This notice explains how we use your data and how we protect your privacy. As our services develop we will continue to update and review this statement to comply with both the law and customer feedback.
Data Controller and Purpose
Bancroft TMC (BTMC) is a registered data a controller under the Information Commissions Office (ICO), our registration number is Z2914352. We collect and process personal information about our residents to provide social housing and services related to housing. We process your data in accordance with the General Data Protection Regulation (GDPR) and UK privacy legislation. If you have any concerns you can contact BTMC on firstname.lastname@example.org
What is personal data?
Personal data is data related to a living individual who can be identified from the data. Sensitive personal data is data which includes more specific information about the individual such as ethnicity or sexual orientation.
What information we collect about you?
The information we require from you, as tenant(s) or leaseholder(s), includes:
- Full name (and proof of your identity / photo ID)
- Date of birth
- National Insurance number (your unique identifier)
- Contact details (phone, email or correspondence address)
- Details of anyone authorised to act on your behalf if applicable
- Basic details (name and DOB) of all household residents
- Proof of housing eligibility, any interest or equity in other property
- Other personal information that will vary on a case by case basis to help us resolve breach of tenancy, alleged anti-social behaviour, fraud or to process applications for parking, estate facilities or Right to Buy applications.
The information we may collect from you includes:
- Disabilities or vulnerabilities. We use this information to tailor our service to better meet your particular circumstances and needs. We may use this information for safeguarding of staff.
- Financial information. We may use this to help resolve arrears payments and optionally to provide welfare, benefits and debt advice as a free service to help you budget and pay your bills. We may use this to apply for funding on your behalf or make a referral to an appropriate support organisation with your consent.
- Health information. We require this to support applications for adaptations made to the property you are living in. More specific details will be provided if you use this service.
- Photo ID, bank statements, payslips or income details when we require this information for processing a house sale or purchase.
If you do not provide the information we need then we may not be able to provide all our services to you, and ultimately you may not be able to hold a tenancy or lease, or purchase a property.
How we collect your information?
BTMC collects information from you through a variety of sources including when you sign a tenancy agreement or purchase a lease, complete one of our forms, or when you call, write, email or meet us or respond to a survey. We may also collect information when you use our social media sites or website. Email correspondence may be kept as a record of contact.
CCTV is installed on our estate. They are fitted to monitor building security and for crime prevention and detection. The estate based CCTV is operated by Tower Hamlets Council for us and the images are stored by them. From time to time we may operate CCTV/sound recording and/or use photography to capture evidence of breach of tenancy, alleged anti-social behaviour or crime. We will not hold images for longer than necessary and will dispose of them securely.
We also hold information about our employees, including prospective, current and former employees.
How we use this information?
We collect and process your information so we can deliver effective housing services, statutory and otherwise. We do not want to be intrusive and will only collect the necessary information needed to effectively and efficiently run our services. The information you provide will not be seen by, or disclosed to anyone who shouldn’t see it. Unless specifically advised otherwise, we will only collect and process you information in order to carry out these functions:
- Managing your tenancy
- Property and estates maintenance and repair
- Adaptations to the properties we manage
- Delivering support to you or any member of your household within an agreed support plan
- Collecting information in order to monitor our performance
- Recruiting, supporting and managing our board, employees, agents and contractors
- Promoting the services we provide
- Carrying out surveys and conducting research
- Local fraud initiative
- Organising and assisting community events
- Offering opportunities involved
- Corporate administration and all activities we are required to carry out as data controller
- Ensuring we meet our legal obligations.
We use information about our residents and properties to inform strategic decision making through the preparation of block, estate or neighbourhood profiles.
How we use information about children?
BTMC does not normally process children’s information as part of the tenancy, as all tenants and leaseholders are adults. However, we record children’s basic information if they are residents in one of our properties, including their name and date of birth.
How we communicate with you?
BTMC needs to communicate with our customers and this will usually be in writing or by telephone, although we are increasingly using electronic and paperless means to do so. We are planning to move some of our services online as this is usually more convenient for you and more efficient for us. We deliver a copy of our regular newsletters to every property we manage in order to keep residents informed about our services and aware of opportunities for involvement.
We will only discuss and communicate your tenancy or lease details with those named on the agreement or those authorised (temporarily or permanently) by you. You can authorise someone temporarily verbally over the phone or permanently in writing.
Who we share data with
From time to time we may need to provide or obtain personal information relating to you or a member of your household from third parties. However, this will only happen so we can achieve the purposes detailed above and deliver the best possible service to you.
BTMC shares limited personal information with our contractors who are carrying out services on our behalf. Our contractors are required to comply with the law and our own data protection contract clauses to ensure data is managed appropriately and for specified purposes; these include to complete emergency, responsive or planned property repairs.
BTMC has a duty to public funds and may use personal information and data-matching techniques to detect and prevent fraud, and ensure public money is targeted and spent in the most appropriate and cost-effective way. Information may be shared internally and with Tower Hamlets Council, government departments, such as the Department for Work and Pensions, other local authorities and registered social landlords, utility companies, and the Police where we are legally allowed to do so.
How we store information
We take our responsibilities under the GDPR very seriously and will adopt and maintain high standards in respect of handling personal information. Your personal information will only be collected if it is necessary and proportionate to do so. We have a number of policies and procedures in place to ensure your data is kept secure and safe. Methods such as encryption, access controls and staff security training are all designed to ensure that your data are only made available to those who have a right to see them.
The law prohibits organisations from processing data outside the European Economic Area (EEA) and BTMC abides by this.
We will only hold your information for as long as is required by law to provide you with the necessary services. We follow the local government recommend guidelines around retention periods. For example, information relating to a tenancy agreement will be kept for as long as the agreement is active and for a period not exceeding six years afterwards. We have been reviewing our Retention and Disposable Schedule and the functionality of our IT system and will be implementing full disposal regimes as part of our regular system upgrades.
We aim to make our information easily accessible. Under the GDPR you have a number of rights over your personal data.
For further information, or to make a request to exercise any of your data subject rights you can contact us at the following:
12 Wickford Street
Tel: 0207 265 8343
If you wish to make a complaint about how we are processing your personal information you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO). You can find out how to contact the ICO on their website: https://ico.org.uk/make-a-complaint/