Who are we?
Community Housing registered at 3 Foley Grove, Foley Business Park, Kidderminster, DY11 7PT under the company registration of 30464R is a wholly owned subsidiary of The Community Housing Group Ltd. and trades as Community Housing. We are responsible for providing and monitoring equipment and services to provide independence, safety, and security to our service users.
Community Housing is registered to process data with the ICO. Our registration number is ZB210539.
Processing your data
Community Housing needs to collect and process personal information about its service users in order to deliver our services to them. By reading this notice you will understand what to expect when Community Housing processes your personal information and your rights in relation to your data.
We are committed to handling your personal information fairly, lawfully and securely in line with current data protection laws. This privacy notice explains the personal information we process and for what purposes. It explains the data we will collect and hold about you. This may be information provided by you directly or on your behalf from a third party.
If you have any questions about how we use your personal information, our Data Protection Officer can be contacted by email at email@example.com or by post at "The Data Protection Officer, Community Housing, 3 Foley Grove, Kidderminster, Worcestershire, DY11 7PT."
|What Information do we collect?||Why do we collect this information?|
|Your Name||So, we can pass your details on to emergency services and call you by the name you wish to be called by|
|Your Address||So, we know where to send help. So, we can help you to access local support and services|
|Your date of birth||For emergency services to identify you|
|Home or mobile telephone number||So, we can contact you to ensure you are happy with our service or to wish you a happy birthday|
|Details of who to contact in an emergency||So, we can get help to you quickly|
|Details of your next of kin||So, we can inform them of any incidents where they need to be notified, with prior consent|
|Details of your Doctor||So, we can call for medical help when you're feeling unwell|
|Key safe code||So, we can get the emergency services into your property quickly without damaging it|
|Medical details||So, we can help you better over the phone and pass this information onto the emergency services to help them understand your needs|
|NHS Number||So, we can pass this on to the ambulance service to assist them in accessing your medical details|
|Physical description of you||If you have become lost, we can pass your description to the emergency services to help them find you quickly|
|Account holder and payment details||So, we can collect payment promptly and ensure arrears do not accrue|
|Call details||This helps the operator to see what has happened and identify if you need help, or signpost other services to you if you are happy for us to do so|
|Notes on calls||This helps the continuity between contacts, emergency services and our monitoring centre team|
|Details of your life||This information can be volunteered by you, so we can get to know you better|
|Details of holidays or absence from the home||This is so we don't try to contact you when you're not there, but we will still treat all calls from the equipment appropriately|
|Any changes to your information||This is so we have relevant and accurate information in order to deliver our service commitment to you|
|How you feel about our service||This is so we listen to our customers to improve things that could be better and celebrate the things we do well|
The lawful reasons for using your personal information
We only collect and use your personal information where it is permitted to do so by the laws that protect your privacy rights. These lawful reasons are:
- We need to use the information to perform a contract with you;
- It is necessary for us to so do to protect your vital interests (e.g. if you have a severe and immediate medical need);
- We determine it is fair to use the personal information either in our interests or someone else's interests, but there is no harm to you as a result - this may include where it is in our interest to contact you about relevant products or services with relate to services we may already provide to you;
- Where we need to seek your consent - If we ask for your consent, you have the right to subsequently withdraw it. We will let you know how to do that at the time we gather your consent.
Special protection is given to certain kinds of personal information that is particularly sensitive. For example - your health status, racial of ethnic origin, political views, religious or similar beliefs, sexual orientation, or criminal convictions and allegations. We will only collect and use this kind of personal information when absolutely necessary and for these lawful reasons:
- It is necessary for medical diagnosis or, to provide a health or social care service;
- It is necessary for us to so do to protect your vital interests (e.g. if you have a severe and immediate medical need); or
- You have specifically given us consent to use the information.
Do we share personal data?
We do not sell your data or pass on your data to 3rd parties that are not relevant to your service.
In order to deliver our service and, when there is a lawful reason to do so, we may share your data with:
- Your authorised contacts or representatives;
- Health and Social care providers;
- Emergency Services including your regional Ambulance, Police, and Fire & Rescue Services;
- Our 3rd party 'sub-processors' who provide services to us which enable us to deliver the overall service to our service users. A current list of sub-processors be found on our website at https://www.communityhousing.co.uk/dataprocessors;
Where your service is commissioned with us by another organisation, we may share your personal information with them as the owner of the data (for instances where we are a data processor).
At the time of our interaction with you we will respect your wishes not to share your personal information, unless there is a vital interest to protect your life or you from harm.
In the event that you activate your alarm service, but we have not been able to hear an affirmative response from you – Community Housing will share your details when contacting the ambulance or falls response service.
Keeping your personal data
Your personal information above will be recorded on the service user's Profile Plan and held within Community Housing's computer systems. All personal data stored both in paper or electronic format by Community Housing will be subject to the provisions within current data protection legislation (the UK Data Protection Act 2018, and the EU General Data Protection Regulations).
The length of time we keep your personal information for depends on the services we deliver to you. We will never retain your personal identifiable information for any longer than is necessary for the purposes for which we need to use it. Usually this means that we will keep your personal data for up to 7 years after the end of your service provision.
You or your authorised representatives can exercise your rights over your personal data at any time.
Transfer of Data Abroad
We do not transfer personal data outside the EEA.
Automated Decision Making
We do not use any form of automated decision making in our business.
Your rights and your personal data
Unless subject to an exemption under data protection laws, you have the following rights with respect to your personal data:
The right to be informed
Through our privacy notices we will inform you of who is obtaining and using your personal identifiable information, how this information will be retained, shared and secured and what lawful grounds will be used to obtain and use your personal identifiable information.
The right of access
You have a right to ask us what personal information we hold about you and to request a copy of your information. This is known as a ‘subject access request’ (SAR).
The best way to do this is to put your request in writing using our template form located below. When a Subject Access request is made, we will take reasonable steps to verify your identity before we can proceed so you may wish to submit a copy of your photo ID with your request to save time.
If you are seeking to obtain specific information (e.g. about a particular matter or from a particular time period), it helps if you clarify the details of what you would like to receive in your request. Very broad requests are likely to require clarification so we can make sure we know what information you require. If someone is requesting information on your behalf they will need written confirmation from you to evidence your authority for us to release this and proof of ID (both yours and theirs).
Where you are unable to put your request in writing, you can contact the Data Protection Team to arrange for your request to be documented on your behalf. If you choose to make a verbal SAR request, please contact us via the Contact Centre and request a call back from the Data Protection Team. We aim to contact you within 5 working days and will then send you a copy of the request to verify and attach ID before we start processing your request.
In response to SARs, we will provide you with a copy of the information we hold that relates to you in an appropriate format.
You also have the right to obtain a copy of the personal identifiable information we hold about you. This is known as a "subject access request" (SAR). Here is our Subject Access Request form.
The right to rectification
You can ask us to rectify your personal data if it is inaccurate or incomplete. Please help us to keep our records accurate by keeping us informed if your details change.
The right to erasure
The right to erasure is also known as "the right to be forgotten". In some circumstances, you can ask us to delete or remove personal data where there is no compelling reason for Community Housing to continue to hold it. This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data, and any legal/regulatory requirements for the data.
The right to restrict processing, and the right to object
You can object and ask us to restrict processing if you feel that the Group is using your personal identifiable information unlawfully and/or holding inaccurate, inadequate or irrelevant personal identifiable information which if used may have a detrimental impact on you and /or has an impact on your rights.
The right to data portability
For such companies as Utilities providers (e.g. Gas, Electric suppliers); you can request that information you've provided to them, such as meter readings be transferred to another company. If the situation arises where it would be helpful for you to move, copy or transfer personal data we hold about you, across different services, you may be able to ask us to do this.
Rights in relation to automated decision making and profiling
You can ask us to review any decisions that are determined by automated means, and object to our use of your personal data for profiling activities.
To make enquiries for further information about exercising any of your rights detailed in this privacy notice, then please contact us by email at firstname.lastname@example.org or by post at "The Data Protection Officer, Community Housing, 3 Foley Grove, Kidderminster, Worcestershire, DY11 7PT."
You can also make a complaint to the data protection supervisory authority in the region where your personal identifiable information is being held and processed. Where your personal identifiable information in held and processed in the UK, you can complain to the Information Commissioner's Office, at www.ico.org.uk
This privacy notice replaces any previous notices that we have published about using your personal identifiable information.
Document AMPN01 V1.2 - Date: 09/07/2020