VHSS is committed to protecting your privacy and complying with the General Data Protection Regulations 2018. This Privacy Notice sets out the basis by which we collect, use and disclose the personal data of our tenants and employees / volunteers, as well as your rights in respect of such personal data.
How we collect information about you
We collect and process data for a variety of purposes which largely relates to the tenancy relationship that we undertake and also for the day to day administration and staffing of the company.
Some examples of where the company may collect, handle, manage, store and/or process data includes:
- Assessing individuals for prospective tenancy with company members
- Assessing and processing a tenant’s rent in accordance with the member’s rent policy or other such rent policy as the association may be obliged to apply
- Performing accounting and other record-keeping functions
- Applications for employment / volunteering opportunities with the company
- Monitoring and improving our service delivery by undertaking tenant surveys or research
- Undertaking criminal record vetting checks in particular for Employees, volunteers and applicant tenants
- Providing general information, updates, public relations and advocacy of the company’s activities
- Complying with our legal, regulatory, funding and contractual obligations
- Planning for the future delivery of services to meet the on-going needs of our tenants and clients
Examples of data that may be collected/processed in the above procedures include:
- Marital status
- Contact details (email, phone)
- PPS number
- Income details
- Employment status
- Medical / Disability information
- Criminal convictions
- CCTV images
- Images (photos or film) taken at publicity events
Lawful basis for processing
Lawful grounds for processing personal data, as set out in Article 6 of the GDPR will be applied to each data set (as set out above), as applicable. The lawful grounds are as follows and at least one will be applied to each data set:
- the consent of the individual;
- performance of a contract;
- compliance with a legal obligation;
- necessary to protect the vital interests of a person;
- necessary for the performance of a task carried out in the public interest;
- legitimate interests of company/organisation (except where those interests are overridden by the interests or rights and freedoms of the data subject).
Data Processing means performing any operation or set of operations on personal data, including:
- obtaining, recording or keeping data;
- organising or altering the data;
- retrieving, consulting or using the data;
- disclosing the data to a third party (including publication); and
- erasing or destroying the data.
Who we collect information on
We collect personal information about:
Tenants (current, former and potential tenants) and staff / volunteers (current, former and potential staff / volunteers).
How we use your information
We use the information we collect so that we can deliver our services to you. We use information to:
- manage allocations and lettings
- manage tenancies
- receive rent and service charges
- provide a repairs and maintenance service
- provide support services
- provision of additional services/assistance e.g. employability/digital inclusion
- resolve disputes
- investigate complaints
- Recruit and employ staff / volunteers
- Publications– we will send you general information about the company’s work, relevant news and upcoming events.
Sharing your information
We will not share your personal information without your consent, unless allowed by law. Examples of organisations we may share your information with, where appropriate, are:
- Contractors (for repairs, maintenance)
- Local Authorities
- Govt. Departments
- Utilities companies
- Support agencies
- Health services
Whenever we share your information, we will ensure that your personal information is handled under strictly controlled conditions and in accordance with the requirements of the GDPR. We will not transfer your personal data outside of the EEA without your explicit consent.
Accessing your information
Under the General Data Protection Regulations individuals can find out if we hold any personal information (including CCTV images of themselves) by making an ‘access request’. If we do hold information about you we will tell you what this is and let you have a copy of it. Under GDPR, you have the right to:
- Information about how and why their personal data is being processed, how long it will be retained for and the right to obtain access to that personal data.
- Have your access requests processed within 30 days of the request.
- Receive this information free of charge
- Have information corrected if it is inaccurate or incomplete
- Request the deletion or removal of personal data where there is no longer a reason for the continued processing / storage of data and where consent is withdrawn
- Restrict your personal data being processed further than was originally consented to
- Object to direct marketing and scientific, historical or statistical processing
- Lodge a complaint with the Data Protection Commissioner
If you wish to make an access request, please do so in writing (this can include email, text, social media contact) and we will respond to you in accordance with the above-mentioned rights.
Retention of Personal Data
Personal Data will be retained in line with the company’s Data Retention Policy. If you wish to request a copy of this policy please do so in writing.
Data Protection Contact Person in VHSS
The Data Protection contact person for VHSS for all queries and subject access requests is Mary O’Doherty Telephone: 085 1901899 | email: firstname.lastname@example.org