Privacy and cookies

Our privacy notice has three sections

• For customers
• For Staff
• For customers and staff

Coastline Privacy Notice

At Coastline Housing Ltd (Coastline) we are committed to ensuring that your privacy is protected, and that data is used in accordance with the data protection legislation in force in England and Wales.

This privacy notice sets out why we collect personal information from you, how we use it and who we may share it with. It also explains your individual rights under the current data protection legislation.

If we ask you to provide information which can identify you, then we will only use it in accordance with this privacy notice.

We may change this notice by updating it on our website. You should check the notice from time to time to ensure that you are happy with any changes.

Any queries regarding this notice and our privacy practices can be sent to the company Data Protection Officer by email using sara.pascoe@coastlinehousing.co.uk or by writing to the Data Protection Officer at:

Coastline Housing Limited
4 Barncoose Gateway Park
Pool
Redruth
Cornwall
TR15 3RQ

Alternatively you can telephone us on 01209 200200.

Who we are

Coastline Housing Limited is a registered housing provider and charity.

For the purposes of data protection legislation, Coastline Housing Limited is a Data Controller.

Our Privacy Notice is in three sections:

1. For Customers
2. For Staff
3. For Customers and Staff

Customers

(current, prospective and former)

Why we collect information

We collect and process your information because you have entered into, or wish to enter into a contract (tenancy agreement) with us. This is generally the legal basis for processing your information and carrying out our activities. We need the information to help us assess and manage your tenancy and to provide the services you have requested from us.

There will also be times when processing personal information is necessary for a legitimate interest pursued by Coastline or a third party. Where processing is being carried out because of a legitimate interest, this will be set out in the privacy notice. Some of the information that we hold will be with your consent – we will always make it clear when this is the case, and also explain how you can withdraw your consent.

What information we collect about you

We will collect the following information from you when it is needed to manage your tenancy. If you do not provide the information we need then you may not be able to hold a tenancy with us.

Existing customers

• Name and date of birth
• Details of people who occupy the property with you

We may also hold other information which is necessary to the management of your tenancy agreement that will vary on a case by case basis. This would be to help us resolve a tenancy management issue such as arrears of rent, alleged or actual anti-social behaviour, criminal activities or fraud. This information may also potentially be used to safeguard our staff or any risks to other people including children.

To help us to manage your tenancy and /or provide services to you we may also hold the following information about you:

• Contact details, such as telephone numbers and email addresses to help us communicate with you
• Bank details
• Marital status
• Diversity information such as gender, ethnicity, cultural or religious beliefs/ needs and sexual orientation, to assist us with equality and diversity monitoring which is a regulatory requirement
• Disabilities, support needs or vulnerabilities. With your consent we use this information to tailor our service to better meet your particular circumstances and needs. We will also use the information when assessing the need for any adaptations within your property
• Employment status and your current financial information. With your consent we may use this to help resolve arrears payments and optionally to provide welfare, benefits and debt advice as a free service to help you budget and pay your bills. With your consent we may use this to apply for funding on your behalf
• We may send you customer satisfaction surveys, which we will use to make improvements to our services. It is optional for you to respond to these surveys, and the information that you provide will be anonymized
• We will collect demographic information such as preferences and interests, with your consent.
• We will ask for emergency contact details in case we need to get in touch with your chosen person.
• Signature and/or photographic identification, for the prevention and detection of tenancy fraud
• Your IP address when using our online service My Coastline

Most of this information will be supplied by you directly, although we may sometimes receive information from outside agencies.

Prospective customers

If you apply for a property with us, in addition to the above information, we need the following information before we will confirm the allocation of a property:

• Current address, previous address, and forwarding address
• Your application for rehousing, and confirmation that the details on it are correct
• Details of your financial circumstances, including employment details and welfare benefit entitlements
• Bank or building society details
• National Insurance number
• Other organizations who are involved with your household
• Unspent criminal convictions

Former customers

If you move to a different property we will retain information as follows:

• If you move to another Coastline property and start a new tenancy with us it is in our legitimate interests to retain all your previous tenancy information to assist with managing your current tenancy
• If you move to a property which is not owned or managed by Coastline we retain basic tenancy information as part of your contract in order that we can provide information in the event of you making an application under the right to buy or the right to acquire
• If you move to a property which is not owned or managed by Coastline it is in our legitimate interests to:
• Continue to hold details of any outstanding debt against your tenancy
• Keep records of any anti-social behaviour that occurred during the course of your tenancy

How we collect your information

Coastline Housing Limited collects information from you via a variety of sources, including when you apply for one of our properties, complete one of our forms, write, call, email or meet with us or respond to a survey.

Telephone calls

Calls made to Coastline through our call centre, may be recorded. Recordings of calls may be used, in pursuit of our legitimate interests, for the following reasons:

• For staff training to develop confidence and potential of staff and to improve services
• To check and measure whether we meet standards agreed with customers
• For use in appraisals with staff to develop better customer service
• As evidence where there are disputes
• As evidence in investigations concerning either our customers or staff

Access to call recordings is through sampling apart from training purposes or when abusive or threatening behaviour has occurred or a complaint has been made and requires investigation.

We may collect information when you use our social media sites, websites or self-service portal.

CCTV

We will also operate CCTV/sound recording in and around some properties in pursuit of our legitimate interests to provide a safe and secure environment for residents and to protect the general interests and well-being of all building users.

We operate CCTV systems at Coastline House, Miners Court, and the Homeless Service in pursuit of our legitimate interests of building security and the detection and prevention of crime.

Photographs

We may take photographs at our events and in our communities to use for general marketing and publicity. However, photographs of individuals will only be used for those purposes with your consent.

We may also on occasion take photographs of our properties (including the interior). It is in the legitimate interest of Coastline to record any issues within our properties, including where it is in a poor condition, to assist both the management of property and potentially your tenancy.

We may receive information about you from third parties including:

• Your council or benefits office relating to your housing
• Credit agencies and Previous landlords when you apply for housing
• Police, welfare or support organisations dealing with you
• Councillors, MP’s or other representatives acting on your behalf or with your instruction
• Financial institutions when you apply for our services

Internet

When you sign-up to our online service My Coastline we will record your IP address.

What we do with it

We may use your personal information as follows:

Existing customers

• To provide a service that you request as part of your tenancy agreement, for example, to pr ovide a repairs service
• To understand your needs and provide you with a better and more supported service
• To comply with our legal obligations
• For internal record keeping
• To survey you or undertake market research about our delivery of services for quality improvement and monitoring purposes
• To send you information about the work of Coastline and events in your area that might be of interest
• To customise the Coastline website according to your interests
• We may also use this information for safeguarding our staff and other residents

With credit reference agency Experian Rental Exchange – details at www.coastlinehousing.co.uk/experian-rental-exchange

Prospective customers

We may use your personal information to help decide whether the property you have bid for with Coastline is right for you in your current circumstances by:

• Undertaking tenancy reference checks
• Undertaking affordability checks
• To research and inform the development and implementation of new products or services, for example size and location of new homes

Former customers

When you are no longer a tenant of Coastline we may use your personal information as follows:

• To confirm your occupancy of a property in the event of you making an application to buy a property under the Right to Buy or Right to Acquire
• To assess your suitability for housing with Coastline should you apply for one of our properties in the future
• For the recovery of any debts owing using third party debt collection agencies

Special Category Information

Under data protection legislation certain personal information is classed as special category. This is information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, data about sexual orientation.

We minimise our holding and use of special category personal information but, given the services we provide, there are times when we use it to understand our customers and their needs better.

We will normally only hold special category data with your explicit consent and you have a right to withdraw this consent at any time. However, if you do not wish us to process this data, it may have an impact on the services we provide to you.

On occasion we may also hold information about criminal convictions that are relevant to the management of your tenancy.

How long we keep your information

We will only store your information for as long as is reasonably necessary for us to fulfil the purposes set out in this notice. We will then securely dispose of your information.

• This is normally a maximum of six years after you cease to hold a tenancy with us.
• If when you leave a Coastline tenancy there is an outstanding debt your information will be retained in pursuit of our legitimate interests in recovering that debt.
• We will retain basic tenancy information if required to do so by law, for example to assist with Right to Buy/Right to Acquire applications.
• Recorded telephone conversations are usually kept for up to 90 days. Recorded calls that are deemed abusive or threatening are kept until any investigation action is completed.
• CCTV footage is normally kept for a period of six weeks unless it is to be used in relation to allegations of anti-social behaviour or criminal activity, when it may be retained for a period of up to two years after any legal proceedings have finished.

If you have consented to having your photograph taken, consent given is given to use it in new material for 12 months. After this time images and recordings will be either securely destroyed or archived. If we would like to use any pictures of individuals after 12 months, we will contact you to ask if you would be willing to renew your consent.

Sharing your information

We will only share your information where we are legally obliged to do so, for example:

• To provide you with the services you require
• To comply with the law (e.g. police, health authorities, inland revenue, government departments)
• Where there is a clear health and safety risk
• Where we are requested to do so by another organisation in pursuit of its legitimate interests
• Child protection and safeguarding issues
• Where there is a clear risk to yourself, staff and others
• If we hold information relating to powers of attorney or individuals who we may have been instructed to share your information with
• To seek legal advice or in connection with court proceedings or statutory action to enforce compliance with tenancy conditions
• For the detection and prevention of crime, prosecution of offenders and for the detection and prevention of fraud

We may therefore share your information with third parties from time to time such as*:

• Contractors providing maintenance and other housing related or support services
• Utility companies (water, electricity, gas)
• Consultants providing services to us
• Police
• HMRC
• Local Authorities, the NHS and Primary Care trusts
• Health professionals
• Supporting People administrative authorities
• Partner landlords
• Legal advisors, the courts
• Our insurers and auditors
• Language translation services
• Mediation partner organisations
• External assistance where you have agreed to a referral, e.g. to help with money problems
• The regulator for social housing
• Credit checking agencies and debt recovery agents
• Charities and voluntary organisations and our support partners
• A nominated third party where you have given us permission
• Banks to carry out payments through a secure system
• Companies that help us mail out newsletters etc.
• Training providers or learning organisations

We will share your name and address with utility companies at the beginning of your tenancy. This is because we have a legitimate interest in ensuring that charges are directed to those responsible. We may also share information if you move, such as a forwarding address if requested to do so by the utility company. Each third party (as data controllers in their own right) will be responsible for the safe handling of your data in accordance with their own privacy policies.

*This list is not exhaustive.

Staff

Why we collect information

We collect and process your information because you have entered into a contract of employment with Coastline and we need to process your data to perform obligations under the employment contract. This is usually the lawful basis for processing your information and carrying out our activities.

There may be instances where the lawful basis for processing is for the purpose of Coastline’s legitimate business interest, for example CCTV video footage and door access controls data.

Sometimes processing is necessary in order to comply with a legal obligation, for example we need to maintain records of sick leave and other types of leave for which statutory payments are available, as well as complying with health and safety law in certain circumstances.

Occasionally we may need to obtain occupational health reports. This will be done where it is necessary for the assessment of working capacity.

What information we collect about you

Coastline holds and processes personal data and special category personal data about its staff, which may include:

• Name
• Address
• Email address (personal and work)
• Telephone contact details
• Date of Birth
• Educational data
• Employment history
• References
• Entitlement to work in the UK
• Equality & Diversity information
• Performance management information such as appraisal records and one-to-one supervision notes
• Disciplinary and grievance records
• Learning and Development information
• Next of Kin/emergency contact details
• Health information
• Occupational health and health surveillance records
• Pay records
• Bank details
• Tax and pension information
• National Insurance Number
• Driving licence summary
• Attachment of earnings information
• Security identification photograph
• CCTV video footage
• Door access controls data
• Biometric data such as finger print recognition
• Location tracking information for lone workers
• Fleet vehicle driver tracking information
• Declarations of Interest
• Trade Union membership

How we collect your information

Information is, in the first instance, provided to Coastline by you as a prospective member of staff on an application form. This is added to by Coastline as necessary over the course of your employment.

We also collect information in the following ways:

• Telephone calls – which are made to Coastline through our call centre, are recorded.
• CCTV – both within some of our corporate buildings and on our estates
• Access control data at Coastline House
• Photographs – both on staff identity cards and events and in our communities to use for general marketing and publicity.
• Coastline vehicles are fitted with tracking devices which provide details about the driver and the way in which the vehicle is driven
• Lone worker devices are fitted with tracking devices which provide details of location for emergencies

We may also receive information about you from third parties including:

• Your Referees
• HMRC
• Our Occupational Health provider (IMASS)
• Child Benefit Agency
• Your Pension provider
• Court orders – attachment of earnings
• Trade Union membership
• Organisations that provide learning and development
• Disclosure and Barring Service

What we do with it

Coastline needs to process certain personal data about its staff for a number of administrative and management purposes:

• Managing Human Resources processes such as recruitment, payment of salaries and pensions, performance management, disciplinary and grievance processes and training and development
• Providing facilities such as the IT service
• Health and Safety reporting
• As part of an agreement, such as a post entry training loan agreement or salary sacrifice scheme
• Monitoring Fleet vehicle usage through the vehicle tracking devices
• Dealing with insurance claims
• Monitoring equal opportunities
• Building Security such as using CCTV and access controls
• Photographic ID Cards in order to identify staff to customers
• Provision of wellbeing and support services, e.g. Occupational Health
• Provision of employee benefits
• Compliance with legal obligations such as making external/statutory returns to HMRC or attachment of earnings
• Health and wellbeing programmes
• Maintaining contact with past employees

Personal data may be shared between colleagues who legitimately need the information to carry out their duties. The amount of personal information shared within Coastline will be no more than is reasonably necessary, and will be anonymised where this does not undermine the purpose for which it is to be used.

We operate a CCTV system at Coastline House in pursuit of our legitimate interests of building security and the detection and prevention of crime.

Staff photographs are used on Coastline identity cards for the purposes of identification and security. ID cards are required for access to Coastline House and its car park for building security. This access data may also be used for monitoring purposes including tracking staff movements.

There are also CCTV cameras in use at other Coastline-owned premises.

We operate CCTV/sound recording in and around some properties in pursuit of our legitimate interests to provide a safe and secure environment for residents and to protect the general interests and well-being of all building users. If you are visiting those properties your image may be captured. For more information refer to the separate CCTV Policy.

Coastline may occasionally commission photographs which could include images of staff for inclusion in promotional or corporate material.

Telephone calls

Recordings of calls may be used, in pursuit of our legitimate interests, for the following reasons:

• For staff training to develop confidence and potential of staff and to improve services
• To check and measure whether we meet standards agreed with customers
• For use in appraisals with staff to develop better customer service
• As evidence where there are disputes
• As evidence in investigations concerning either our customers or staff

Access to call recordings is through sampling apart from training purposes or when abusive or threatening behaviour has occurred or a complaint has been made and requires investigation.

Our Business Continuity plans contain the personal contact details of key members of staff, in pursuit of our legitimate interests, to enable them to be contacted if the plans need to be invoked outside of normal working hours.

Coastline monitors and records usage of IT services and applications to ensure adherence to the IT Acceptable Use Policy. This information may be provided to Coastline Senior Managers in the event of non- compliance with this policy.

Staff personal data may be analysed for management and planning purposes, for example, retirement forecasting.

Special Category Information

Coastline also processes special category data in order to fulfil obligations and exercise specific rights in the field of employment law or where it is necessary for the assessment of working capacity. This includes:

• Managing Human Resources processes such as administering Sick Pay and Sick Leave schemes, managing absence, administering Maternity Leave and related pay schemes
• In disciplinary and grievance cases where the information is strictly relevant to achieving a fair outcome.
• Managing a safe environment and ensuring fitness for work
• Assessing employees’ working capacity
• Managing obligations under Equal Opportunities legislation
• Provision of occupational health and wellbeing services to individuals
• Establishing, exercising and defending legal claims
• Equality & Diversity monitoring
• Protecting the vital interests of the employee or another person

Coastline will obtain information about past criminal convictions as a condition of employment for certain posts.

How long we keep your information

We will only store your information for as long as is reasonably necessary for us to fulfil the purposes set out in this notice, or for a maximum of six years after you cease to be employed by Coastline. Medical records relating to the control of asbestos will be kept for 40 years, as required by the Control of Asbestos Regulations 2012. For more information please see the Data Retention schedule.

If we are in dispute with you the information will be kept until legal proceedings have ended.

We will retain CCTV video footage for no more than six weeks unless the footage is being used to investigate an alleged crime or incident in which case it may be retained for up to 2 years following the conclusion of any investigation.

We will retain door access control data for 42 months.

Vehicle tracking data is kept for one year then archived for seven years. It is destroyed after seven years.

These retention periods are recorded in the Coastline Data Retention Schedule, a copy of which can be found in Policies and Strategies on the Intranet.

We will securely dispose of all information at the end of the retention period.

Sharing your information

Coastline may need to share your personal and special category personal data with third parties outside of Coastline who are contracted to work on its behalf, for example:

• Your Pensions provider
• Occupational Health
• Insurers
• Consultants including for example obtaining legal and pensions advice
• Retained legal advisors for obtaining legal advice
• Auditors undertaking investigations or carrying out periodic reviews.
• HMRC
• Child Benefit Agency/DWP
• Mortgage reference/Letting agencies
• Trade Unions
• Child care or cycle to work organisations as part of a Salary sacrifice scheme
• Simplyhealth in connection with employee membership
• AXA Healthcare in connection with private medical insurance
• Skyguard in connection with MySos lone working devices
• Organisations that provide learning and development
• PCC for attachment of earnings
• The Police
• ACAS and employment tribunal services if necessary to defend employment claims

Where relevant, we will share information such as name, payroll number and union subscription rate with the trade unions.

Vehicle tracking data (from Coastline fleet vehicles) is held on a hosted site by Masternaut (the system owners). This will include personal information and is used to assist in the management of Fleet vehicles. Other IT data might be used for testing purposes outside of Coastline. The contract with Masternaut includes appropriate protection of the data at all times.

Coastline will, on request, confirm dates and nature of your employment to a prospective employer if you have identified us as a referee. We will also provide salary/employment information to mortgage or letting agencies where you have given consent for us to do so.

In addition, we may share your data where we are legally obliged or able to do so, for example:

• To comply with the law (e.g. police, health authorities etc.)
• To seek legal advice or in connection with court proceedings or other statutory action
• Where there is a clear health and safety risk
• If there are child protection and safeguarding issues
• Where there is a clear risk to building users
• For the detection and prevention of crime, prosecution of offenders and for the detection and prevention of fraud

We may securely share payroll data with our software supplier as part of system management for a limited period of time, after which it is securely destroyed.

We will not share your personal information with anyone who claims to represent you unless we are satisfied that you have appointed them or they act in some recognised official capacity. We do not give out information to other employees requesting your personal information (for example your address or data of birth) unless there is a legitimate business reason for doing so.

Your responsibility

You are responsible for checking that any personal data you provide Coastline is accurate and up to date. You must inform Coastline of any changes to your data (e.g. change of name or address). You are required to inform anyone whose contact details you have provided to Coastline for contacting in the case of an emergency that the information is being held and to ensure they are in agreement.

Customers and staff

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect and process. This includes mandatory training for all of our staff in the relevant data protection legislation and best practice.

Whilst the majority of the IT systems that we use are based within the UK, Coastline does use the following, which means that your data may be stored electronically outside of Europe:

• Survey Monkey
• Smart Survey
• Microsoft Cloud
• Google
• Apple
• Dropbox
• WiredPlus

Your rights in relation to your personal data

In certain circumstances, Data Protection legislation gives you a number of individual rights in relation to your personal data. More information on the individual rights and how they apply can be obtained by clicking on the associated link. These are as follows:

• The Right to be Informed about how your data is managed – this right is met by this privacy notice and a range of other notices which relate to specific aspects of Coastline, such as the CCTV privacy notice and the website privacy notice.
• The Right of Access to your personal information – so that you can be aware of and verify what personal data we hold.
• The Right of Rectification - to have any personal data corrected if it is inaccurate, incomplete or out of date.
• The Right of Erasure of your personal data – this only applies in certain circumstances, such as where you have given consent for us to hold information and you withdraw that consent.
• The Right to restrict processing – in certain circumstances you have the right to block or restrict how we process your data;
• The Right to data portability – which in certain circumstances allows you to obtain and reuse your personal data for your own purposes across different services
• The Right to object - in certain circumstances, to the processing of personal data. In particular you have the right to object to being sent direct marketing information.

If you would like to know more about your rights, visit the ICO website at ico.org.uk.

If you wish to exercise any of the above rights, please contact:

Governance Administrator
Coastline Housing Limited
4 Barncoose Gateway Park
Pool
Redruth
Cornwall
TR15 3RQ

Alternatively you can make a request electronically, by email, to sara.pascoe@coastlinehousing.co.uk or by telephone on 01209 200200.

Making a complaint

If you believe that Coastline Housing Limited has not handled your personal information correctly you have the right to make a complaint. You can raise a complaint in a number of different ways:

• To a Coastline staff member
• At our offices at Coastline House
• Through our website
• Using social media
• By telephone on 01209 200200
• In writing

You also have the right to lodge a complaint with the Information Commissioners Office at:

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Coastline Housing Limited collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests should be sent to the Coastline Data Protection Officer at the above address.

If you or someone you know would like this information in large print, braille, or translated into another language, please contact our Governance Administrator on 01209 200200 or by email at sara.pascoe@coastlinehousing.co.uk

Updated 12th July 2019.