Data Protection

Who we are

We are Christian Action (Enfield) Housing Association, a Data Controller & processor whose registered address is Benedict House, 61 Island Centre Way, Enfield EN3 6GS. Tel no: 01992 765900.

 This is our main privacy notice; we have separate privacy notices for our young people’s services, employees, and people applying to work for us. 

Why do we process personal data?

We collect and process personal information in order to deliver services to our customers and we are committed to being transparent about how we collect and use that information and to make sure we meet our data protection obligations.

When we collect personal information about you we will always make sure we:

• process it fairly and transparently and have a valid reason for doing so
• only use your information for the reason it was collected
• only collect the amount of personal information that we need to provide our services
• do our best to make sure your information is  accurate and kept up to date
• only keep your personal data for as long as we need it
• keep your information secure and protect it against unauthorised access or accidental loss

What information do we collect about you?

We collect and process a range of information and this will vary according to the type of service we are providing you with. Most of the information we hold will be collected from you directly but we may also receive information about you from third parties such as a local authority, GP or health professional, or another community partner.

Information we may collect:

• your name, address and contact details, including email address and telephone number
• your date of birth and gender
• the names and date of birth of members of your household
• next of kin contact details
• relationship status
• photographic ID
• national insurance number
• income and benefits details
• employment status
• bank details and records of payments that you make to us
• housing history
• details of any disability or health condition that we need to be aware of to provide you with an appropriate service 
• communication or accessibility requirements
• records of all our contact with you, and any contact from third parties representing you or about you, this may include call recordings.
• your image on our CCTV systems if you visit a property, office or communal facility which is covered by this facility

Some of the personal information, we collect is sensitive personal information (also known as special category data) which may include:

• Race or ethnic origin
• Religious or philosophical beliefs
• Sexual orientation
• Health information

We use this type of data to ensure services are delivered appropriately and to monitor equality, diversity and inclusion. We will make sure we have appropriate security and confidentiality measures when processing your sensitive personal information.

Why do we need the information?

There are a number of different reasons why we need to collect and process your information.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing some of the information we require is part of a contractual agreement, and without it we will be unable to process applications for housing or other services. For example documents verifying your identity to make sure that an application is not fraudulent.

Much of the information we collect and process is for our legitimate business interests, which means it is needed for us to deliver our services effectively. This could include things like your housing history, details of your income and any communications needs that you have.

Where we rely on legitimate interests as a reason for processing data, we have considered whether or not those interests are overridden by your rights and freedoms as individuals and have concluded that they are not.         

Who has access to your data?

Usually only Christian Action staff will be able to see and process your personal information however sometimes we need to share personal information we hold about you with other organisations that we work with or who provide services on our behalf.  We also sometimes share information when you ask us to, for instance in support of a transfer to another housing association.  When sharing information we will comply with all aspects of data protection law. 

Where it is in our ‘legitimate business interests’ to share your information, we may do so without seeking your consent first.  This may be with:

The Ministry of Housing, Communities and Local Government for research and statistical purposes (CORE reporting) – see separate information on our website          

• Our contractors to carry out repairs, maintenance or improvement works.
• Debt and money management advisors.
• Local authority teams such as social services, environmental health and benefit agencies.
• Utility companies (and their representatives) and Council Tax Departments to ensure billing details are correct.
• Third parties providing services on our behalf. For example a mailing company distributing our letters, our tenant portal provider or a debt collection agency pursuing former tenant arrears.
• Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative.
• Police and other relevant authorities (e.g. Department of Work & Pensions, Probation Service, HM Revenue and Customs) in relation to the prevention and detection of crime, the apprehension of offenders or the collection of tax or duty.
• Other statutory organisations e.g. social services and health authorities as necessary for exercising statutory functions.
• A third party out of hours contact centre if you live in one of our retirement housing schemes. 

We may also share information when required by law for example where ordered by the Court. We may also share information when it is in an individual’s vital interests, such as needing protecting from immediate harm.

Where the information is special category data, for example about your health, we may need consent from you prior to sharing this information unless we are required or permitted to do so by law. We will be clear about what you are consenting to, will keep a record of your consent and you will have the right to withdraw your consent at any time.

Christian Action Housing will never sell your personal data to 3^rd party organisations for marketing purposes.

How do we protect your data?

We take the security of your data seriously. We have internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees or other authorised individuals. Your information is securely stored.

Where we engage third parties to process personal data on our behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of your data.

To help us to ensure confidentiality of your personal information we may ask you security questions to confirm your identity when you call us. We will not discuss your personal information with anyone other than you unless we have a valid reason to do so or you have given us prior written authorisation.

How long will you keep my data?

Christian Action only holds records during the period of our relationship and for a set period afterwards to allow us to meet our legal obligations including resolving any follow up issues there may be between us.

We have a document retention schedule which sets out how long we keep different types of information. This is based on National Housing Federation guidance, legal requirements and best practice.

Please contact us if you would like any more information. 

What if you do not provide personal data?

When we ask you for information, we will make it clear why we need it and also the consequences of not providing it. We will also make it clear when you do not have to provide us with information. 

Automated decision-making

There may be some circumstances where decisions about whether to offer you a service or not is automated. Examples include where we use credit reference agencies during affordability checks for market rental and home ownership. Please contact us if you have any further questions.

Keeping you informed about our services

We will use your contact details to send you information and communicate with you about your tenancy or other services that we offer such as our newsletter.

Our website

When you visit our website, or register to the tenant portal we collect standard internet log information for statistical and value for money purposes and we ensure we respect your privacy in the following ways:

• We use cookies to collect information in an anonymous way, including the number of visitors to the site, and the pages they visited.
• We do not make any attempt to identify visitors to our website. We do not associate information gathered from our site 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 website may 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.

Your data protection rights

Under data protection law, you have rights including:

• Your right of access - You have the right to ask us for copies of your personal information.
• Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we will comply with the data protection requirements. We could refuse to respond to a request if it is manifestly unfounded or excessive, or, we could charge a reasonable fee for dealing with the request. Either way, we will demonstrate why it is manifestly unfounded or excessive. Please contact us at dataprotection@christianaction.org.uk if you wish to make a request.

How to contact us or make a complaint

If you have any concerns about our use of your personal information, or have any questions, require further information, or would like to make a complaint you may contact us at:

The Data Protection Officer

Christian Action Housing

Benedict House

61 Island Centre Way

Enfield

EN3 6GS 

E-mail: dataprotection@christianaction.org.uk

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:           

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

  Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Keeping this privacy notice updated

We regularly review and update our privacy notices. This privacy notice was last updated on the 1^st August 2024.  

Job Applicant Privacy Notice

Christian Action Housing Association is a data controller and we collect and process personal data relating to job applicants as part of any recruitment process. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.

What information do we collect?

We collect and process a range of information about you. This includes

• your name, address and contact details, including email address and telephone number;
• details of your qualifications, skills, experience and employment history;
• information about your current level of remuneration, including benefit entitlements;
• whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
• information about your entitlement to work in the UK; and
• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief. This information is anonymised before processing.
• if you attend an interview, your image on our CCTV systems in/out of the office,  properties or communal areas which is covered at that facility
• We may use video conferencing for meetings and interviews (such as MS Teams). After you join a meeting, we may start recording and transcription. A notification appears so everyone in the meeting knows that the recording has started. You must notify a member of staff if you do not wish for the interview to be recorded.

We collect this information in a variety of ways. For example, data might be contained in application forms, CVs, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.

We will also collect personal data about you from third parties, such as references supplied by former employers and information from criminal records checks. We will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

Why do we process personal data?

We need to process data to take steps at your request prior to entering into a contract with you. We also need to process your data to enter into a contract with you.

In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant's eligibility to work in the UK before employment starts.

We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.

Where we rely on legitimate interests as a reason for processing data, we have considered whether or not those interests are overridden by the rights and freedoms of employees or workers and have concluded that they are not.

We process health information if we need to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out our obligations and exercise specific rights in relation to employment.

Where we process other special categories of data, such as information about ethnic origin, sexual orientation, health, religion or belief, age, gender or marital status, this is done for the purposes of equal opportunities monitoring with the explicit consent of job applicants, which can be withdrawn at any time.

For some roles, we are obliged to seek information about criminal convictions and offences. Where we seek this information, we do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment.

We will not use your data for any purpose other than the recruitment exercise for which you have applied.

We only use CCTV recordings to increase the personal safety of staff and visitors and reduce the fear of physical abuse, intimidation and crime.  We will not use CCTV recordings as part of the recruitment and selection process.

Who has access to your data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the People & Culture team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

We use a third party to collect and process job applications on our behalf however we will not share your data with any other third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.  Please note that all information obtained during pre-employment checks (including references) are treated as confidential and will not be shared with anyone outside of the People & Culture Team and the relevant manager if required.

We will not transfer your data to countries outside the European Economic Area (EEA) and where data may be transferred outside of the EEA by third parties we will seek assurances that this is done in line with data protection legislation.

How do we protect your data?

We take the security of your data seriously. We have internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties.

Where we engage third parties to process personal data on our behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

How long do we the keep your data?

If you are unsuccessful after being interviewed the organisation will hold your data on file for 6 months after the end of the relevant recruitment process.

CCTV recordings are not held longer than 30 days.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. Details about the periods for which your data will be held are included in our employee privacy notice.

Your rights

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data on request;
• require us to change incorrect or incomplete data;
• require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
• object to the processing of your data where we are relying on legitimate interests as the legal ground for processing; and
• ask us to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override our legitimate grounds for processing data.

If you would like to exercise any of these rights, please contact dataprotection@christianaction.org.uk

If you believe that we have not complied with your data protection rights, you have the right to complain to the Information Commissioner.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.

Automated decision-making

We do not make any decisions based solely on automated decision-making during our recruitment processes.

Who can I contact if I have any questions?

For further information you can contact Christian Action’s Data Protection Officer as follows:

The Data Protection Officer

Christian Action Housing

Benedict House

61 Island Centre Way

Enfield

EN3 6GS 

E-mail: dataprotection@christianaction.org.uk 

You can find more information about your rights around how we handle your personal data from the Information Commissioners Office on 0303 123 1113 or via their website www.ico.org.uk

Keeping this privacy notice updated

We regularly review and updated our privacy notices. This privacy notice was last updated on 29^th May 2024.