Who are we?

At Bolton at Home (BH), we are committed to maintaining the trust of our customers, tenants, workers and job applicants. In particular, we want you to be confident that we are handling your personal data in accordance with the Data Protection Act 2018 (DPA) and General Data Protection Regulation (GDPR).

We are registered as the data controller with the Information Commissioner's Office under ZA304342 as we will decide how and why we process your personal data.

If you would like to know when and why we collect your personal data, how we use it, the limited conditions under which we may disclose it to others and how long we may keep it for, please read on.

What personal data do we collect and why?

We may collect your personal data and / or special category personal data from you. Personal data are any information that can directly or indirectly identify you. Special category personal data are any information about your biometrics, ethnic or racial origin, genetics, health, political opinions, religion, sex life, sexual orientation and trade union membership.

See below for details.

Data subjects

Categories of personal data

Purposes for processing

Basis / condition for processing

Customers and tenants.

Personal data and / or Special category data.

Tenancy applications and support (e.g. property allocation and bids, support to sustain tenancy).

Legal bases for processing:

  • with your consent; 

  • because it is necessary for our contract with you for your tenancy;

  • because it is necessary for a legal obligation under your tenancy;  or

  • because it is necessary for our legitimate interests which are linked to your tenancy.

Condition for processing:

  • with your explicit consent relating to your tenancy application and  tenancy.

Customers and tenants.

Personal data and / or Special category data.

Property repair and maintenance (e.g. disability adaptations, general repairs).

Legal bases for processing:

  • because it is necessary for our contract with you for your tenancy;

  • because it is necessary for a legal obligation under your tenancy; or

  • because it is necessary for our legitimate interests which are linked to your tenancy.

Condition for processing:

  • with your explicit consent relating to your tenancy and property requirements.

Customers and tenants.

Personal data and / or Special category data.

Support into work (e.g. CV writing support, training, work placements).

Legal bases for processing:

  • with your consent ; or

  • because it is necessary for our legitimate interests which are linked to your tenancy.

Condition for processing:

  • with your explicit consent relating to the support received to help you back to work.

Customers and tenants.

Personal data and / or Special category data.

Welfare support (e.g. budgeting, debt advice Urban Care and Neighbourhood Centres [UCANs]).

Legal bases for processing:

  • with your consent; or 

  • because it is necessary for our legitimate interests which are linked to your tenancy

Condition for processing:

  • with your explicit consent relating to the welfare support that you accessed .

Customers and tenants.

Personal data and / or Special category data.

Financial processes

(e.g. grant applications, rent payments).

Legal bases for processing:

  • with your consent; 

  • because it is necessary for a legal obligation under your tenancy; or

  • because it is necessary for our legitimate interests which are linked to your tenancy.

Condition for processing:

  • with your explicit consent relating to your tenancy or service accessed.

Customers and tenants.

Personal data and / or Special category data.

General service enquiries.

Legal basis for processing:

  • with your consent. 

Condition for processing:

  • with your explicit consent relating to your service enquiry. 

Customers and tenants.

Personal data and / or Special category data.

Legal requirements        (e.g. criminal offences, court proceedings, insurance claims).

Legal bases for processing:

  • because it is necessary for a legal obligation under the Criminal Justice Act 2015; or

  • because it is necessary for the establishment, exercise or defence of legal claims or where courts are acting in their judicial capacity.

Condition for processing:

  • with your explicit consent relating to your legal requirements. 

Customers and tenants.

Personal data and / or Special category data.

Property purchases (new build and ‘right to buy’).

Legal bases for processing:

  • because it is necessary for a legal obligation under the Government legislation for ‘right to buy’;

  • because it is necessary for a legal obligation under property legislation); or

  • because it is necessary for our legitimate interests which are linked to the property purchase.

Condition for processing:

  • with your explicit consent relating to your property purchase. 

Customers and tenants.

Personal data and / or Special category data.

Neighbourhood safety (e.g. anti-social behaviour, hazard and fault reporting, outreach groups).

Legal bases for processing:

  • with your consent; 

  • because it is necessary for our contract with you for your tenancy;

  • because it is necessary for a legal obligation under your tenancy; or

  • because it is necessary for our legitimate interests which are linked to your tenancy.

Condition for processing:

  • with your explicit consent relating to your anti-social behaviour report, fault or hazard report, or neighbourhood safety.

Customers and tenants.

Personal data and / or Special category data.

Support for tenants with disability (e.g. Careline, property adaptations, rapid response service).

Legal bases for processing:

  • because it is necessary for our contract with you for your tenancy;

  • because it is necessary for a legal obligation under your tenancy; or

  • because it is necessary for our legitimate interests which are linked to your tenancy.

Condition for processing:

  • with your explicit consent relating to your tenancy and tenancy support received.

Customers and tenants.

Personal data and / or Special category data.

Customer complaints, feedback and service evaluation (in relation to service accessed or tenancy).

Legal bases for processing:

  • with your consent;

  • because it is necessary for our contract with you for your tenancy; or 

  • because it is necessary for our legitimate interests which are linked to the service you accessed.

Condition for processing:

  • with your explicit consent relating to your access to our services.

Workers.

Personal data and / or Special category data.

Payroll services (e.g. expenses, salaries).

Legal basis for processing:

  • because it is necessary for our contract of employment with you.

Condition for processing:

  • to carry out obligations under employment and social security and social protection law.

Workers.

Personal data and / or Special category data.

Training & development (e.g. job related and or mandatory training).

Legal bases for processing:

  • because it is necessary for our contract of employment with you; or

  • because it is necessary for our legitimate interests which are linked to your job.

Condition for processing:

  • with your explicit consent relating to your job.

Workers.

Personal data and / or Special category data.

Health and safety (e.g. health and safety and / or risk assessments, occupational health).

Legal basis for processing:

  • because it is necessary for a legal obligation under health and safety regulation.

Condition for processing:

  • with your explicit consent relating to occupational health and safety.

Workers.

Personal data and / or Special category data.

Facilities management (e.g. access fobs, identity badges, lockers).

Legal basis for processing:

  • because it is necessary for our legitimate interests which are linked to your job.

Condition for processing:

  • with your explicit consent relating to your job.

Workers.

Personal data and / or Special category data.

Human resources (e.g. absence, employment contracts performance monitoring).

Legal basis for processing

  • because it is necessary for our contract of employment with you.

Condition for processing:

  • because it is necessary for the purposes of preventive or occupational medicine, for assessing the working capacity of an employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional.

Workers.

Personal data and / or Special category data.

Partnerships and communications (e.g. corporate events, corporate Facebook account, filming and photographs for marketing).

Legal bases for processing:

  • with your consent; or 

  • because it is necessary for our legitimate interests which are linked to your job.

Condition for processing:

  • Not applicable.

Workers.

Personal data and / or Special category data.

On boarding new starters (induction process).

Legal basis for processing:

  • because it is necessary for our contract of employment with you.

Condition for processing:

  • with your explicit consent relating to your job.

Job applicants.

Personal data and / or Special category data.

Recruitment and selection (recruitment process).

Legal basis for processing:

  • because it is necessary for our contract of employment with you.

Condition for processing:

  • with your explicit consent relating to your job.

 

 

Where you do not provide this personal data and / or special category personal data above, we may not be able to fulfil the corresponding purposes and this may adversely impact on the Services that we are able to provide to you.

We may carry out automated decision making and / or profiling for the purposes of the Careline and Concierge Services, debt enforcement and recovery, marketing, money advice, property maintenance and repair, recruitment of Board members, tenancy applications and sign up and terminations, and workers’ development and training.

Who do we share your personal data with?

We may share your personal data in certain circumstances with one or more of the following: BH subsidiaries such as Maxmedia and Starts With You, British Gas, DBS check providers, educational and training organisations, external auditors, external property valuers, external service providers, financial organisations, health and social welfare organisations, HomeSwapper, insurance companies, local and national government bodies, other employers regarding job references, other housing associations or landlords, pension providers, prison service, regulatory authorities, research organisations, solicitors, the media, trade unions, Trustmarque, and where required by law, with other bodies such as the courts and the police.

Why do we conduct data matching

We are supporting computerised data matching. It is part of the Cabinet Office’s National Fraud Initiative (NFI) and will help us to identify fraudulent claims and payments.

Data matching works by comparing sets of computer records held within or between organisations. This is usually personal data. Where records are found to be inconsistent, the reason needs to be investigated.

The Cabinet Office carries out the NFI data matching exercise. By volunteering our data for this, we are taking action to protect ourselves and others against fraud.

We provide specific sets of data, including details of our creditors, as set out in their guidance.

The use of data by the Cabinet Office in a data matching exercise is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. It does not require your consent under the DPA and GDPR.

Data matching by the Cabinet Office is also subject to the Code of Data Matching Practice.

For further information on the Cabinet Office’s legal powers and the reasons for matching particular information, you may wish to consider their Privacy Notice.

How long do we keep your personal data?

We may keep your personal data for no longer than necessary and for a period of up to 15 years in order to provide our Services to you and to fulfil legal, contractual and regulatory requirements.

What rights do you have in respect of your personal data?

You have rights, subject to exemptions, under the DPA and GDPR:

 

  • to be informed via this Privacy Notice about our collection and use of your personal data;
  • to withdraw your consent at any time, where we are relying on your consent as a basis and / or condition for processing;
  • to make a subject access request for a copy of your personal data;
  • to request that we correct your personal data if it is inaccurate or out of date;
  • to request that we erase your personal data where it is no longer necessary for us to retain it;
  • to request a restriction is placed on further processing where there is a dispute in relation to the accuracy or processing of your personal data;
  • to request that we provide you with your personal data and where possible, transmit that data directly to another data controller;
  • to object to the processing of your personal data;
  • to not be subject to automated decision making including profiling; and
  • to lodge a complaint with the Information Commissioner's Office by writing to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or casework@ico.org.uk.

You may be able to exercise these rights on behalf of other individuals with their express permission.

However, information about a deceased person does not constitute personal data and is not subject to the DPA and GDPR. Therefore, we are not obliged and we will not respond to, requests under the DPA and GDPR in respect of the information of deceased individuals (regardless of your relationship to them) as a matter of course. 

How can you contact us about your personal data?

If you would like to make a subject access request to BH, please complete Subject access form[docx] 678KB  and submit this form to: Bolton at Home,
Information Governance Team,
2nd Floor,
Valley House,
98 Waters Meeting Road,
Bolton BL1 8SW
or email IG@boltonathome.org.uk

Please ensure that you follow the instructions within the form, such as the requirement to provide proof of your identity, as failure to do so may delay our processing of your request.

If you have any questions or complaints about how we handle, or you would like to exercise your other rights in respect of, your personal data, please write to:
Bolton at Home,
Information Governance Team,
2nd Floor, 
Valley House,
98 Waters Meeting Road,
Bolton BL1 8SW
or email IG@boltonathome.org.uk

Why are we not subject to Freedom of Information?

We are a charitable Community Benefit Society. We do not constitute a public authority under the Freedom of Information Act 2000 (FOIA) and Environmental Information Regulations 2004 (EIR), and therefore, we are not obliged and we will not respond to, requests under such legislation as a matter of course.

However, you are able to consider corporate information that we have chosen to make publicly available in the 'About us' section of our website.

If you would like independent advice in regard to our status under the FOIA and EIR, you may wish to contact the Information Commissioner's Office, which is the regulator for this legislation, by writing to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or casework@ico.org.uk.

When do we update this Privacy Notice?

We will review this Privacy Notice annually, or sooner if required. The last date of review for this Privacy Notice was 23 May 2018.