General statement
We at North & East Housing Association (NEHA) take personal privacy very seriously and take steps to ensure that your data is used and stored in a secure manner. We want you to know what we do with personal information that you and others provide to us. This statement explains how we use your data and what rights you have in relation to your personal information.
This Privacy Statement should be read in conjunction with terms and conditions, any Contract, or Tenancy Agreement.
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about
- Kept securely.
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).
There are "special categories" of more sensitive personal data which require a higher level of protection. Special categories of data include health data.
We will collect, store, and use categories of personal information about you. We may also collect, store and use "special categories" of more sensitive personal information:
Situations in which we will use your personal information
The situations in which we process your personal information and the purpose, legal basis and retention period on which we do so are listed in the table below
|
Purpose |
Retention |
Legal Basis |
|
|
To access the suitability of a Prospective tenant |
name of applicant, address, |
3 years |
Legal Obligation |
|
To allocate a property to a tenant - |
Names, addresses, PPS , dob, confirmation of garda vetting (contact details: email, phone number) |
7 years from end of tenancy |
Consent |
|
Annual Rent Review |
Name, Address, Income Details, PPS No. DOB. Signature, contact number, Gender, household make up (name, relationship, dob, PPS no. employment status, Educational Status, Social Welfare payments, type of SW payment, weekly payment amount). Tenant's employment details, type, weekly/monthly amount, pay slips or SW slips, revenue employment details summary. If self-employed form 11 from revenue & statement of net liabilities. Additional income details, type of income (i.e. child maintenance). Any property bonds or shares held, letter from pension provider. Bank statements for last 3 months. Letters from college if child or tenant is attending. Print out of revenue account to show active or ceased employment. Copy of any court orders for child maintenance. |
7 years from end of tenancy |
Contract |
|
Additional Occupant Request |
Name, Address of both tenant and proposed additional occupier, PPS and tel no of proposed occupier, Local authority Housing Status |
3 years from end of tenancy |
Contract |
|
Tenant events (e.g. roadshow/seasonal events) |
Tenant name and child name. Possible guests such as parents. Signature and child's name and date of consent. |
TBC |
Consent |
|
Mortgage to rent |
Name, address, dob, tel no. PPSN. Income details, household members (their dob and pps), any details of medical conditions, details of GP and any support services medically. Declaration of any Anti Social Behavior or criminal behavior, |
Legal Obligation |
|
|
To access your application if you apply for a role in North and east Housing |
Contact details, Professional Qualifications, Work History, CV , Details of the referee |
Employee contract |
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
-
- With your explicit consent.
- Where we need to carry out our legal obligations or exercise rights in relation to your employment with us.
- Where it is needed in the public interest.
We do not need your consent if we use special categories of your personal information to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data, including your biometric information. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
Auto-mated decision making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes]
We may have to share your data with third parties, including third-party service providers and other entities .
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the EEA. If we do, you can expect a similar degree of protection in respect of your personal information.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers:
- Benefits provision including payroll
- IT services.
How secure is my information with third-party service providers?
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may need to share your personal information with a regulator or to otherwise comply with the law.
Some of the third parties that we may disclose your personal data to are based outside the EEA, so their processing of your personal data will involve a transfer of your personal data out with the EEA. Whenever we transfer your personal data out with the EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the EU.
- Where we use certain service providers, we may use specific contracts or EU model clauses.
- Where we use providers based in the US, we may transfer data to them if there are secure standard contract clauses in place under GDPR which requires them to provide similar protection to personal data shared between the EU and the US.
:
We have put in place measures to protect the security of your information.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. Please see the Data Breach Policy for more details
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our Data Retention Policy and in section 4 above. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact enter DPO@NEHA.ie .
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact DPO@NEHA.ie. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you have any questions about this privacy notice or how we handle your personal information, please contact DPO@NEHA.ie. You have the right to make a complaint at any time to the:
Irish Data Protection Commissioner
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.