Privacy notice - care

Privacy notice for care customers - collecting and retaining personal information.

Barony Housing Association is a non-profit making charity. We are a Registered Social Landlord, registered with and regulated by the Scottish Housing Regulator. We also provide a care and support service. This privacy notice relates to the care and support service we provide.

We are members of Wheatley Group - Scotland's leading housing, care and property-management group. Barony Housing Association will be the 'data controller' of the personal information you provide to us about you, as a person receiving care and support services.

We need to hold personal information about you in order to deliver care and support services to you in accordance with your contact with us and our statutory responsibilities.

Our Data Protection Officer is Ranald Brown who can be contacted on #wheatleydataprotectionofficer@wheatley-group.com.

What we need
 

The information we require from you includes:

  • your full name
  • your date of birth
  • your contact details (phone, email or correspondence address)
  • details of anyone authorised to act on your behalf if applicable
  • other personal information that will vary on a case by case basis to assist us in providing services to you
  • other details - next of kin details
  • equality, disabilities or vulnerabilities. We use this information to tailor our service to better meet your particular circumstances and needs. We may use this information for safeguarding of staff
  • financial information. We may use this to act as your appointee or to help you make a decision around affordability, resolve any debts/arrears and provide welfare benefits, fuel and debt advice as a service to help customers budget and pay bills
  • health information when we require this to provide support in this area
  • photo ID, bank statements or income details for verification purposes
  • historic complaints information
  • information required to provide your care package
  • referral information from a third party, for example a local authority.

The information we may collect from you includes:

  • disabilities or vulnerabilities. We use this information to tailor our service to better meet your particular circumstances and needs. We may use this information for safeguarding of staff
  • your health number and any unique identifiers provided by a local authority, and
  • your photo. We use your photo to identify you to care workers, letting us provide your care and support package, and keeping you safe.

We collect your personal information from you via a variety of sources, including when you complete one of our forms, when you call, write, email or meet with us or respond to a survey. We may collect information when you use our social media sites and websites.

Our landline phone calls to our Customer Service Centre and the Group Debt Recovery Team are recorded for training and monitoring purposes and our recordings are held for a period of six months.

We operate a CCTV system at our office premises and at various locations within the vicinity of our properties for the detection and prevention of crime, to fulfil our legal obligations to keep our staff safe and in pursuit of our legitimate basis to keep our properties safe and secure. Our CCTV cameras operate continuously and recordings are held for one month.

We may also take photographs and video footage at events we organise or take part in, at our offices and in our communities to use for general marketing and publicity. Photographs will only be used for those purposes with your consent.

We may transfer information about you to other Wheatley Group companies for purposes connected with the management of your contract with us and with Barony Care’s business.

We may receive information about you from third parties including:

  • your local council or benefits office relating to your care plan
  • police, welfare or support organisations dealing with you
  • Councillors, MPs or other representatives acting on your behalf/instruction.

Children’s information
 

We do not usually process children’s information as part of your care package. However, we do record children’s basic information if they are living with you including their name, age and family structure. This is to allow us to support you as a parent or legal guardian. We may, for example, use this information to signpost you to agencies, benefits and resources which may help your family.

We may at a later stage receive children’s information if we are involved in a welfare case as part of a multi-agency working solution.

Why we need your personal information – legitimate purposes
 

We also process your personal information in pursuit of our legitimate interests to:

  • deliver our investment programme to provide appropriate facilities
  • pursue any debts owed to us
  • offer support services to you and those living with you
  • provide education, employment and training advice and opportunities
  • target customers impacted by welfare reform
  • issue communications to you regarding our services, including letters, newsletters, emails and texts
  • carry out customer segmentation research to allow us to help us better understand our customers’ characteristics and prioritise, tailor and target services to you
  • undertake research and statistical analysis to help improve our business processes and the services offered to our customers, as well as to evaluate our performance against other benchmarks. Where possible, statistical information is anonymised or pseudonymised, and
  • we may also conduct surveys regularly and periodically relating to our services in order to gauge satisfaction and make improvements based on feedback.

Where we process your personal information in pursuit of our legitimate interests, you have the right to object to us using your personal information for the above purposes.

If you wish to object to any of the above processing, please contact us on InformationRequests@wheatley-group.com. If we agree and comply with your objection, this may affect our ability to undertake the tasks above for your benefit.

Why we need your personal information – equality monitoring requirements
 

We are required to use your personal information relating to your health, racial or ethnic origin for equality monitoring purposes as required by government departments and agencies, Care Inspectorate and auditors and with other organisations and agencies where we are legally allowed to do so.

We will process such personal information to identify and keep under review the existence or absence of equality of opportunity or treatment between groups of people within the same categories to promote or maintain equality within our Group.

Additional services
 

We offer a number of additional voluntary services to the people we work for including organising community events, fire safety visits, providing debt advice and adapting the property you live in.

For these voluntary services, where your personal information is needed, we will always notify you about the service being offered, explain the service and obtain your consent or use another lawful basis to proceed.

For the additional voluntary services, much of the information contained in our Privacy Notice is still relevant, such as details about the Data Controller and the rights you have under the legislation, including the right to withdraw your consent and the right to complain.

Other uses of your personal information
 

We may ask you if we can process your personal information for additional purposes. For example we may share your information with a language translation service if it is necessary to translate any information into or from a foreign language for you.

Where we do so, we will provide you with an additional privacy notice with information on how we will use your information for these additional purposes.

Who we share your personal information with
 

We share limited personal data with our contractors who are carrying out services on our behalf including:

  • to provide a language translation service if it is necessary to translate any information into, or from, a foreign language for you
  • to carry out research, surveys and segmentation on our behalf to help us to improve the services we offer to you
  • if we are conducting a survey of our products, services, or customer base your information may be disclosed to third parties assisting in the compilation and analysis of the survey or customer segmentation results, and
  • with our professional and legal advisors for the purposes of taking advice.

Our contractors are required to comply with the law and our own Data Processing Agreement or Data Processing Clauses within our contracts to ensure data is managed appropriately and for specified purposes.

In the event we enter into a joint venture or merge with another business entity your information may be disclosed to our new business partners or owners.

We may be required to share personal information with statutory or regulatory authorities and organisations to comply with statutory obligations. Such organisations include the Care Inspectorate, Health and Social Care Partnerships, homelessness services, health services or care and support organisations that we work with, local authorities, government departments and agencies, with our regulator and auditors, with utility companies or with other organisations and agencies. We will only share information on the basis of your consent or in accordance with UK data protection legislation.

In the event we do share personal information with external third parties, we will only share such personal information strictly required for the specific purposes and take reasonable steps to ensure recipients shall only process the disclosed personal information in accordance with those purposes.

How we will communicate with you
 

As a customer we need to communicate with you. This will usually be in writing or by telephone, but is more commonly becoming electronic and paperless. We are moving many of our services online as this is usually more convenient for you and more efficient for us.

The people we work for receive our newsletters with information about what is going on within the organisation. We are required by our regulator to keep the people we work for informed and to offer opportunities for involvement, but you may opt-out of receiving this by contacting info@wheatley-group.com.

We will only discuss or communicate your details in relation to our services with those authorised (temporarily or permanently) by you.

How we protect your personal information
 

Your personal information is stored on our paper and IT filing systems which may be copied for testing, backup, archiving and disaster recovery purposes. All data is held within the UK.

If any of your personal information is transferred out with the European Union or the European Economic Area by any of our contractors we will ensure that there are adequate safeguards in place to protect your personal information in accordance with the General Data Protection Regulations and applicable UK Data Protection Legislation.

How long we keep your personal information
 

We will only keep your personal information for as long as necessary to provide you with our services and to safeguard Barony in the event of any claims, complaints, litigation, enquiries or investigations during, or following, the termination of your care and support service. Unless you ask us not to, we will review and possibly delete your personal information where your care package has terminated for seven years if you no longer require our services or three years if you pass away.

We have a data retention policy that sets out the periods for retaining and reviewing all information that we hold. This sets out different retention periods for all information we hold about your care. You can request a copy by contacting us at InformationRequests@wheatley-group.com

We review our data retention periods regularly and will only hold your personal information 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 contracts with you or the local authority commissioning services on your behalf.

Your rights
 

You can exercise any of the following rights by writing to us at InformationRequests@wheatley-group.com

Your rights in relation to your personal information are:

  • you have a right to request access to the personal information we hold about you by making a Subject Access Request
  • if you believe any of your personal information is inaccurate or incomplete, you have a right to request we correct or complete your personal information
  • you have a right to request we restrict the processing of your personal information for specific purposes, and
  • if you wish us to delete your personal information, you may request that we do so.

Any requests received by Wheatley Group will be considered under applicable UK Data Protection Legislation. If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner's Office at www.ico.org.uk

The accuracy of our information is important to us - please help us keep our records updated by informing us of any changes to your personal information.

Changes to our Privacy Notice
 

Our Privacy Notice is regularly kept up to date and this version was updated on 4 September 2018. The latest full version is always available from our website.