Plymouth Community Homes Tenants

Privacy Notice  

Plymouth Community Homes Tenants  

Effective 10 December 2024

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.

The information provided in this notice gives an overview and examples of data processing, it does not necessarily include every scenario.  If there is anything you don’t understand or you have any feedback on this notice please contact 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

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

Why we collect information

We need your personal information to help us assess and manage your tenancy and to provide the services you have requested from us.

We are legally allowed to collect information for several different reasons:

• legal contract (for example, a tenancy agreement)
• compliance with law
• consent (such as customer consent for photos or films or for special projects.) We will always make this clear and explain how you can withdraw your consent
• vital interests (in other words, a life-or-death situation)
• legitimate interest (where we believe our reasons for using your data outweigh your rights and freedoms, such as when we record phone calls to monitor and improve our performance)

What information we collect about you

We collect the following information from you:

Prospective tenants

If you apply for a property with us, we need the following information before we will confirm the allocation of a property: 

• Name and date of birth
• Details for other household members - people who will occupy the property with you
• Contact details, such as telephone numbers and email addresses to help us communicate with you
• Communication needs
• Current address, previous address, and forwarding address
• Your application for rehousing and confirmation that the details on it are correct
• Information to confirm your identity such as birth certificate, benefit/pension letter, photographic ID such as passport, driving licence.
• National Insurance number
• Details of your financial circumstances, including employment details and welfare benefit entitlements
• Bank or building society details
• Other organisations who are involved with your household
• Details of criminal convictions or cautions against you or anyone on your application
• Household needs, for example, any relevant health conditions, addictions, or accessibility issues
• Diversity information such as ethnicity, cultural or religious beliefs/needs, to assist us with equality and diversity monitoring

Current tenants

In addition to the above, to help us to manage your tenancy and /or provide services to you we may also hold the following information about you:

• Family details including marital status
• We will add your photograph to your tenancy agreement in line with our tenancy fraud policy.
• Diversity information such as ethnicity, cultural or religious beliefs/needs, to assist us with equality and diversity monitoring
• Information about disabilities, vulnerabilities and health and any other support needs. With your consent we use this information to tailor our service to better meet your circumstances and needs. We will also use the information when assessing the need for any adaptations within your property.
• Current financial information. With your consent we may use this to help you resolve arrears payments and optionally to provide welfare, benefits and debt advice as a free service to help you budget and pay your bills. With your consent we may use this to apply for funding on your behalf.
• We may send you customer satisfaction surveys, which we will use to make improvements to our services. It is optional for you to respond to these surveys, and the information that you    provide will be anonymised.  
• We will collect demographic information such as preferences and interests, with your
• We will also ask for emergency contact details if you live in one of our Housing with Support      You may also choose to provide details if you are general needs tenant. We may also ask for emergency contact details if you attend resident involvement meetings with us on a regular basis.
• We may ask for additional information, with your consent, in connection with resident involvement activities.

Most of this information will be supplied by you directly, although we may sometimes receive information from outside agencies, such as family, neighbours, the police or the local council.

If you provide us with personal information relating to members of your family or your associates, we will assume you do so with their knowledge and consent.

We may also hold additional information necessary for the management of your tenancy agreement that will vary on a case-by-case basis. This would be to help us resolve a tenancy management issues such as arrears of rent, alleged or actual anti-social behaviour, criminal activities or fraud. This information may also potentially be used to safeguard our staff or mitigate any risks to other people including children.

Special Category or ‘sensitive’ Information

We minimise collection and use of sensitive information, however, given the services we provide, there are times when we use it to understand our customers and their needs better (such as providing accommodation for customers with disabilities or when dealing with neighbourhood disputes involving alleged criminal activity). We may collect information such as:

• ethnicity
• religious or other beliefs
• physical / mental health needs or conditions
• criminal convictions or offences

Where we process special categories of data, this is using the lawful basis of employment, social security and social protection law, which relates to our activities as a not-for-profit housing association.

There may be other times where we ask you for your explicit consent to use this type of personal information and you have a right to withdraw this consent at any time. However, if you do not wish us to process this data, it may have an impact on the services we provide to you. An example of this is where we ask your consent to share health data with our Livewell partnership.

How we collect your information

Plymouth Community Homes collects information from you via a variety of sources, including when you apply for one of our properties, complete one of our forms, write, call, email or meet with us or respond to a survey. You may provide us with information if you set up a MyPCH account to access services via our website. We may also collect information about you that has already been made public, such as the local newspapers etc. Here are some ways we may collect information:

Telephone calls – telephone calls made to Plymouth Community Homes 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.

Recordings of calls may be used, in pursuit of our legitimate interests, for the following reasons:

• For staff training and to improve customer service
• To check and measure whether we meet standards agreed with customers
• As evidence in investigations or disputes concerning either our customers or staff

Access to call recordings is through sampling apart from training purposes or when abusive or threatening behaviour has occurred, or a complaint has been made and requires investigation.

We may collect information when you use our social media sites, websites or self-service portal ‘MyPCH Account’. For more information refer to the separate Privacy Notice for PCH website users.

CCTV - We will also operate CCTV / sound recording in and around some properties in pursuit of our legitimate interests to provide a safe and secure environment for residents and to protect the general interests and well-being of all building users. For more information refer to the separate Privacy Notice for CCTV on PCH Estates.

We operate a CCTV system at Plumer House 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 at Plumer House

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.

We may receive information about you from third parties including:

• Devon Home Choice / Cornwall Home Choice in relation to your application for rehousing
• Your council or benefits office relating to your housing
• Credit agencies and previous landlords when you apply for housing
• Police, welfare or support organisations dealing with you
• Councillors, MP’s or other representatives acting on your behalf or with your instruction
• Financial institutions when you apply for our services

What we do with your information

We may use your personal information as follows:

Prospective tenants

We may use your personal information to help decide whether the property you have bid for with Plymouth Community Homes is right for you in your current circumstances by:

• Undertaking tenancy reference checks
• Undertaking affordability checks
• Undertaking risk assessments

Existing tenants

• To provide a service that you request as part of your tenancy agreement, for example, to provide a repairs service or adaptation
• To understand your needs and provide you with a better and more supported service
• To comply with our legal obligations
• To highlight health and safety or wellbeing issues
• For internal record keeping
• To provide statutory statistical information
• 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

We do not provide your personal information to other organisations for their marketing purposes.

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

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.

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 a maximum of 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 only share your information where we are legally permitted to do so, for example:

• To provide you with the services you require (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 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, prosecution of offenders and for the detection and prevention of fraud.
• Where you have provided consent

We may therefore share your information with third parties from time to time 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 within our estates
• Consultants providing services to us
• Police
• Fire 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

We do not provide your personal information to other organisations for their marketing purposes.

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

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.

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

Plymouth Community Homes Group

Registered Office: Plumer House, Tailyour Road, 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.