Melin Homes – COVID-19 Privacy Policy

This policy describes how Melin Homes may handle your data in relation to the current Covid‐19 public health crisis.

If you have any questions in relation to this document or how we use your personal data they should be sent to Melin’s Data Protection Officer. Contact details are in the main Privacy Policy.

This privacy information applies to Melin’s residents.

Melin Homes may collect, store, or disclose information in relation to the Covid‐19 epidemic for the following purposes:

  1. Safeguarding the health and safety of our residents;
  2. Providing care and support to our tenants who may need it;
  3. Safeguarding the most vulnerable among us and helping everybody comply with the government guidelines in the current context;
  4. To provide support to vulnerable residents who are shielding for their own protection, or the protection of a member of their household or someone they provide care for;
  5. To ensure that social distancing is maintained, and unnecessary contact avoided;
  6. Profiling, modelling and analysis that helps us to manage our services.

In order to fulfil the above purposes we may need to process information about your health status and special arrangements for managing urgent repairs or essential servicing.

The information below illustrates how we use the information we collect in relation to Covid 19 including the lawful grounds for processing and retention guidelines.

Relates to

Residents for whom we have a duty of care.

  • Monitoring the health of residents.
  • Referrals to support systems where there is a need for social care.
Legal basis

Article 9.2(h) GDPR: Health and Social Care.

Retention period

When government advice that the medical risks have been eliminated. No later than two months following a government announcement to the end of the pandemic.


It is not our intention to base processing of personal data or special category personal data on consent. There are other lawful bases on which we can rely.

You have the right to object to our processing of your personal data for Covid 19 purposes. If you wish to object please let us know.

Sharing or Disclosing information

We may share data with the following categories of recipients in line with the purposes and lawful bases for processing outlined above:

  1. Our contractors and other organisations we may ask to visit our premises
  2. Other support providers that we recommend and that you agree to be referred to.


We may undertake basic profiling to build up a picture of the demand for Covid-19 related support among our residents.

For more information on your rights, or the other ways we process your data, please refer to our Privacy Policy below.

Your privacy is hugely important to us here at Melin Homes. We want you to be confident that the information you give us when using our website or any of our services is safe and secure. In this Privacy Policy we'll explain how we use it.

We'll also tell you how and why we collect your personal info, your rights and choices when it comes to these details, as well as the steps we take to keep it secure and confidential.

Our Data Protection Officer is Melin’s Research & Development Manager. If you have any queries relating to our use of your personal information or any other related data protection questions, please contact us. Email or telephone 01495 745910, or you can write to us at Melin Homes Ltd, Ty'r Efail, Lower Mill Field, Pontypool, NP4 0XJ.

Melin’s servers are based in the UK. Most of our processors are based in the UK or European Economic Area (EEA); we only use processors outside of the EEA where there are adequate safeguards in place, such as the US-EU Privacy Shield, approved standard clauses, or binding corporate rules.

Legitimate interests pursued by Melin

1. Newsletters and marketing

Our newsletters contain information about Melin and the services we offer that we believe will be of interest to you. If you are a resident or a shareholder of Melin Homes there is a relevant and appropriate relationship between you and us, so the legal basis for processing your personal data is ‘legitimate interest’. If you would prefer not to receive Melin newsletters you may object to this type of processing. We will not share your personal data with any other marketing organisation.

2. Application for a home with us

Processing is necessary for the performance of, or setting up of, a contract (Rental Agreement) between you and Melin Homes.

3. Employment service

Engaging with this scheme is entirely voluntary and if you choose to use this service it will be based on your consent.

4. Homebuy affordable home ownership options

Processing is necessary for the performance of, or setting up of, a contract (house purchase) between you and Melin Homes.

5. Y Prentis

Processing is necessary for the performance of, or setting up of, a contract (of employment) between you and Y Prentis.

6. Care & Repair services

We use the personal information you give when you contact Care & Repair to check your eligibility for various grants and services. Often your name, address, phone number and the nature of any disabilities is provided to us by a third party, such as a hospital or social services Occupational Therapist, so that we can fit an adaptation to your home. We use your personal information to organise the installation that they recommend.

7. Applying for a job with Melin Homes

Processing is necessary for the performance of, or setting up of, a contract (employment) between you and Melin Homes. We may also ask if you would like us to keep your email address to notify you of new jobs as they become available.

8. Photographs at public events

We use photographs to showcase the ways that we support local communities.

9. Telephone calls

Calls may be recorded for training and monitoring purposes.

10. CCTV

Images are monitored and recorded for the purposes of crime prevention and public safety.

11. 100 Voices

Your views, experiences and opinions are used to inform and improve services.

Who do we share your data with and when?

1. Newsletters and marketing

We will not share your personal data with any other marketing organisation.

2. Application for a home with us

We will obtain references from previous landlords and credit checking agencies prior to entering into contract with you. If you are claiming Universal Credit or Housing Benefit we may need to share your personal data with DWP or the local authority in order that you can claim your correct entitlement. During your tenancy we may share your personal information with external contractors, but only where it is necessary, so that they can provide a service on our behalf. This is so that they can contact you to carry out our instructions, for example to make repairs or improvements to the property. You can find a list of the main contractors we use by following this [link]. We may use other contractors not on this list for specialist, urgent or ad hoc work. Our contractors may sub-contract the work to another contractor, you should see their privacy notice if you want to find out how they will process your personal data. When your tenancy begins or ends we will share this information with utility companies (water, gas, electric) to ensure that bills are accurately calculated.

We will share information with law enforcement authorities, such as the Police or local authority in relation to complaints about criminal activity or anti-social behaviour.

3. Employment service

With your permission, we will share your personal data with training providers, employers, Job Centre, and other employment support agencies.

4. Homebuy affordable home ownership options

We will not share your information with anyone else.

5. Y Prentis

We will share your personal data with employers who are part of the Y Prentis shared apprenticeship scheme and with CITB (Construction Industry Training Board). We have some legal obligations to share information about your earnings with HMRC.

6. Care & Repair services

With your permission, we will share your personal information with other services that may be of interest to you.

7. Applying for a job with Melin Homes

We will share your personal data when seeking references. We may ask that you complete a Disclosure and Barring Scheme application.

8. Photographs at public events

Some photographs will be publicly available but we will not share the rights to use your photograph with any other person or organisation.

9. Telephone calls

Recording will not usually be shared outside of Melin. Calls that direct threats or abuse towards our staff may be used to take legal action and shared with the police or legal advisers.

10. CCTV

We may use third party contractors to provide maintenance of the CCTV systems or to provide redaction or editing services where the Association cannot do so itself. The recorded images are, where necessary, disclosed to third parties such as the police.

11. 100 Voices

We will not share the information you provide with any other organisation.

Period of time that your data will be stored

1. Newsletters and marketing

We will store your contact information until you no longer wish to receive newsletters or communications from us.

2. Application for a home with us

We keep information relating to your tenancy for 7 years after the end of your tenancy. This may be longer if you owe us money when you leave.

3. Employment service

Once you are in sustainable employment we will continue to store your data for up to 18 months.

4. Homebuy affordable home ownership options

We will retain your data for as long as you have an interest in the property. Your financial verification documents will be deleted once the sale is concluded. When you no longer have an interest in the property we will dispose of your personal data after 7 years.

5. Y Prentis

We retain information about our employees for 7 years, from when your employment ceases. If you applied to work with us but did not become an employee we will keep your application for 2 years.

6. Care & Repair services

We keep information for 7 years.

7. Applying for a job with Melin Homes

Application forms, shortlists and interview notes are retained for one year. If you are an employee of Melin Homes employee related information will be kept for 7 years from when employment ceases.

8. Photographs at events

We store photographs for two years. If we would like to continue using a photograph beyond that time we will contact you again to ask if you agree to this. The images will be stored on servers located within the UK or European Economic Area (EEA).

9. Telephone calls

Recordings are stored for three months, or longer where needed in connection with proceedings.

10. CCTV

Recordings are stored for 60 days. For evidence purposes, until such time as the proceedings have been determined.

11. 100 Voices

We will continue to process your personal information until you tell as that you no longer wish to be involved in 100 Voices.

What if you don't give us information

1. Newsletters and marketing

We’d like to be able to tell you about Melin services but can only do this if we have your contact details.

2. Application for a home with us

If you do not provide the information we ask for we may not be able to offer you a tenancy agreement.

3. Employment service

Participation is voluntary, we will work with you to overcome barriers to getting into work. You may need to provide information to help us to help you.

4. Homebuy affordable home ownership options

We will not be able to enter into a contract with you.

5. Y Prentis

If you do not provide the information we ask for we may not be able to consider your application for an apprenticeship with us.

6. Care & Repair services

We might know about other services that you are eligible to receive. If you don’t provide information we may not be able to help you as much as we could.

7. Applying for a job with Melin Homes

If you do not provide the information we ask for we may not be able to consider your application for a job with us.

8. Photographs at events

You are not obliged to agree to us using your image and there will be no negative consequences if you prefer that we don’t.

9. Telephone calls

Recording is automatic.

10. CCTV

Recording is automatic.

11. 100 Voices

You won’t be able to take part in certain surveys but we will always welcome your feedback about the services we provide to you.

The existence of automated decision making, including profiling, as well as the anticipated consequences for the data subject

All our decision making includes human involvement and we do not carry out any automated decision-making (making a decision solely by automated means without any human involvement); or profiling (automated processing of personal data to evaluate certain things about an individual).

Special Categories of data

This may also be known as sensitive data. Special categories of data are those that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, or sex life or sexual orientation, or is genetic or biometric data used for the purpose of uniquely identifying an individual. We may ask you for health information to help us to make sure that we consider how suitable a property is to meet your needs. We may also ask for information from tenants or job applicants in order to monitor equality of opportunity. You are not required to provide this information if you prefer not to. Your decision not to provide this type of information will not be used against you. We will not use equality monitoring information to discriminate or make decisions about you.

Equality monitoring

What do we use the information for?

In order for us to provide services for all of our residents, we need to know about them. To do this, we use equalities monitoring to answer questions such as:

  • Who is using our services?
  • Who is not using our services?
  • What are the experiences of different groups of customers?
  • Are services reaching the people who need them most?

This information helps us to avoid discriminatory practices and inform decision-making, policy development and to improve our services.

What information do we hold and use?

We collect and process the following information:

  • personal information (such as name)
  • ‘Protected Characteristics’, as defined by the Equality Act (such as ethnicity, age, gender and marital status).

On what grounds do we use the information?

The Welsh Government regulates social housing in Wales (The Welsh Ministers have general functions under section 75 of the Housing Associations Act 1985 (as amended)). Among their expectations is that we deliver high quality services – that means providing services that meet people’s needs and expectations.

How do we collect this information?

We are collecting this information by phoning residents who agree to us contacting them for this Information.

Who we share your information with?

We will not be sharing your information outside of the Business Improvement Team at Melin Homes. High level information (i.e. anonymous data on numbers or percentages relating to each protected characteristic) is captured corporately so that we can use it to plan new services and monitor how accessible our services are to all who need them.

How long do we store it and is it secure?

We ensure that information is only held for as long as it is needed. Over time the information we hold about our residents becomes out of date and needs to be refreshed. After two years the data will be anonymised so will only be used for comparison and no individual person will be identifiable.
We take steps to keep your information secure:

  • Pseudonymisation – while not completely anonymous, the equalities monitoring data will not form part of your tenancy record.
  • Encryption – wherever possible our data is encrypted in transit and at rest. This means that if it is intercepted it cannot be decoded.
  • Data protection policies and procedures for employees.
  • Testing – we carry out regular integrity testing of our systems to combat cybercrime.
  • Our security arrangements have attained CyberEssentials accreditation.
  • Our employees receive instructions on data privacy and regular training.

What rights do you have?

  • The right of access - You are entitled to see the information we hold about you.
  • The right to rectification – you are entitled to have any wrong information we hold about you corrected.
  • The right to erasure/right to be forgotten
  • The right to restrict processing - Should you wish to limit how we use your data.
  • The right to data portability – there will be no requirement for data portability.
  • The right to object - In addition to the right to limit the use of your data, you also have a right to object to the use of your data for certain actions.

Where can I find out more?

If you want to know more about how Melin uses information, your rights or have a concern about the way we are collecting or using your personal data, we request that you raise your concern with us in the first instance.

You can contact our data protection officer at or by phoning us on 01495 745910.

Your rights

You have the right to ask us:

  • For access to the information we hold about you
  • To correct (rectify) any inaccurate data;
  • To permanently destroy (erase) any data we are processing about you;
  • To temporarily stop (restrict) processing information about you;
  • To permanently stop (object to) processing data about you.

While you have the right to ask for this, we may not be able to comply with your request. For example, the processing may be necessary for the performance of a contract with you, or because it is necessary for compliance with a legal obligation. If we cannot agree to your request we will tell you why.

The right to data portability

Your right to data portability allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability.

This right only applies to information you have provided to us and that is held in a digital format by us.

The right to lodge a complaint with the supervisory authority

If you have concerns about the way that Melin Homes is treating your personal data you may make a complaint to the Information Commissioner’s Office.

Information Commissioner's Office
2nd floor
Churchill House
Churchill way
CF10 2HH

Tel: 0303 123 1113
Fax: 0292 067 8399

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