In order to deliver our services, Elim needs to gather personal data from its residents, service users, and those applying for housing. This makes us a Data Controller.

Elim respects your privacy and are committed to protecting your personal data. This Privacy Notice gives you information about the personal data, including sensitive personal data, we collect, why we collect it and how we look after it. It will give you information about your rights and explain what you can do if you have any questions or concerns.

Although this notice is geared towards residents of Elim homes, the notice is also applicable to any other individual who provides personal data to Elim, e.g. a member of staff or a job applicant.

Elim is a provider of social, supported and other types of housing, registered with Homes England. Our normal activities are:

• Providing social and other types of housing
• Delivering housing related support services
• Property and grounds maintenance and repair
• Managing tenancy, license or leases as a landlord
• Developing new housing

Elim has a profit-making subsidiary, Lime Property Ventures.

Our Head Office address is Elim Housing, Units 3 & 4 Pinkers Court, Briarlands Office Park, Gloucester Road, Rudgeway, BS35 3QH, our telephone number is 01454 411172 and our email address is info@elimhousing.co.uk.

We are a Data Controller, registered with the Information Commissioners Office. Our registration number is Z7302750.

Personal data is data relating to any individual that can be used to identify that individual, for example:

• Names
• Address
• Dates of birth
• Contact Details, (ink Email and Telephone Numbers)
• National Insurance number
• Copies of any relevant identification documents
• Employment details
• Current living conditions
• Details about your home, your housing needs and the written statement of your occupation contract
• Rent & service charge information, including details of any arrears

• Financial Information, including:
o Credit checks
o Details of outgoings & any debts
o Income details
o Bank details

• Photographs taken of you or your property, such as CCTV footage or photos taken for repair assessments
• Audio recordings of calls made to & from our Head Office and other correspondence you have with Elim Housing Association
• References received about you (for example from your employer or previous landlord) We will also at your request, provide references to a new landlord on your behalf

This list is not exhaustive, and we may request other information from you. This will however only be to enable us to deliver services to you or provide additional support.

Sensitive personal data are special categories of data that are subject to additional protections in how they can be gathered and used. Sensitive personal data includes information relating to person’s:

• Ethnic or racial origins
• Political opinions or trade union membership
• Finances
• Sex life
• Philosophical or religious beliefs

Elim collects personal data to carry out the normal activities detailed above. When we collect personal data, we do so under specific legal bases. This table details our most common legal bases for processing personal data and gives examples of how we might use them in carrying out our activities.

The table is not exhaustive. For more detail about the legal bases for processing personal data you can go to the website of the Information Commissioner’s Office at www.ico.org.uk or enter ‘ICO legal basis for processing’ into Google or another search engine. The website also includes information about the bases for the processing of sensitive personal data.

We will only use your personal data for the purposes for which we collected it, unless we reasonably believe that we are using it for another legal basis.

The lawful basis for most of our personal data processing of your information is where it is necessary for the purposes of Hightown’s legitimate interests. Where Elim Housing Association relies on legitimate interests as a reason for processing data it has considered whether or not those interests are overridden by the rights and freedoms of service users and has concluded that they are not.
The lawful basis may in some instances be because we have your consent to process your personal information. Where this applies this will be made clear to you and you can withdraw your consent at any time.

We may also process your information for other reasons, such as where we are under a legal or contractual obligation to process or disclose the information; or where we need to protect your vital interests or those of another person.

Some personal information is treated as more sensitive (for example medical or diversity information). The legal basis for processing these special categories of personal information is more limited. To lawfully process special categories of personal data, we must identify a specific lawful basis for the processing, which may be because we have your consent; we need to protect the vital interests (health and safety) of you or another person; you have already made your personal information public; we or another person needs to bring or defend legal claims; there are substantial public interest grounds.

We collect personal data in a variety of ways:

• Directly from the data subject, e.g. if you give us financial information as part of an affordability test, if you provide personal information for completion of a support plan, or when an applicant for a job with us submits their application.
• From a third party, e.g. when you apply for one of our properties through a local authority’s Choice Based Lettings or Home Choice scheme.
• Digital technologies or interactions, e.g. your activity on our website may be monitored. Our website will provide you information about the gathering of cookies and similar technologies when you arrive there.
• Through CCTV footage.

In the course of carrying out our activities, we may need to share your data with third parties. This will always be done under a legal basis for processing. Most commonly, the legal basis used is that we need to share your information in order to deliver to you a service as part of our contract with you, e.g. providing your name and address to a contractor who carries out repairs for us. We always take steps to ensure:

• That we only provide personal data necessary for the activity to be carried out.
• That the third party only uses the data provided for the purpose for which it was intended.
• That the third parties we provide your information to respect the security of your personal data and are compliant with data protection regulations.

Third parties that we might expect to share information with include:
• Local authorities
• Benefit agencies
• Sub-contractors who we pay to deliver part of our service, e.g. companies providing a maintenance service
• Support agencies involved in providing a support plan
• Your potential future housing providers

We will ask for basic information about children in households; however we would not process this information as part of our normal activities. Knowing the number and age of children in a household helps us to monitor occupancy of a property and can improve any advice we might offer.

Under data protection laws, you have rights in relation to the data you choose to provide and how you want us to process it. The rights include (but are not restricted to):

The right to not provide your personal data
You do not have to provide your personal data if you would rather not. In some cases, however, not providing personal data may mean we are unable to provide a service, e.g. we cannot provide you with a tenancy agreement without your name. In other cases, failure to provide personal data may mean that we are not able to provide a service to the standard we would choose to, e.g. information
about a person’s health or disability helps us to make sure that specific needs are taken into account when arranging visits or repairs.
If you are unsure why we might need specific personal data, then please ask the member of staff you are dealing with, and they will be able to explain.

The right to request access to your personal data that Elim hold
This is known as a ‘data subject access request.’ You can make a subject access request by contacting the relevant member of staff. We will sometimes ask you to confirm the request in writing, though this will not always be necessary. We will provide you the information in writing within one calendar month of the request being received, though in most cases we would hope that we can do it much more quickly.

The right to be informed about how we use your personal data
You have the right to know about how we are using your personal data and the grounds for that usage. We will provide this information through the same process as a data subject access request.

The right to request correction to your personal data that Elim hold
It is helpful for everybody if the data that we hold is accurate. You can have any incomplete or incorrect personal data that we hold corrected by speaking to a member of staff, though we may need to verify the accuracy of the new data that you provide to us.

The right to request erasure of your personal data
You can ask us to delete your personal data if you feel that there is not good reason for us to continue to hold it. You may be asked to put your request in writing. On certain occasions we may not be able to act on your request for legal reasons, but we will always explain these reasons clearly to you.

The right to withdraw consent
Where we are processing your data on the basis of consent, you can withdraw this consent at any time, though doing so could affect the service we are providing to you.

In the majority of circumstances, we will erase or destroy personal data once it has fulfilled the purpose for which it is gathered, e.g. information gathered when determining who to allocate a property to will be erased/destroyed once the property has been allocated.

Certain personal data may need to be kept for longer for legal or other reasons, e.g. we keep tenancy agreements permanently, even after the tenancy has ended. For more detailed information on how long we retain personal data for, see our Retention Policy. This is based on National Housing Federation guidance, legal requirements and best practice.

At all times, Elim will have a named Data Protection Officer. At present, the postholder is Jane Okonkwo, Head of HR. Jane can be contacted at Head Office, by phone on 01454 411172 or by email at info@elimhousing.co.uk.

Other related documents that provide more information about Elim’s data protection are either available on our website or by request to the email address above.

The Information Commissioner’s Office has a website with extensive information - www.ico.org.uk – and can be contacted on 0303 1231113.

If you wish to make a complaint, then you can use Elim’s complaints procedure or, if you think that we in breach of any data protection regulations, you can complain directly to the ICO.