPR): Performance of a contract (tenancy and or support agreement).

Condition (Article 9 UK GDPR): N/A

• Financial information: includes employment details, benefit entitlements, bank account and payment details. Bank statements, details of income and expenditure.

Purposes of processing - more detail in section above 'How we use your information': Assessing eligibility for housing and/or support services. Rent and/or support charges collection. Affordability checks and budgeting support.

Lawful basis (Article 6 UK GDPR): Performance of a contract. Legitimate interest (rent and/or support charges collection).

Condition (Article 9 UK GDPR): N/A

• Identification details: includes name, maiden name, marital status, title, date of birth and gender. Photographic ID documents (e.g. passport, driving licence), birth certificate, National Insurance number, benefits/pension letter, references, household makeup.

Purposes of processing - more detail in section above 'How we use your information': Identity verification and fraud prevention. To provide appropriate accommodation.

Lawful basis (Article 6 UK GDPR): Legal obligation. Performance of a contract.

Condition (Article 9 UK GDPR): N/A

• Health and support information and other household needs: includes disabilities, medical conditions both mental and physical, other vulnerabilities, care & support needs of the household.

Purposes of processing - more detail in section above 'How we use your information': To identify and provide appropriate accommodation and/or support services tailored to customer and household needs.

Lawful basis (Article 6 UK GDPR): Legal obligation. Vital interests (emergency situations only).

Condition (Article 9 UK GDPR): Employment, social security and social protection. Vital interests. Substantial public interest (safeguarding vulnerable individuals).

• Criminal record data: (if applicable) against you or anyone on your application.

Purposes of processing - more detail in section above 'How we use your information': Assessing housing and/or support applications where applicable.

Lawful basis (Article 6 UK GDPR): Public interest.

Condition (Article 9 UK GDPR): Substantial public interest (safeguarding vulnerable individuals).

• Emergency contact details:

Purposes of processing - more detail in section above 'How we use your information': To contact in case of emergency or incidents affecting the customer.

Lawful basis (Article 6 UK GDPR): Vital interests.

Condition (Article 9 UK GDPR): N/A

• Equality and diversity data: (eg. ethnicity/racial origins)

Purposes of processing - more detail in section above 'How we use your information': Monitoring compliance with equality legislation, ensuring non-discrimination. 

Lawful basis (Article 6 UK GDPR): Legal obligation.

Condition (Article 9 UK GDPR): Substantial public interest (equality of opportunity monitoring). 

• CCTV footage: in communal areas of some PCH properties and Plumer House. For more information refer to the separate Privacy Notice for CCTV on PCH Estates or the separate Privacy Notice for CCTV at Plumer House.

Purposes of processing - more detail in section above 'How we use your information': Crime detection & prevention and providing a safe and secure environment for tenants, staff and visitors.

Lawful basis (Article 6 UK GDPR): Legitimate interest (security of premises).

Condition (Article 9 UK GDPR): N/A

• Maintenance and repairs data: (eg. repair requests, access to property)

Purposes of processing - more detail in section above 'How we use your information': Managing maintenance and repair requests, scheduling property inspections, safety checks e.g., annual gas check etc.

Lawful basis (Article 6 UK GDPR): Performance of a contract.

Condition (Article 9 UK GDPR): N/A

• Telephone calls: some calls made to PCH, where a call management system is in place, are recorded. A recorded message will tell you if your call will be recorded before the call starts.

Purposes of processing - more detail in section above 'How we use your information': For staff training and to improve customer service, to check and measure whether we meet standards agreed with customers and as evidence in investigations or disputes concerning either our customers or staff.

Lawful basis (Article 6 UK GDPR): Legitimate interest (monitoring and training).

Legitimate interests

When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Consent

We may sometimes process your data for specific purposes which require your consent. If we do this, we will always ask for your written consent. An example of this is where we ask for your consent to share health data with our Livewell Southwest partnership, as part of our joint support project.

Where we are processing your personal data based on your consent, you have the right to withdraw that consent at any time. This may affect the services that we can make available to you, but this will be explained in the consent form. Please contact us if this is the case.

Special Categories of Personal Data:

Special categories of particularly sensitive personal information, such as information about your health, racial or ethnic origin, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information.

We minimise the collection and use of sensitive data, however, given the services we provide there are times when we use it to better understand our tenants needs, for example:

• Information about your health where the information is necessary for us to provide appropriate services to you, for example where accommodation or services are adapted to your needs.

• Dealing with neighbourhood disputes involving alleged criminal activity.
• We may also request information on ethnicity for statistical reporting and analysis to comply with regulation and equality legislation and to ensure services are appropriate. It is optional for you to provide this information.

We may collect information about criminal convictions and offences where this information is relevant to assessing your housing and/or support needs and your use of our services.

In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data, but we are not required to obtain consent for all special category data we process. If we do ask for consent, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

Children’s personal data

We record children’s basic information if they are 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 also receive children’s information if we are involved in the housing and tenancy aspects of a welfare case, and/or as part of delivering support services as part of a multi-agency working solution.

We process children’s information based on our legitimate interests and to fulfil our legal and regulatory obligations.

How we store your information

Your information is stored securely. Some information is stored on paper, but the majority is stored electronically. To prevent unauthorised access or disclosure, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information.

Transferring your data internationally

We ensure that appropriate security measures are in place when handling your personal data. It may sometimes be necessary to transfer personal information outside the UK as a result of our requirements for data hosting services.  Occasionally, we may share your data with third party suppliers outside of the European Economic Area (‘EEA’), for example we may use Survey Monkey which has servers in the USA. When it is necessary for us to transfer your personal information outside of the UK this will only be done in accordance with the UK GDPR.

How long we keep your information

We will only store your information for as long as is reasonably necessary for us to fulfil the purposes set out in this notice. We will then securely dispose of your information.

• This is normally six years after you cease to hold a tenancy with us.
• If, when you leave a PCH tenancy, there is an outstanding debt your information will be retained in pursuit of our legitimate interests in recovering that debt.
• We will retain basic tenancy information. This is to ensure you are able to obtain the appropriate discount in future should you be eligible to exercise your Right to Acquire and / or Right to Buy.  It is therefore in your interests for PCH to continue to hold this information.
• Recorded telephone conversations are usually kept for up to 6 months.  Recorded calls that are deemed abusive or threatening are kept until any investigation action is completed.
• Live chat scripts made through our website are kept for 28 days.
• CCTV footage is normally kept for a period of 28 days unless it is to be used in relation to allegations of anti-social behaviour or criminal activity, when it may be retained for a period of up to two years after any legal proceedings have finished.
• If you have consented to having your photograph taken, consent given is valid for three years, after which the images and recordings will be either securely destroyed or archived. Group shot photographs will be archived and photographs of individuals securely destroyed. If we’d like to use any individual material after three years, we will contact you to ask if you would be willing to renew your consent.
• If you have consented to participate in a video calls (Remote Assist) to evidence and diagnose a repair in your property prior to a visit, or as preparatory viewing for routine inspections such as asbestos electrical or gas work, or for the purpose of property viewing - footage will normally be retained for a period of 7 years unless it is necessary to keep it for longer in the event of any queries.

Sharing your information

We will not share your information with any third parties for the purposes of direct marketing.

We may share your personal information but will only do so when this is fair and we have a lawful basis for doing so. In some circumstances we are legally obliged to share information. We do not rely on your consent to share your data, unless we specifically ask for it. Reasons for sharing your data include:

• To provide you with the services you require under the terms of your tenancy agreement (such as with repairs and maintenance contractors)

• To comply with the law (e.g., police, health authorities, inland revenue, government departments)
• Where there is a clear health, safety or other risk to yourself, staff and/or others
• Where we are requested to do so by another organisation in pursuit of its legitimate interests
• Child protection and safeguarding issues
• To seek legal advice or in connection with court proceedings or statutory action to enforce compliance with tenancy conditions
• For the detection and prevention of crime and fraud and for the prosecution of offenders
• Where you have provided consent

We may therefore share your information with third parties such as, but not limited to:

• Contractors providing maintenance and other housing related or support services, including our ‘out of hours’ service.
• Utility companies (water, electricity, gas)
• Parking Management Companies working for us on our estates
• Consultants providing services to us
• Police
• Fire & Rescue Service
• HMRC
• Local Authorities / councils, government regulators and agencies (such as the Department of Work and Pensions, Regulator of Social Housing or Homes England)
• The NHS, Primary Care Trusts, LiveWell
• Health professionals
• Partner landlords
• Legal advisors, the courts
• Solicitors for property conveyancing purposes
• Our insurers and auditors
• Language translation services
• Mediation partner organisations
• External assistance where you have agreed to a referral, e.g., to help with money problems
• Credit checking agencies and debt recovery agents
• Charities and voluntary organisations and our support partners
• A nominated third party where you have given us permission
• Banks to carry out payments through a secure system
• Companies that help us mail out newsletters etc.
• Training providers or learning organisations

Residents need to be aware that:

• current or forwarding addresses may be shared with utility companies and local authority council tax departments to ensure billing details are correct. This is because we have a legitimate interest in ensuring that charges are directed to those responsible.
• we may discuss your financial situation, rent payments (including any arrears) and any claims made for welfare benefits with an external debt advice agency, welfare rights advisor, government welfare and benefits agencies, or local authority housing advice and homeless prevention teams to make sure benefits are paid correctly
• we may pass your contact information to a third party to conduct surveys and research on our behalf to improve the services we offer. The third party would be bound to strict terms and conditions outlined by us and would not share your data with other organisations. You can opt out by contacting us.
• we may share your information as part of a safeguarding report where we have concerns about your wellbeing, safety and/or security (this is permitted within safeguarding laws)
• we may share your National Insurance number to verify your Universal Credit application and manage these payments
• we may also share your National Insurance number to prevent and investigate tenancy and Right to Buy/Acquire applications fraud.
• in the event of a situation where a member of staff feels vulnerable or in danger, we may activate emergency recording and GPS tracking to ensure the safety and wellbeing of our staff

We participate in the government CORE (Continuous Recording of Social Housing Lettings and Sales Data) data gathering scheme that gathers information and statistics about new lettings and sales. If your household enters a new social housing tenancy or purchases a social housing property, social housing providers will share your personal information with the Ministry of Housing, Communities and Local Government (MHCLG) for research and statistical purposes only.

For more information on what we share and why please see the Privacy notice for tenants and buyers of new social housing

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.
• 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 to automated decision making – PCH does not use automated decision making

More information on the individual rights and how they apply can be obtained by clicking here, 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.

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 a PCH staff member
• At our office at Plumer House, Tailyour Road, Crownhill, Plymouth, PL6 5DH
• Through our website
• Using social media - Facebook, Instagram, X
• By telephone
• In writing

Website:          www.plymouthcommunityhomes.co.uk

Email:              enquiries@plymouthcommunityhomes.co.uk

Tel:                  0808 230 6500

You also have the right to contact the Information Commissioners Office (ICO):

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.

Plymouth Community Homes Group

Registered Office: Plumer House, Tailyour Road, Crownhill, Plymouth, PL6 5DH

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.