HOUSING SYSYEMS DATA PRIVACY POLICY
Introduction
Our Privacy Policy is explained in detail below, but the main points
to note are:
·
We will only ever ask for what we really need to
know
·
We will collect and use the personal date shared
with us transparently, honestly and fairly
·
We will always respect an individual’s choices
around the data that they share with us and the communications channels that
they ask us to use
·
We have security measures in place to protect
the personal data we hold and these are regularly reviewed
·
In general, unless still required in order to
fulfil a contract, personal data will be removed from our records 5 years after
the date it was collected
·
We never sell personal data.
At Housing Systems we are committed to protecting personal data
and being transparent about what data we hold. We have developed the following
policy to help you understand how personal data will be treated as you engage
with us both online and off. It’s important that organisations and individuals
know how we record personal data when you do things like visit our website or
use our other services so that they know they can trust us with that
information.
We ensure that we use personal data in accordance with all
applicable laws concerning the protection of that information. Maintaining
personal data in a secure manner is important to us. This privacy policy
explains all you need to know about:
·
What personal data we may collect
·
Why we collect it
·
What we do with it
·
When we may share it with others
·
How that data can be accessed and updated by the
individual.
By taking out a subscription, requesting a trial, arranging or
attending a training course or using any of our services, you accept this
privacy policy and authorise Housing Systems to collect, store and process personal
data in the ways explained.
If you have any questions about this privacy policy or would
like more information on our legal basis for processing personal data please
contact us using the details at the end of this statement.
Who we are
Housing Systems is a limited company registered in England
and Wales (registration number 3028972). Our registered office is at Archway Court, Broughton Hall, Broughton, Skipton BD23 3AE.
Where we collect personal data from
We collect personal data in the following ways:
When we are given it
DIRECTLY
We collect personal data for many reasons, including to
provide individuals with the services they are entitled to in line with the
contract their employer has with us, to enable us to communicate with them about
our services and to send them information that they have requested.
Depending on what that interaction with us is, we may process personal data
when:
·
An individual requests a service from us - such
as requesting a free trial
·
An organisation becomes a subscriber
·
An organisation buys our publications or requests
a training course, or
·
An individual applies for a job or acts as a
freelancer for us.
This data may be collected via any paper forms completed,
telephone conversations, emails, face-to-face interactions, digital forms
completed via our website, or communication via social media.
When we are given it
INDIRECTLY
Personal data may be shared with us by third parties for
example where an individual attends a training course or workshop arranged by
that third party. The Privacy Policy of this third party organisation should be
checked to understand fully how they will also process personal data.
We may also access information available publicly, such as
via Companies House or information that has been printed in newspapers,
magazines etc.
When we collect it as
individuals use our WEBSITE
Like most websites, we use cookies to help us make our
website better. Cookies mean that a website will remember a user. They’re small
text files that websites transfer to a computer, phone or tablet. They make
visits to websites faster and easier, for example by automatically filling a
name and address in the text fields.
We use cookies, like most websites, to help us provide users
with the best experience when they visit our site. Some cookies are essential
to the smooth running of our website, for example our pages recording user
frequency replies on this. Other cookies
allow us to understand how visitors are interacting with our website, so that
we can improve it.
All browsers allow you to control which cookies you accept
and which you delete. For more information about cookies, please see http://www.allaboutcookies.org/.
Please note, no personal data is held on our website.
What types of data do we collect?
Non-personal data
This type of data does not identify an individual, but it
does help us to improve our services. When a user visits and looks around our
website, we record things like IP (internet protocol), which pages are visited,
when they were visited, and the browser being used. This information helps us
create a better experience for everyone who uses our website.
Personal data
This means any information that may be used to identify an
individual, such as a name, telephone number, postal and email addresses and
includes:
·
Full name
·
Contact details including work postal address, work
telephone number(s) and work email address
·
Records of correspondence and engagement with us
and the subscription an organisation holds or have held with us
·
Occupation or other biographical information
·
Other information shared with us.
We will only ask for personal date where it is appropriate,
reasonable and relevant.
Children’s data
We do not knowingly process data of any person under the age
of 16. If we come to discover, or have reason to believe, that an individual is
under 16 and we are holding their personal data, we will delete that
information.
How we use personal data
Subscribers
If an organisation signs up to become a subscriber to the
Housing Systems website, we have a contractual obligation to provide them with
the membership benefits they have signed up for. If they do not wish to receive
these benefits, let can us know by getting in touch using the details in the
‘Contact us’ section below.
We use a range of methods to keep in contact with our subscribers
and their staff - email, direct mail, and occasional telephone calls in order
to fulfil the requirements of our contract – unless an individual has opted
out.
An organisation’s employees are in control of how we contact
them. If they want to stop receiving emails, they are able to click the
‘unsubscribe’ link at the bottom of any of our Newsletters. If they would like
to make changes to the type of communications they get from us, or if their
personal details change, we encourage them to get in touch using the details in
the ‘Contact us’ section at the end of this statement.
Administrative
communications to subscribers
We will also communicate with organisations by post, telephone, and email
to deal with any administrative matters. Even if Companies or individuals opt
out of communications from us, we may still need to communicate occasionally
for administrative purposes.
Newsletters and
Briefings
If an individual lets us know that they are interested in our newsletters
and briefings they will then receive communications relating to the
newsletter/briefing. They can withdraw their consent, unsubscribe, or update
their preferences at any point by using the contact details in the ‘Contact us’
section below. If they make any changes to their consent, we will update their
records as soon as we possibly can. Email communications will be stopped immediately. It may take up to 14 days to stop any postal
communications from us being sent.
Email Query Service
If an organisation or a member of their staff emails our query service to
seek help with their work, our staff may take notes on the information given to
us and record it on our systems. This data
is used for quality assurance, complaint investigations and to collect the data
needed to fulfil our obligations to our subscribers in terms of interactions
with our services.
Please note that we will immediately delete any benefit
query that is sent to us with personal data of any of an organisation’s
customers. We will also notify our Main
Contact at the organisations of this as it constitutes a data breach.
We may use this data for statistical reports. These
statistics will not include information that could be used to identify any
individual.
Any personal data collected is held for 5 years in case of
complaint investigations. An individual can ask for us to remove their data
before then if they do not want us to hold it.
Representation
If an organisation or a member of their staff receives advice or representation
from us, we will need to process their personal data because of their specific
relationship with us. We use a customer relationship management system
(Insightly) to support our work. This means that we can keep the information
provided to see the history and relevant details of their interactions with us.
This ensures that we can provide organisations with appropriate and accurate
advice and representation. We take information security very seriously and no
one is allowed to access our system or files unless they need this to provide
the service to our member organisations or to regulate the quality of the
service.
Any personal data collected is held for 5 years in case of
complaint investigations. An individual can ask for us to remove their data
before then if they do not want us to hold it.
Non-Subscribers
We use a range of methods to keep in contact with
non-subscribers and their staff - email, direct mail, and occasional telephone
calls or order to keep them up to date with information relating to the welfare
reforms – unless an individual has opted out.
We will always gain an individual’s consent to contact them
by email for marketing purposes. We will send marketing by post, on the basis
of it being within our legitimate interests (see below section on ‘Our legal
basis for processing your data’ for more information) to do so, unless an
individual has opted out.
We send the following marketing email communications from
time to time:
·
Updates about Housing Systems work, including
newsletters, magazines, and other publications with useful information about
welfare benefits and welfare reform;
·
Updates about what training is currently
available and in what areas
·
Training materials, letters and flow charts
Non-subscribers who have opted in to receive these updates
can choose how they hear form us, whether by post, phone, or email. We will
never share or sell personal data to a third-party organisation for its
campaigning or marketing purposes.
Non-subscribers can withdraw consent, unsubscribe, or update
their marketing preferences at any point by using the contact details in the
‘Contact us’ section below. If they make any changes to their consent, we will
update their record as soon as we possibly can. Marketing email communications
will be stopped immediately if they unsubscribe. Updates to contact preferences
sent by email may take up to one week to process. It may take up to 14 days to
stop any postal communications from being sent.
Business services and professional
contacts
We may collect data about the professional contacts and
partners we work with, or who have used our services such as attending training
courses or buying publications. Personal data collected in this way will be
processed according to data protection law and this policy.
We may send our professional contacts information and
updates about our work by email and by post if they have opted in to these
services. They can opt out of receiving this information at any time. They can
withdraw their consent, unsubscribe, or update their preferences at any point
by using the contact details in the ‘Contact us’ section below. If they make
any changes to their consent, we will update their record as soon as we
possibly can. Email communications will be stopped immediately. It may take up
to 14 days to stop any postal communications from being sent.
Job applicants and volunteers
When an individual applies for a job or contract training
role, their personal data will be collected to monitor the progress of their
application. Where we need to share their data, for example to gather
references, they will be informed beforehand unless the disclosure is required
by law. These checks are only done after a position has been offered to the
successful candidate. Personal data about unsuccessful applicants is held for
12 months. An individual can ask for us to remove their data before then if they
do not want us to hold it.
Our legal basis for processing
personal data
We need a lawful basis to collect and use personal data
under data protection law. The law allows for six ways to process personal data
(and additional ways for sensitive personal data). Four of these are relevant
to the types of processing that we carry out at Housing Systems. This includes
information that is processed on the basis of:
·
A contractual relationship, for example, to
provide the goods or services an organisation has purchased from us including a
membership subscription
·
A person’s consent, for example, to send direct
marketing by email
·
Processing that is necessary for compliance with
a legal obligation, for example accounting data
·
Housing Systems legitimate interests: please see
below for more information.
Personal data may be legally collected and used if it is necessary
for a legitimate interest of the organisation using the data, if its use is
fair and does not adversely impact the rights of the individual concerned. When
we use personal data, we will always consider if it is fair and balanced to do
so, and if it is within reasonable expectations. We will balance an
individual’s rights and our legitimate interests to ensure that we use personal
data in ways that are not unduly intrusive or unfair.
Our legitimate interests include:
·
Company governance: including delivery of our purposes,
statutory and financial reporting and other regulatory compliance purposes
·
Administration and operational management:
including responding to solicited enquiries, providing information and
services, research, events management, administrating recruitment processes for
staff and freelancers.
Anyone who requires more information on our uses of
legitimate interests, or to change our use of personal data in this manner, should
get in touch with us using the details in the ‘Contact us’ section below.
When we may disclose
personal data
We will not share any personal data with any third party –
except where:
·
The third-party is helping us provide a service
to an organisation or a person working for that organisation*or
·
The transfer is to a secure data processor,
which carries out data processing operations on our behalf, for example to
process a mailing*or
·
It is necessary to protect the vital interests
of an individual – i.e. to protect someone’s life, or
·
We have obtained the individual’s consent.
*These third parties have access to that personal data only
to perform these specific tasks on our behalf and are obligated not to disclose
or use it for any other purpose.
We will never share or sell personal data to a third-party
organisation for any purpose.
How we keep personal data secure
We endeavour to ensure that there are appropriate and
proportionate technical and organisational measures to prevent the loss, destruction,
misuse, alteration, unauthorised disclosure or of access to personal data.
We use
appropriate technological and operational security measures to protect your
information against any unauthorised access or unlawful use, such as:
·
Ensuring the physical security of our office
·
Ensuring the physical and digital security of our equipment and devices
by using appropriate password protection
·
Maintaining an internal data protection policy for, and delivering data
protection training to, our employees
·
Limiting access to personal information to those in our company who need
to use it in the course of their work, and
·
Using trusted third-party suppliers to provide services for data
recording, processing and mailing.
Unfortunately, sending information via the internet is not
completely secure. Although we will do our best to protect personal data, we
cannot guarantee the security of the data sent to third parties e.g to process
our Newsletters. Once we have received personal information, we will use strict
procedures and security features to try to prevent unauthorised access.
The security of personal data is important to us but it must
be remembered that no method of transmission over the internet, or method of
electronic storage is 100% secure. While we strive to use commercially
acceptable means to protect personal data we cannot guarantee its absolute
security.
How we use data processors
We may use third parties for software, systems, platform
support, print and mailing, cloud hosting services. We may also use a third-party supplier to
manage marketing or to conduct surveys on our behalf. We actively check these
companies to ensure privacy and security is protected. These third-party
suppliers are only permitted to use the data in accordance with data protection
law, under instruction from us, and in accordance with a data processing
agreement made between Housing Systems and the supplier.
Organisations can find out more about the suppliers we use
by getting in touch with us using the details in the ‘Contact us’ section
below.
Links to websites
Our website contains links to other websites. Our inclusion of such links does not imply that we endorse those websites. We do not control the content of those third party websites, and assume no responsibility for the third party or their polices or practices. We encourage users to review the privacy policies of these third party websites because their procedures for collecting, handling and processing personal data may be different from ours.
How long we keep personal data
Whatever the relationship with us, we will only store personal
data for a limited amount of time.
The length of time we keep personal data may depend on the
reasons we are processing it, on the law or regulations that the information
falls under, such as financial regulations, Limitations Act, Health and Safety
regulations, or on any contractual obligation we might have, such as with government
contracts. For business case data, we will anonymise the data so no individual
is identifiable.
In general, unless still required in order to fulfil a
contract, personal data will be removed from our records 5 years after the date
it was collected. After this period, we will confidentially dispose of and / or
permanently delete personal data.
If an individual asks not to be contacted by us, we may keep
some basic information about them on our suppression list to avoid sending
unwanted materials in the future.
Rights to your personal data
An individual has a right to request a copy of the personal
information we hold about them, and to have any inaccuracies corrected. They
also have the right to request that we erase their personal information, restrict
our processing of their personal information or to object to our processing of their
personal information.
An individual who wishes to exercise these rights, may need
to prove their identity with two pieces of approved identification. Requests used
be submitted using the contact details below and we will respond within 28
days. An Individual should provide as much information as possible about the
nature of their contact with us to help us locate their records, including all
of the email addresses they have used when in contact with us.
Where an individual has provided their consent for us to use
their personal information, they always have a right to withdraw their consent
at any time.
How to find out more about personal
data rights
The way we collect and use personal data on is in accordance
with the General Data Protection Regulation (GDPR) and the Data Protection Act.
For further information please visit the Information Commissioner’s Office at
www.ico.org.uk.
Ability to edit and delete account
information preferences
An individual has a choice about whether or not they wish to
receive information from us. If they do not want to receive any information or
only certain types of information then they can update those choices at any
time.
The accuracy the personal data we hold is important to us. This
can be updated at any time. If someone would like to change their preferences
or update the details we hold about them they can get in touch using the
details in the ‘Contact us’ section below. If an individual would like changes
to be made to their personal data, they should provide as much information as
possible about the nature of their contact with us to help us locate their
records, including all of the email addresses they have used when in contact
with us.
Contact us
If you have any questions about this policy, would like more
information, or want to exercise any of rights in relation to data protection,
you can get in touch with us in the following ways:
• Email us at advice@ucnotes.co.uk
• Telephone us on
01756 796394
• Write to us
at Housing Systems Ltd, Archway Court, Broughton Hall, Broughton, Skipton BD23 3AE
Changes to this policy
This policy may change, but we will always have the latest
version available for you on our website. If there are any major changes, we
will add a notice on our website or contact you. This policy was last updated
on 19th April 2022.