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Privacy
Melin Homes – Privacy Notice
Introduction
Melin Homes Limited is a registered social landlord in Wales.
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 what personal information we hold about you and how we use any personal data we collect about you when you use any of our services or when you visit our website.
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.
1. Controller
Melin Homes Limited is the controller and responsible for your personal data (collectively referred to as “Melin”, “we”, “us” or “our” in this privacy notice).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice or the our use of your personal information, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Our full details are:
Full name of legal entity: Melin Homes Limited
Email address: Email our Data Protection Officer at dpo@melinhomes.co.uk
Postal address: Melin Homes Ltd, Ty'r Efail, Lower Mill Field, Pontypool, NP4 0XJ.
Telephone number: 01495 745910
You can also contact the Information Commissioner’s Office (ICO) via www.ico.org.uk for information, advice or to make a complaint.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier, and job title.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes payment card details.
- Transaction Data includes details about payments to and from you.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
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.
2. Purpose of collection, legal basis, storage and data sharing
a. Application for a home with us
Purpose of collection and processing
We will ask for information about your name, address, national insurance number and date of birth so that we can confirm your identity. We need to do this to comply with our legal obligations and in order to enter into a contract (rental agreement) with you. We may ask to take a photograph so that we can be sure of your identity when we deal with you in future. We will ask you for information about other people in your household so that we can make sure that any home we offer will be suitable for your needs. We will collect information about your finances so that we can establish that your home will be affordable for you, and will not lead to under- or over-crowding. We will also ask for your permission to provide your name to the company that supplies water, gas, electricity or any other utility to the property so that we can ensure that billing is properly set up. You don’t have to tell us about any health conditions you have, or that any member of your household has. However, if you do this will help us to make sure that we consider how suitable a property is to meet your needs. We may also gather additional information so that we can offer you additional help, or recommend other services to you. When we do this we will explain what information we want, why we want it and what we will do with it. If we need your consent we will collect it at that time and remind you of your data protection rights.
Once you are a tenant of ours, we may need to share your contact information – typically name, address and phone number – with external contractors to enable us to carry out repairs or improvements on your home/our property. Our Contractors page shows the main developers, contractors and service providers that we share information with. If you want to know how they process your information, you can find out by looking at their Privacy Notice. Privacy notices can usually be found on the organisation’s website. If you are unable to find it there you may wish to contact them by telephone; you can find details on our Contractors page. Some of these organisations will also share your information with sub-contractors or specialist suppliers depending on the nature of the repair, defect or improvement to be addressed. Please be aware that we do not take responsibility for such websites, which may have different privacy and security policies and procedures to us.
We may make use of lone workers devices that can record audio when we are visiting your property. We also share data with organisations we have Data sharing agreements with. If you have any questions about this, kindly contact us.
Legal basis for processing by Melin
Processing is necessary for the performance of, or setting up of, a contract (Rental Agreement) between you and Melin Homes. We also have a legal obligation on occasions to share information with the police or other organisations we have data sharing agreements with.
Who do we share your data with and when?
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.
Period of time that your data will be stored
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.
What if you don't give us information?
If you do not provide the information we ask for we may not be able to offer you a tenancy agreement.
b. Employment service
Purpose of collection and processing
This is our initiative to help our residents get into employment. With your consent, if you want to use this service we will use the contact information we already have about you. We will ask you about any barriers to employment that you face. You don’t have to tell us about these, but if you do it will enable us to tailor the service to your needs.
Legal basis for processing by Melin
Engaging with this scheme is entirely voluntary and if you choose to use this service it will be based on your consent.
Who do we share your data with and when?
With your permission, we will share your personal data with training providers, employers, Job Centre, and other employment support agencies.
Period of time that your data will be stored
Once you are in sustainable employment we will continue to store your data for up to 18 months.
What if you don't give us information?
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.
c. Homebuy affordable home ownership options
Purpose of collection and processing
We need to collect certain personal and financial information from you in order to enter into a contract to help you buy a home through us.
We may also store your personal data as a private resident or homeowner
Legal basis for processing by Melin
Processing is necessary for the performance of, or setting up of, a contract (house purchase) between you and Melin Homes. As a homeowner or any third party reporting any anti social behaviour, estate management or housing management issues, we will store only data where you have consented to it
Who do we share your data with and when?
We will not share your information with anyone else.
Period of time that your data will be stored
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.
What if you don't give us information?
We will not be able to enter into a contract with you.
d. Y Prentis
Purpose of collection and processing
In order to enter into a contract of employment with you we will need to collect personal information about you, including your bank details and qualifications. We may carry out pre-employment checks (references).
Legal basis for processing by Melin
Processing is necessary for the performance of, or setting up of, a contract (of employment) between you and Y Prentis.
Who do we share your data with and when?
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.
Period of time that your data will be stored
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.
What if you don't give us information?
If you do not provide the information we ask for we may not be able to consider your application for an apprenticeship with us.
e. Applying for a job with Melin Homes
Purpose of collection and processing
When you apply for a job with Melin Homes we will collect personal information to maintain contact with you and in order to enter into a contract of employment with you. We will also collect information about your skills, qualifications and employment history and details of referees.
Legal basis for processing by Melin
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.
Who do we share your data with and when?
We will share your personal data when seeking references. We may ask that you complete a Disclosure and Barring Scheme application.
Period of time that your data will be stored
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.
What if you don't give us information?
If you do not provide the information we ask for we may not be able to consider your application for a job with us.
f. Photographs at public events
Purpose of collection and processing
We often use photographs to share news about an event, or to publicise future events. Images may be used in press releases, on social media, printed publicity and published on Melin Homes’ website. They will be stored securely, and we will delete them after they are no longer needed for publicity purposes. We will not use your image in this way without first asking for your consent. At large events we will display notices warning that photographs are being taken in the area, and who to speak to if you or your child prefer not to be photographed.
Legal basis for processing by Melin
We use photographs to showcase the ways that we support local communities.
Who do we share your data with and when?
Some photographs will be publicly available but we will not share the rights to use your photograph with any other person or organisation.
Period of time that your data will be stored
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).
What if you don't give us information
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.
g. Telephone calls
Purpose of collection and processing
When you speak with us by telephone, the call may be recorded for training and monitoring purposes.
Legal basis for processing by Melin
Calls may be recorded for training and monitoring purposes.
Who do we share your data with and when?
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.
Period of time that your data will be stored
Recordings are stored in line with our retention schedule. Please contact us if you need information on this.
What if you don't give us information?
Recording is automatic.
h. CCTV
Purpose of collection and processing
We operate CCTV recording at our offices and some of our schemes. Prominent notices will inform you about the existence of CCTV cameras.
Legal basis for processing by Melin
Images are monitored and recorded for the purposes of crime prevention and public safety. The legal basis for processing this data is public interest.
Who do we share your data with and when?
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.
Period of time that your data will be stored
Recordings are stored for 60 days. For evidence purposes, until such time as the proceedings have been determined.
What if you don't give us information?
Recording is automatic.
i. Melin Voices
Purpose of collection and processing
Your experiences and views matter to us. All our residents are called Voices and we send out surveys by email, text and post to ask all residents questions about our services and what they think of them in order to improve our services.
Legal basis for processing by Melin
Your views, experiences and opinions are used to inform and improve services. The legal basis for collecting and processing personal information is consent.
Who do we share your data with and when?
We will not share the information you provide with any other organisation.
Period of time that your data will be stored
Recordings are stored in line with our retention schedule. Please contact us if you need information on this.
What if you don't give us information?
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.
j. Communicating with you via social media
Purpose of collection and processing
We will endeavour to use your preferred method of contact whenever possible. As well as traditional methods we also use social media (such as facebook or WhatsApp) to communicate with you. If you contact us using social media you will have agreed to that platform’s terms and conditions. We will not initiate contact with you via social media without your consent, but will reply to messages you send to us. If you wish to cease communicating with us via social media you can find instructions on how to block our number on those platforms.
Legal basis for processing by Melin
It’s important that we make it as easy as possible for you to communicate with us. Social media platforms offer the advantage of being free to use and to send more than text messages. We have a legitimate interest in contacting you using whatever data we hold in order to recover overdue rents.
Who do we share your data with and when?
You can find the terms of use and privacy notices on the websites of Facebook and WhatsApp to better understand how they use and share your data.
Period of time that your data will be stored
You can find the terms of use and privacy notices on the websites of the relevant social media site to better understand how long they retain your data.
What if you don't give us information
You are not obliged to agree to us communicating with you via social media and there will be no negative consequences if you prefer not to.
k. IES/Smart meter devices
Purpose of collection and processing
Where you live in a property which has been fitted with an IES Device and Smart Meter (or needs to be fitted with an IES Device/ Smart Meter) we may need to capture monitoring information using sensors in your home. There are a number of schemes we participate in to trial the effectiveness and efficiency of different energy saving measures. This is part of our commitment to achieving ‘net zero’. If your home is chosen for inclusion for monitoring you will be provided with more information about what information we will capture, consent, data sharing and retention. In some cases we will need to share your key contact details comply with our obligations to Welsh Government/Welsh Government service providers as part of their initiatives (such as the optimised retrofit programme) . The data collected by the monitoring devices is about the property and will not be linked back to your personal data.
You may be offered the option of having a smart meter activated by a service or utility provider, there are additional services available which can provide you with feedback on how to improve energy efficiency and reduce costs - this is up to you if you agree to have your utility/usage data analysed.
Legal basis for processing by Melin
It’s important that we find the best ways of making our homes as efficient and affordable as possible for residents. No personal data is being shared so no legal basis is required.
Who do we share your data with and when?
We will supply you with details of any sharing if your home is selected for monitoring.
Period of time that your data will be stored
We will supply you with details of any sharing if your home is selected for monitoring.
What if you don't give us information?
The information will be collected by monitoring equipment installed in your home. We will supply you with details of any sharing if your home is selected for monitoring.
4. International transfers
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.
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
5. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
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 employees receive instructions on data privacy and regular training.
6. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You may withdraw your consent to us processing your personal data at any time by contacting dpo@melinhomes.co.uk. 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. We will also let you know what processing will stop if you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
7. Glossary
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
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).
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