Methodist Action (North West) Limited, sometimes known as A Place to Live, needs to collect and process personal data to deliver its services, including:
tenancy management and property maintenance services
providing and managing residential services
developing new services to support the homeless or those at risk of homelessness
helping to support individuals to live, stay and grow
Methodist Action (North West) Limited (MANW) takes your privacy seriously and we are committed to protecting your personal information (personal data). This privacy notice lets you know how we look after your personal data which either you provide to us or we obtain and hold about you and it tells you about your privacy rights and how the law protects you.
MANW is responsible for the collecting, processing, storing and safekeeping of your personal data as part of our business activities. We manage your information in accordance with current Data Protection laws and regulations. This Privacy Notice supersedes any earlier privacy notices that we have published about your personal information. If we make major changes in the future to how we use your information we will update this notice and inform you of the changes. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
This privacy notice is effective from 20th June 2018
IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW YOUR PERSONAL DATA IS COLLECTED
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Methodist Action (North West) Limited collects and processes your personal data which either you provide to us or we obtain and hold about you including any data you may provide when you become a tenant, landlord, staff member or subscribe to our mailing lists.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or dealing with personal data about you (e.g. website privacy notices and employment privacy notices) so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
The Trustees of Methodist Action are the Data Controller and are responsible for data protection issues arising in all aspects of the work of the Charity. This includes information relating to Tenants, Landlords, and Staff Members.
Our full details are:
The controller for routine, day to day data protection matters for Methodist Action (North West) is:
Methodist Action (North West) Limited
Howick Park Avenue
The Trustees have identified a lead contact for enquiries:
Name contact: Lesley Finch
Tel: 01772 751000
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 20th June 2018.
We have the right to update and amend the provisions of this notice to ensure continual compliance with data protection legislation. We will provide you with copies of the new notice wherever it is practically possible to do so but please check the online or locally displayed hard copy notice regularly to see if any updates have been made.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with the Methodist Action (North West) Limited.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about a living 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 our tenants (and their families), landlords, staff members, those who are interested in and supportive of the work of the charity, individuals who provide services to us and individuals who contact us.
We have grouped the different kinds of personal data together as follows:
Administrative Data includes details about you included in; meeting records, invoices; supplier and contractor details; and back-up files.
Image Data includes photographs taken of you where it is possible to identify you and images of you caught by any CCTV or similar devices at the Fox Street Community.
Contact Data includes home address, email address and telephone numbers e.g. information used to contact you.
Employment Data includes employment history, training records, pension information, details about next of kin and other details relating to your employment by the Charity.
Financial Data includes bank account and payment card details.
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Marketing and Communications Data includes your preferences in receiving information from us about fundraising events and your communication preferences.
Tenancy Data, includes information about your eligibility for Housing Benefit or other financial support.
Special Categories of Data includes your race or ethnicity, your religious beliefs, sexual orientation, information about your health, also information about criminal convictions and offences in keeping with the Charities Safeguarding Policy.
Tax Data includes national insurance numbers and other information that may be required by HMRC relating to gift aid donations and other tax related payments and receipts.
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 any websites operated by the Charity.
Transaction Data includes details about payments to and from you and other details of your tenancy or lease agreements that you enter into with us relating to our properties
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with accommodation under a tenancy agreement or process gift aid payments). We will notify you if this is the case at the time.
3. HOW YOUR PERSONAL DATA IS COLLECTED?
We use different methods to collect data from and about you including through:
Direct exchanges. You may choose to provide personal information to us direct e.g. by speaking to us, by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
join and take part in fundraising or promotional events;
apply for paid or voluntary roles within the Charity ; or
enter into property contracts with us including leases, or tenancy agreements;
Automated technologies or interactions. As you interact with any websites run by the Charity, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. Please see website privacy notices and cookie policies available from such Local Websites for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Your family members;
Partner agencies, e.g. Local Councils
Identity and Contact Data from publicly available sources such as Companies House, the Charity Commission and the Electoral Register based inside the EU.
4. HOW WE USE YOUR PERSONAL DATA
Methodist Action (North West) Limited takes its obligations under data protection law (including the General Data Protection Regulation (GDPR)) seriously. We keep personal data as up to date as possible and take active steps to rectify any personal data we find to be incorrect. We store and destroy personal data securely and do not collect or retain personal data which is in excess of our processing activities. We take steps to protect all personal data (including Special Category Data) from loss, misuse, unauthorised access and disclosure by ensuring that appropriate measures are in place to protect personal data.
We ensure that personal data is processed in accordance with the principles of the GDPR and is processed:
Lawfully, fairly and in a transparent manner;
For specified, explicit and legitimate purposes and not processed in a manner which is incompatible with those purposes;
Accurately, relevantly and limited to what is necessary in relation to the purposes for which it is processed;
Kept accurate and where necessary kept up to date, with all reasonable steps being taken to ensure that all inaccurate data is erased or rectified without delay;
Is not kept longer than is necessary for the purposes for which the personal data is processed; and
In a manner that ensures appropriate security of the Personal Data including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage by using appropriate technical and organisational measures.
HOW WE USE YOUR DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Legitimate interests means the interests of the Charity, conducting and managing our activities to enable us to fulfil our charitable purposes. 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.
Where we need to perform the contract we are about to enter into or have entered into with you.
Performance of Contract means processing your personal 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 including employment contracts and property contracts, such as leases and tenancy agreements.
Where we need to comply with a legal or regulatory obligation.
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.
In rare cases we may need to use your personal data in the following circumstances:
Where we need to protect your vital interests e.g. in an emergency life or death situation where the emergency services are called to treat you when you are with us.
Vital interests means where it is necessary to use your personal data to protect your "vital interests" or those of another person (such as a child) in a life-or-death situation.
Where we need to perform a task carried out in the public interest e.g. in certain safeguarding situations.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sharing your personal data with third, sending marketing and fundraising communications to you via email or to legitimise dealing with Special Category Data. You have the right to withdraw consent at any time by contacting us although this will not prevent processing where the law allows us to process for a different reason in addition to consent.
SPECIAL CATEGORY DATA
Where data processing relates to Special Categories of Data the following processing conditions apply in addition to the legal basis identified above:
Explicit Consent has been given by the data subject;
Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement;
Processing is carried out by a not for profit body provided there is no disclosure to a third party without consent;
Processing relates to personal data manifestly made public by the data subject;
Processing is necessary for the establishment, exercise, defence of legal claims or where the courts are acting in their judicial capacity; or
Processing is necessary for archiving purposes in the public interest, scientific and historical research purposes or statistical purposes.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out in the section above entitled “How we use your data”, a description of the main ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. If you need details about the specific legal ground we are relying on to process your personal data please contact the lead contact using the details contained in this notice.
NOTIFYING YOU ABOUT EVENTS AND FUNDRAISING
We like to notify our members, trustees, friends and those in regular contact with us about upcoming events and fundraising opportunities so that you can play as much of a role in the life of the Charity as you choose from time to time. Most of the time we will let you know about such opportunities on the basis that we have a legitimate interest in doing so.
If we decide to contact you by email or telephone where you are registered with the telephone preference service we will provide you with choices as required to do so under data protection legislation and the Privacy and Electronic Communications Regulations 2003 (PECR).
As a Charity we will not share your personal data with any third parties for marketing purposes but if we thought you might be interested in hearing from another community group or charity about certain events or fundraising we will get your express opt-in consent to us sharing your information with them before we do so.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us.
CHANGE OF PURPOSE
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the Local Contact.
If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
SHARING PERSONAL DATA
We treat all personal data as strictly confidential, except where consent has been provided for it to appear in publications available to general members of the public.
Personal data will not be shared with third parties, other than those listed below unless we are legally obliged to do so or:
with your explicit consent;
it is necessary for law enforcement purposes; or
it is necessary to protect our rights, property or safety of our members, ministers, volunteers or staff.
We may have to share your personal data with the parties set out below.
Statutory agencies, for example local councils, Department for Work & Pensions, where we need to provide information to support your tenancy or for other legal reasons
Professional advisers including lawyers, surveyors, bankers, auditors and insurers based in the UK who provide such services to the Charities.
Other suppliers of services to the Charity for example building contractors responsible for repairs to our properties, where it is essential to the performance of our contracts..
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
We will ask all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third-parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. TRANSFER of Personal Data outside of the European Economic Area (‘EEA’)
We may at times transfer and process personal data outside of the EEA.
Storing, publishing or transmitting personal data via the internet, (this includes by email), is not completely secure and therefore whilst we take all reasonable and necessary precautions to protect personal data from unauthorised access, you acknowledge that there is a risk that your personal data may be transferred and accessed outside of the EEA.
7. DATA SECURITY
We implement reasonable and appropriate security measures against unlawful or unauthorised Processing of personal data and against the accidental loss of, or damage to, personal data in accordance with our internal data security policy. In addition, we limit access to your personal data to those members, volunteers, ministers and employees who have a 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 reasonable and appropriate 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.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data 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.
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.
Full details of retention periods for data processed by us are available on request
In some circumstances you can ask us to delete your data: see Section 9 and details about Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Unless personal data is subject to an exemption under GDPR, such as it is subject to the prevention, investigation, detection or prosecution of a criminal offence, you have the following rights with regards to your personal data:
Where consent is used as the legal basis for processing personal data, you have the right to withdraw consent to the data processing at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent or processing carried out using an alternative legal basis such as performance of a contract or legal obligation;
The right to request a copy of the personal data which we hold about you (commonly known as a “data 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. If you would like to exercise this right then please send us a Subject Access Request and send it to us as described in section 1 of this privacy notice.
The right to request that we correct any Personal Data which is found to be inaccurate. Note that we may need to verify the accuracy of the new data you provide to us;
The right to request that we erase any Personal Data where there is no good reason for us continuing to process it. 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.
Where consent or the performance of a contract is used as the legal basis for processing Personal Data, you have the right to 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 and this right is unlikely to apply to personal data held by us.
The right to request for a restriction on data processing. 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.;
Where legitimate interest is used as the legal basis for processing Personal Data, you have the right to object to the processing of personal data where 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. Note that in some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
The right to lodge a complaint with the Information Commissioners Office (ICO).
Contacting the ICO
Further information, guidance and advice is available from the ICO at:
Information Commissioner’s Office
Tel: 0303 123 1113
If you wish to exercise any of the rights set out above, please contact us using the details set out in section 1 above.
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 LIMIT 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.
“controller” is the controller described in Section 1 of this privacy notice.
“data subject” is a living, identified or identifiable individual about whom personal data is held. e.g. our tenants, landlords, employees, and those who are interested in and supportive of our work.
“explicit consent” is a very clear and specific statement of consent.
GDPR means the General Data Protection Regulation ((EU) 2016/679). Personal data is subject to the safeguards specified in the GDPR.
“lawful bases” are the five lawful grounds on which we can lawfully process personal data set out under Article 6 of GDPR. The lawful basis or bases on which we rely are set out under Section 4 of this privacy notice.
“Methodist Action (North West) Limited" refers to the charitable company of that name and to business conducted under the A Place to Live trading name.
“personal data” is any information identifying a living individual or information relating to an individual that can be identified from that information/data (alone or in combination with other information in your hands or that can reasonably be accessed). Personal Data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour. Personal information includes an individual’s name, address, date of birth, telephone number, email address, a photograph or disability, health or ethnicity data.
“Processing” “processed” or “process” means any activity that involves the use of personal data. It includes obtaining, recording or holding the data, or carrying out any activity or set of activities on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring personal data to third parties. E.g. sharing member information by email and shredding when information is no longer required.