Privacy Notice (Updated 19 January 2021)

Introduction

As part of the housing, support and employment services we offer, we are required to process personal data about our customers, which may include children, our staff and, in some instances, the friends or relatives of our customers and staff. ‘Processing’ can mean collecting, recording, organising, storing, sharing or destroying data. This document will explain how and why we process your data.

We are committed to providing transparent information on why we need your personal data and what we do with it. This information is set out in this privacy notice. It will also explain your rights when it comes to your data.

If you have any concerns or questions please contact our Data Protection Officer (Head of Governance) or our customer services team:

Contacting customer services:

Writing to our registered office:

Phone: 0333 012 4307

Email: customer.services@advanceuk.org

Website: www.advanceuk.org/contact-us

 

Advance Housing and Support Ltd.

2 Witan Way, Witney Oxon, OX28 6FH

This Privacy Notice contains the following sections:

  • Customers
  • Staff (including Volunteers and Board Members)
  • Friends/Relatives/Associates
  • Our Website
  • Your Rights

Summary of key changes in this update:

 

Customer Section

  • Inclusion of COVID-19 information
 Staff section
  • Inclusion of COVID-19 information

 

Customers

What data do we have?

So that we can provide safe, professional and person-centred services, we need to keep certain records about you. We may process data about your tenancy or lease, your support plan or your employment plan with us. We may process your personal data that you have provided for the use of our services (‘service data’), whether by you or by any third party with whom you or we have a separate relationship with (e.g. a Local Authority). We may record data about you classified as ‘general category’ data, including:

  • Your basic details and contact information e.g. your name, address, date of birth and next of kin;
  • Your financial details e.g. details of how you pay us for your support, your funding arrangements, or how you fund your

We also record the following data which is classified as ‘special category’ such as:

  • Health and Social care data about you, which might include both your physical and mental health data, including COVID-19 information;
  • Medical information required to support or allocate accommodation to you;
  • Data about your race, ethnic origin, sexual orientation and religious or philosophical beliefs;
  • Photographs or other biometric

We may also collect and holds criminal record information (including alleged offences).

Why do we have this data?

We require this data to provide you with the best housing, support and employment services tailored to meet your individual needs.

By law, we need to have a lawful basis for processing your personal data. We process your data for one of the following reasons:

  • We are required to do so in order to fulfil a contract that we have with you;
  • We have a legal obligation to do so – generally under the Health and Social Care Act 2012 or Mental Capacity Act 2005, or to comply with regulatory requirements;
  • We are required to do so in our performance of a public task;
  • To protect the vital interests of you as the data subject or another person;
  • We have a legitimate interest;
  • We have consent from

Examples of why we process your special category data:

  • Processing is necessary for reasons of substantial public interest, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject;
  • It is necessary due to employment, social security and social protection law (generally this would be in safeguarding instances);
  • It is necessary for us to provide and manage health and social care

We may also process your data with your consent (for example for direct marketing, use of your information in a case study or pre-contract applications). If we need to ask for your permission, we will offer you a clear choice and ask that you confirm to us that you consent. We will also explain clearly to you what we need the data for and how you can withdraw your consent.

Where do we process your data as a customer?

So that we can provide you with high quality services we need specific data. This is collected from or shared with:

  1. You or your legal representative(s);
  2. Third parties.

We collect information through face-to-face contact, phone, email, our website, post, application and referral forms, online apps, software and closed-circuit television (CCTV).

Third parties are organisations we have a lawful basis to share your data with. These include:

  • Health and Social Care, such as local hospitals, GPs, social workers, clinical commissioning groups, and other health and social care professionals;
  • The Local Authority and DWP;
  • Organisations we have a legal obligation to share information with e.g. for safeguarding, Regulator for Social Housing, the CQC and Ministry of Housing, Communities and Local Government (MHCLG) via the CORE (continuous reporting) system;
  • The police or other law enforcement agencies if we have to by law or court order;
  • Suppliers of contracted services, such as cleaning, gardening and property repairs.

We may also share your data with your consent, such as with your family and friends.

Only with your consent will we share information about any COVID-19 symptoms or positive test with third parties, unless we have a legal basis to do so.

Staff (including Volunteers and Board Members)

What staff data do we have?

As an employer we need to keep certain records about you. This will include gathering information at the pre-employment stage. We will record data about you classified as ‘personal’ data including:

  • Basic details and contact information e.g. your name, address, date of birth, National Insurance number and next of kin;
  • Financial details e.g. details so that we can pay you, insurance, pension and tax details;
  • Training and supervision records;
  • Your declarations of

We also record the following data which is classified as ‘special category’ such as:

  • Health and social care data about you, which might include both your physical and mental health data – we will only collect this if it is necessary for us to know as your employer, e.g. fit notes in order to claim statutory sickness pay, occupational health assessments in order to make reasonable adjustments and information relating to COVID-19;
  • We may also record data about your race, ethnic origin, sexual orientation, religious or philosophical beliefs, trade union
  • We also record photographs or other biometric

As an organisation using the Disclosure and Barring Service (DBS) checking service to help assess the suitability of applicants for positions of trust, Advance complies fully with the code of practice regarding the correct handling, use, storage, retention and disposal of certificates and certificate information. 

Why do we have this staff data?

We require this data to contact you or your next of kin (in an emergency), confirm your eligibility to work in the UK, pay you and make sure you receive the training and support you need to perform your job.

By law, we need to have a lawful basis for processing your personal data. We process your data for one of the following reasons:

  • We are required to do so in order to fulfil a contract that we have with you;
  • We have a legal obligation under UK employment laws;
  • We are required to do so in our performance of a public task;
  • We have a legitimate interest;
  • To protect the vital interests of you as the data subject or another person;
  • We have consent from

We process your special category data because, for example:

  • It is necessary due to employment, social security and social protection

If we request your criminal records data it is because we have a legal obligation to do this due to the type of work you do. This is set out in the Data Protection Act 2018 and the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975. We do not keep a record of your criminal records information (if any).

We may also process your data with your consent. If we need to ask for your permission, we will offer you a clear choice and ask that you confirm to us that you consent. We will also explain clearly to you what we need the data for and how you can withdraw your consent.

Where do we process your data?

As your employer we need specific data. This is collected from or shared with:

  1. You or your legal representative(s);
  2. Third parties.

We collect information through face-to-face contact, phone, email, our website, post, application and referral forms, online apps, software and closed-circuit television (CCTV). 

Third parties are organisations we have a lawful basis to share your data with. These include:

  • Her Majesty’s Revenue and Customs (HMRC);
  • Our pension and pension advisors;
  • Healthcare/assistance schemes (including lone working scheme and occupational health;
  • Regulators, commissioners e.g. Local Authority for safeguarding purposes and CQC;
  • The police or other law enforcement agencies if we have to by law or court order;
  • Our DBS service provider;
  • Employees benefit schemes, employee support schemes and grant funding organisations.

Friends, Relatives & Associates

What data do we have?

As part of our work of providing the best quality services, it might be necessary that we hold the following information on you:

  • Your basic details and contact information e.g. your name and address 

Why do we have this data?

By law, we need to have a lawful basis for processing your personal data. We process your data because we have a legitimate business interest in holding information about our customer’s next of kin, lasting power of attorney/guardian/ appointee or information about associates or advocates in a customer’s support network that the customer has chosen to speak on their behalf, or be actively involved in the service they receive.

In relation to those associated with our staff, we process your data because we have a legitimate business interest to hold next of kin and other emergency contact details for our employees.

We may also process your data as a friend, relative or associate with your consent. If we need to ask for your permission, we will offer you a clear choice and ask that you confirm to us that you consent. We will also explain clearly to you what we need the data for and how you can withdraw your consent.

 Where do we process the data of friends, relatives & associates? 

So that we can provide high quality services we need specific data. This is collected from or shared with:

  1. You or your legal representative(s);
  2. Third parties.

 We collect information through face-to-face contact, phone, email, our website, post, application and referral forms, online apps, software and closed-circuit television (CCTV).

Third parties are organisations we have a lawful basis to share your data with. These may include:

  • Health and Social care, such as local hospitals, GPs, social workers, clinical commissioning groups and other health and social care professionals;
  • The Local Authority and DWP;
  • The police or other law enforcement agencies if we have to by law or court order.

Our Website

In order to provide you with the best experience while using our website, we process some data about you. Users aged 16 and under must get consent from their parents or guardians before giving us personal information.

Our website may contain links to and from third party websites. Advance does not control these third party sites. If you follow a link to any of these websites, please note that these websites have their own privacy notices which you should read and that we do not accept responsibility or liability.

Advance sites may also have ‘plugins’ (such as the Facebook ‘Like’ button) to third party sites or to offer login (such as log in with Facebook) through a third party account. Third party plugins and logon features, including their loading, operation and use, are governed by the privacy notice and terms of the third party providing them.

When you use our website we receive information from your web browser about how you use our website, including pages on our website you visit. The information includes your IP address (a unique identifier assigned to your computer) which does not identify you personally. We use this information to review and improve our website.

We may ask you to register on or log into certain areas of our website in order to provide you with a personalised experience of our website, such as to provide you with helpful information based on the details you have given us. If you use the ‘email a friend’ tool, we do not store your friend’s contact details.

If you have used our website to register or subscribe to a mailing list, please read those particular web pages or the emails you have received to find details about how to edit your information or unsubscribe from that particular mailing list. If you are an Advance customer and have a contract with us, we may not be able to remove your details or stop contacting you altogether.

Cookies

Cookies make websites work better. They collect information about your usage and we use them to help make your visits more effective.

Our website uses cookies to distinguish you from other users of our site. For detailed information on the cookies we use and the purposes for which we use them, see Advance’s Online Links and Cookie Statement and the Website Content Disclaimer available on our website.

Your Rights

The data that we keep about you is your data and we ensure that we keep it confidential and that it is used appropriately. You have the following rights when it comes to your data:

  1. To request a copy of all of the data we keep about you.
  2. To ask us to correct any data we have which you believe to be inaccurate or incomplete. You can also request that we restrict all processing of your data while we consider your rectification request.
  3. To request that we erase any of your personal data which is no longer necessary for the purpose we originally collected it. We retain our data in line with the relevant codes of practice. Our retention policy is available on request.
  4. To request that we restrict processing if we no longer require your personal data for the purpose we originally collected it for, but you do not wish for it to be erased.
  5. To request your data to be erased if we have asked for your consent to process your data. You can withdraw consent at any time – please contact us to do so.
  6. If we are processing your data as part of our legitimate interests as an organisation or in order to complete a task in the public interest, you have the right to object to that processing. We will restrict all processing of this data while we look into your objection.
  7. You can request that we provide you with a portable copy of your information that could, for example, be used by another provider.

Please be aware that if you do not provide relevant information, we may be unable to provide you with the services you or your legal representative(s) have requested.

You may need to provide adequate information for our staff to be able to identify you, for example, a passport or driver’s licence. This is to make sure that data is not shared with the wrong person inappropriately. We will always respond to your request as soon as possible and at the latest within the timescales set out by the Information Commissioner’s Office.

If you would like to complain about how we have dealt with your request, please contact:

Information Commissioner’s Office Wycliffe House

Water Lane Wilmslow Cheshire SK9 5AF

 https://ico.org.uk/global/contact-us/