1. Introduction

This Notice explains: 

-    what information we collect 
-    when we collect it, and, 
-    how we use the information

During the course of our activities we will process information about you, ‘personal data’ and we recognise the need to treat it in an appropriate and lawful manner. The purpose of this notice is to make you aware of how we will handle your information.

This information can be held electronically on our systems, on paper, recorded or otherwise.

2. Who are we?

Maryhill Housing (MH) is a Scottish Charity (Scottish Charity Number  SCO32468), a registered society under the Co-operative and Community Benefit Societies Act 2014 with Registered Number 1904R(S) and having their Registered Office at 45 Garrioch Road, Glasgow, G20 8RG. 

MH take the issue of security and data protection very seriously and strictly adhere to guidelines published in the Data Protection Act of 1998 and the General Data Protection Regulation (EU) 2016/679 which is applicable from the 25th May 2018, together with any other relevant laws now and in the future. 

We are notified as a Data Controller with the Office of the Information Commissioner under registration number Z5989470 and we are the data controller of any personal data that you provide to us.

Any questions relating to this notice and our privacy practices should be sent to The Data Protection Officer, Maryhill Housing, 45 Garrioch Road, Glasgow, G20 8RG, by phone on 0141 946 2466, or e-mailed to enquiries@maryhill.org.uk.

3. How we collect information from you and what information we collect

3.1    Introduction

We collect information about you:
•    when you apply for housing with us, become a tenant, request services/ repairs, enter in to a factoring agreement with ourselves and provide us with your personal details ;
•    when you apply to become a member;
•    from your use of our online services , whether to report any tenancy/ factor related issues, make a comment, complaint, suggestion or other; 
•    when you contact us directly by letter, phone call, via social media or other methods to request a service, make a comment, complaint, suggestion or other;
•    from your arrangements to make payment to us (such as bank details, payment card numbers, employment details, benefit entitlement and any other income and expenditure related information);

3.2    Information Collected

3.2.1    Housing
We collect some or all the following information, as required, about you if you are applying for a house or are a tenant of MH:

•    Name
•    Address
•    NI Number
•    Date of Birth
•    Employers information
•    Doctors information
•    Health information
•    Immigration papers/Passport information
•    Next of Kin
•    Driving License
•    Department of Work & Pensions letters and information
•    Information on Carers; Support Workers;  Link Worker
•    Sexual orientation
•    Religious beliefs
•    Ethnic group
•    Addictions
•    Schedule 1 Sex Offenders Criminal Convictions
•    Information on charges
•    Anti-Social Behaviour information 
•    Incident sheets (tenants) 
•    Financial Information – Bank account, confirmation of income, potentially bank statements and other financial information, direct debit information, details of benefits, pensions (private and state)
•    Payments made by you to us;
•    Complaints and compliments 
•    Repair requests and completion records
•    Other correspondence
•    Recording of telephone calls

This information will be collected at different times, for example on applying for a tenancy; being allocated a house; if an incident occurs etc.

We receive the following information from third parties when you apply for a house with or are a tenant of MH:

•    Initial application from Glasgow Housing register
•    Section 5 Homeless from Glasgow City Council
•    Community Safety Glasgow 
•    Police - Disclosures of offences and incident numbers 
•    Glasgow City Council Benefits information 
•    DWP – Universal Credit information
•    Social work
•    References from previous landlords
•    Glasgow City Council: Temporary furnished accommodation tenants
•    From Contractors – email, calls and in person
•    Terence Higgins Group in relation to repairs for tenants with medical condition.  
•    Feedback from contractors where there is a problem (aggressive etc.)
•    Occupational Health, Glasgow City council, for adaptation requirements
•    Citizens Advice Bureau – Complaints
•    Cllrs, MSPs , MPs – Queries and complaints
•    Doctors re potential health issues, e.g. damp

3.2.2    Factoring

We collect some or all the following information, as required, about you if you are ae a factoring customer of MH:

•    Owner Name
•    Owner Address
•    Phone Number
•    Email Number
•    If absent landlords; forwarding address
•    Information re payments, charges, responses, arrangement to pay
•    Purchase information
•    Borrowing at purchase date
•    Any further mortgages, security arrangements etc.
•    Name of lender
•    Percentage share of property repairs
•    Factoring bills and payments
•    Recording of telephone calls
•    Complaints and compliments
•    Correspondence

We receive the following information from third parties when you are a factored customer of MH:

•    When a factored property is sold/purchased, details are received from the respective Solicitors.
•    Title deed information from the Registers of Scotland.

The majority of information is collected at the initial stage and updated with any further information thereafter.  

3.2.3    Finance

We collect some or all the following information, as required:

•    Cash Income Sheet – Copy of receipts for those paying in cash.  Includes name, address, tenancy number, account paid.  
•    Insurance:  

o    For block policies - names and addresses  
o    Insurance claims – name, address, contact information, medical information where there have been injuries/illness, financial information (of losses)
We receive the following information from third parties when you are a tenant or factored customer of MH: 

•    Glasgow City Council Housing Benefit Schedule – Name, Address, National Insurance Number, Benefit amount  
•    Royal Bank of Scotland Bank Statements –Name, tenancy number and amount paid for those using direct debit
•    Court Citation – Offender’s name, court date, name of our employee called to court.
•    World Pay/AllPay – Tenant’s name, rent reference, sometime address, and amount paid.  
•    Sole traders – name, address, contact information and bank details
•    Invoices are received with job orders attached  - tenant’s name, address, job details and, where available, phone number
•    Right to Buy – How much is paid, name, address
•    Job sheets provided by our Maintenance section to the Contractor 

3.2.4    Other

The following information is also collected and processed:

•    Members of Registered Tenants Organisations: 
o    Name, address, phone numbers, email addresses
•    Members of Community Councils:
o    Name, address, phone numbers, email addresses
•    Individuals seeking tickets for events: number of adult and numbers of children’s tickets.  Will take address to send ticket and keep contact information on a Register of interested people
•    Classes: Contact information (name, address, phone number, email  address) for enquiries. List of who attended 
•    Residents Conference: Contact information (name, address, phone number, email address) for enquiries. List of who attended
•    Other Organisations for example, pop-up allotment group: Contact information of members of management committees  (name, address, phone number, email address)
•    Board members: Name, address, date of birth, how long at previous address, contact information 
•    Rent consultation on-line survey gathers name, address, email address,  This is not processed further
•    Board Members – name, address, phone numbers, email address, bank details and date of birth.  Notification of Members Interests which can include information on family members.  Board application form including job history and employer(s).
•    Bursary Applications : Names, address, phone number, email address and occasionally they provide sensitive health data although this is not specifically required
•    List of members – name, address, email, phone number
•    List of visitors to buildings
•    people captured by CCTV images

This information is collected only when required. 

We receive the following other information from third parties

•    Glasgow Life, Northern United Communities, Jobs & Business Glasgow- Name and address of participants if they attended classes
•    Apprenticeships and work placements as part of Community Benefits policy – Name, address, job details from employing contractor
•    Information from Workers Education Association -  Names, addresses, date of birth, date started, date completed  (English as a 2nd language)
•    MP/MSP/Cllr enquiries will include name and address of constituent and can include sensitive data (in broad terms) on illnesses/health
•    Queens Cross Housing Association: Names, address phone numbers  email addresses for  Hub Board members

4. Why we need this information about you and how it will be used 

4.1    Introduction

We need your information and will use your information:

•    to undertake and perform our obligations and duties to you in accordance with the terms of our contract with you
•    to enable us to supply you with the services and information which you have requested;
•    to enable us to respond to your repair request, housing application and complaints made;
•    to analyse the information we collect so that we can administer, support and improve and develop our business and the services we offer;
•    to contact you in order to send you details of any changes to our or supplies which may affect you;
•    for all other purposes consistent with the proper performance of our operations and business; and
•    to contact you for your views on our products and services.  

4.2    Legal Basis

There is a requirement for MH to identify a legal basis, as defined in the Regulation, for collecting and processing information:    
•    Tenancies, Factoring: Contract.  
•    Photographs/Marketing (excluding newsletters):  Consent 
•    Investment Programmes:  Where there is a requirement to carry out a repair - Legitimate interests
•    Financial Support/Benefits Advice: Consent
•    Credit/Repayment terms: Contract
•    Board/Members Information:  Legal Obligation or legitimate interest depending on the information
•    Registered Tenant Organisation: compliance with duties contained in the Housing (Scotland) Act 2001

4.3    Why we collect you information

4.3.1    Housing

Not all information collected will be applicable to every applicant or tenant and only that information required by MH will be collected. The information is used to:

•    Enter housing application onto system
•    Make a suitable offer 
•    To support and maintain your tenancy
•    To collect, assess and complete benefit claims or referrals to third parties
•    Health Issues – to provide adaptation or make arrangements where tenant is vulnerable or has access requirements
•    To carry out contracts
•    To provide a repairs service
•    Give the contractors they details they need to carry out the work
•    Alerts 

4.3.2    Factoring

The information is used to

•    To determine Income from repairs for factored owners against contract sum
•    Issue Recharge Bills according to individual liability
•    Issue quarterly invoices
•    Provide services
•    Manage the building
•    Respond to complaints

4.3.3    Finance

The information is used to:

•    Carry out money laundering checks (Board information only)
•    Manage Insurance claims
•    Record and manage rent payment
•    Record and manage other payments

4.3.4    Other

The information is used to:

•    Sign grant and other applications.  
•    Report to the Regulator and others
•    Bid for funding
•    To supply Newsletters and other information
•    To pay expenses
•    Determine Bursary Awards
•    Maintain membership list

5. Sharing of Your Information


5.1    Introduction

The information you provide to us will be treated by us as confidential and will be processed only by our employees within the UK/EEA.  We may disclose your information to other third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:

•    If we enter into a joint venture with or merged with another business entity, your information may be disclosed to our new business partners or owners;
•    If we instruct repair or maintenance works, your information may be disclosed to any contractor;
•    If we are investigating a complaint, information may be disclosed to Police Scotland, Local Authority departments, Scottish Fire & Rescue Service and others involved in any complaint, whether investigating the complaint or otherwise;
•    If we are updating tenancy details, your information may be disclosed to third parties (such as utility companies and Local Authority);
•    If we are investigating payments made or otherwise, your information may be disclosed to payment processors, Local Authority and the Department of Work & Pensions;
•    If we are conducting a survey of our products and/ or service, your information may be disclosed to third parties assisting in the compilation and analysis of the survey results
•    Registered Tenant Organisation details with The Scottish Government Tenant Priorities team for maintenance  publicly available (RTO) register requirement to maintain a public register complies with your duties contained in the Housing (Scotland) Act

Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.

5.2    Housing

Third parties to whom we may disclose information includes:

•    AllPay – tenant name, address bank account sort code and account 
•    Citrus Energy – tenants name, address, phone number, email address for energy advice/supplier 
•    EPIC 360 - – tenants name, address, phone number, email address to EPIC 360 for money advice 
•    Glasgow City Council for Council Tax and Housing Benefit – Name, address, rent or Council tax amount, income details  
•    Glasgow City Council – Council Garden Maintenance scheme – Name, address, phone number, email, age, disability info 
•    Fire &Rescue Service: Information on vulnerable people in multi-storey properties, e.g. name, address, phone number disability and help required to leave building
•    All Contractors: Name, Address, phone number, repair required, access issues, support requirements, alerts

5.3    Factoring

•    Solicitors on buying/selling property to ensure details accurate

5.4    Finance and Other

•    Auditors – Details of board members including name, address, date of appointment/resignation, date of birth
•    Regulator – Names and dates of appointment of Board members
•    Charity Commission – Names and dates of appointment of Board members
•    GWSF, Share, SFHA and EVH – Names of Board members re training courses and conferences
•    Members name and address lists to printing and mailing company
•    Tenants and Owners name and address lists to printing and mailing companies
•    Board and members names in press releases
•    Website – Board member names
•    Google Analytics –  IP address and device

6. Transfers outside the UK and Europe

Your information will only be stored within the UK and EEA

7. Security

We take steps to make sure that personal information is kept secure and safe. All data is held in accordance with Maryhill Housing’s Privacy Policy, a copy of this is available on request. Our systems are password protected and all electronic data is stored securely. All paper files are kept in locked cabinets.

8. How long we will keep your information

We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you. 

Our full retention schedule is available on our website.

9. Your Rights

You have the right at any time to:

•    ask for a copy of the information about you held by us in our records;
•    require us to correct any inaccuracies in your information; 
•    make a request to us to delete what personal data of your we hold; and
•    object to receiving any marketing communications from us. 

If you would like to exercise any of your rights above please contact us at enquiries@maryhill.org.uk

You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information.  The Information Commissioner’s contact details are noted below:

The Information Commissioner’s Office – Scotland
45 Melville Street, Edinburgh, EH3 7HL
Telephone: 0131 244 9001
Email: Scotland@ico.org.uk

The accuracy of your information is important to us - please help us keep our records updated by informing us of any changes to your email address and other contact details.