Fair Processing Notice
Who is responsible for my information?
Bournville Village Trust Group (the ‘Data Controller’) [Registration No. Z5847372], is responsible for the collection, processing, storage and safe keeping of personal data and other information as part of our business activities. We manage personal information in accordance with the Data Protection Act 1998 and from May 2018, the General Data Protection Regulations.
We take your privacy rights and the security of your information very seriously. This fair processing notice is supported by a detailed Personal Information Management System which we can provide on request. We will now set out in brief our approach to safeguarding the privacy rights of all individuals who engage with us.
This Fair Processing Notice applies to all personal information collected by BVT.
Our approach to collecting, storing and using personal information
About the personal information we collect
As a customer of BVT, the information we may collect about you and others could include, but is not limited to:
- Date of birth
- National Insurance number
- Contact details (phone/mobile/email)
- Communication preferences
- Racial or ethnic origin
- Religious or other beliefs
- Sexual orientation
- Physical or mental health or condition
- Convictions, proceedings and criminal acts
- Photographs and CCTV images.
We will not collect information about you that we do not need and we will make sure that the personal information we collect is updated to our systems in a timely and accurate manner. All demographic information held by BVT is used only for research purposes and is anonymised so you won’t be identified.
We may apply markers to your information (for example, in relation to your vulnerability or health status) to allow us to tailor services to you and/or if there is a need to protect the vital interests of our staff, contractors and customers.
How we use your personal information
We use your information to respond to your enquiries, provide you with services and manage your relationship with us. We may also use your personal information for research and development, customer administration, marketing and to identify areas where we can improve the services we provide. We only collect or use personal information for those purposes indicated in our notification with the Information Commissioner’s Office.
We will review the personal information we hold about you every 2-3 years and make changes to any service or information-handling processes when the law or the Information Commissioner request such changes. Your contact information will be reviewed more frequently with intermittent checks on telephone numbers and email addresses as and when you contact us.
Recording telephone calls
We only record incoming and outgoing calls to and from the Customer Service Team. An automated greeting message will inform you that the call will be recorded when you dial the main telephone number (0300 333 6540).
If you do not want to be recorded, you can be transferred to an extension that is not recorded. If you do not want to be recorded every time you contact us, we would request a letter or email expressing this request. This information will be stored on our document management system and a pop up alert will be put on your account with us.
When you are making a payment, the recording will pause when card details are given to comply with Payment Card Industry Standards (PCiDSS).
We record telephone calls for the following reasons:
- To help with complaints
- To help train and monitor employees service delivery
- To protect staff from abuse
- If our I.T. Helpdesk need to maintain the Call Recording System.
Recordings are encrypted and cannot be played after 3 months. The data is archived after 12 months.
We would only save the recordings for the following reasons:
- A recording can be saved for the duration of a complaint, this includes the appeal period
- A Senior Manager may save a call for training purposes until it is no longer useful
- A Senior Manager may authorise a recording to be kept if a caller is abusive towards staff and this is being investigated
Any calls stored for training purposes will not include any personal details that would identify you.
How long will we keep your personal information
We will keep the personal information you provide to us for the duration of your tenancy and up to 6 years after you leave BVT.
It is important that you keep us informed of any changes to your information. You may ask us to either remove or correct inaccurate information at any time.
Visiting our websites
When you visit one of our websites, we collect standard internet log information for statistical purposes. In short:
- We do not make any attempt to identify visitors to our websites. We do not associate information gathered from our sites with personally identifying information from any source.
- When we collect personal information, for example via an online form, we will explain what we intend to do with it.
Our websites contain links to various third party websites. We are not responsible for the content or privacy practices of any external websites that are linked from our sites.
Applying to work at BVT
If you submit an application to work for BVT, we will use your personal information to process your application and to produce and monitor recruitment statistics. We will not take up references without your prior permission. We will not share or disclose your information unless you have given us your consent or we are required to by law. Where we are required to carry out a Disclosure and Barring Service check, we will comply with the law and your rights when carrying out these checks.
We retain personal information relating to unsuccessful applicants for no longer than 6 months, for use in the event of an appeal. We produce statistical information to assist with recruitment analysis. We will collect additional information when we make a person an offer of employment. This could include requesting and holding a copy of your passport, national insurance number and in some circumstances a valid driving licence and applicable insurance and MOT documents.
How we share your personal information
We will only share your information with third parties with your consent, but there are occasions where we are required to share your information without your consent due to legal reasons. We may seek your consent directly, or may obtain it by telling you about how your information may be used at the time you provide information or enter into a contract (e.g. sign a tenancy agreement) with us.
Under no circumstances, would your information be shared outside of the European Union.
Our legal obligations
We will share specific and relevant information with law enforcement and government agencies or public bodies where we are legally required to do so. Examples may include:
- The prevention or detection of crime and fraud
- The apprehension or prosecution of offenders
- The assessment or collection of tax or duty owed to customs and excise
- Sharing in connection with legal proceedings
- Sharing in relation to the physical or mental health of an individual, where disclosure is required to protect them or others from serious harm
- Research and statistical purposes
We may also share your information with emergency services and local authorities, where this is necessary to help them respond to an emergency situation that affects you.
Sharing information with our partners
In some areas we may enter into partnerships with other organisations such as local authorities and the Police. For example, we may join a partnership to help prevent and control anti-social behaviour. We will enter into a data sharing agreement before any sharing takes place with a partner organisation.
Sharing information with our contractors and suppliers
There are some cases when we will share your information to support legitimate business purposes. We do this to make sure that we can meet your needs, and also to meet our health and safety obligations towards those delivering services on our behalf. This may include sharing information with our contractors and suppliers to allow them to carry out duties on our behalf or to meet contractual obligations we may have. For example, we may share information to enable our maintenance contractors to make appointments with you to carry out repairs and/or deliver services.
Keeping your information secure
We store personal information both electronically and in paper form. We implement security policies, processes and technical security solutions to protect the personal information we hold from:
- Unauthorised access
- Improper use or disclosure
- Unauthorised modification
- Unlawful destruction or accidental loss.
When you contact us, we may ask you to provide us with some information so that we can confirm your identity. If other people (e.g. family members, support workers, solicitors) act on your behalf, we will take steps to make sure that you have agreed for them to do so. This may include asking them to provide us with supporting information to indicate your consent. We do this to protect you and to make sure that other people cannot find things out about you that they are not entitled to know.
Employees and third parties who have access to, or are associated with the processing of, your personal information will be required to ensure compliance with the General Data Protection Regulation (GDPR) and make reasonable efforts to safeguard it.
Contacting us about your personal information
We will be transparent about what, why and how we collect, use and share your information. Please keep us informed if any of your information changes.
Finding out about the personal information we hold about you
You can ask us whether we are keeping personal information about you by writing to our Data Protection Officer.
The Data Protection Act 1998 gives you a number of rights in relation to your personal information. You can find out about your rights, and get further guidance, on the ICO website.
Requesting a copy of your personal information
As part of our service to you, we will supply you with copies of specific pieces of information, for example a copy of your rent statement. If you want a copy of information we have received or shared with third parties or a copy of everything we have on record relating to you, you will be required to put this in writing. This is called a ‘subject access request’.
If you make a subject access request we will provide you with a readable copy of the personal information we hold about you. To make a subject access request you must:
- Make your request in writing/complete a Subject Access Request form (available on request)
- Provide proof of your identity.
If we do hold information about you, we will:
- Give you a description of it
- Tell you why we are holding it
- Tell you who it could be disclosed to
- Let you have a copy of the information in an intelligible form
Please send your request to our Data Protection Officer, Bournville Village Trust, 350 Bournville Lane, Bournville, Birmingham, B30 1QY.
Withdrawing your consent
You have the right at any time to ‘opt out’ of us processing your personal information for direct marketing purposes or to prevent processing that you feel is likely to cause damage or distress. If you wish to do this at any time, please complete a Data Subject Consent Withdrawal form (available on request).
If you wish to ‘opt out’ of us processing personal information about a child under 16 who you have parental responsibility for, please complete a Parental Consent Withdrawal form (available on request) and send to our Data Protection Officer, Bournville Village Trust, 350 Bournville Lane, Bournville, Birmingham, B30 1QY.
Your request will be actioned immediately.
Questions and complaints
If you are concerned about how we are collecting, using and/or sharing your personal information, you can contact our Data Protection Officer. You can also obtain more information on your rights and our obligations as a Data Controller by contacting the Information Commissioner. You can also apply to the Court for compensation for distress and/or damages due to non-compliance of the Data Protection Act.