Housing 21 will comply with data protection legislation when collecting and processing your   personal data and we will do this by following the principles set out in the legislation, which states that the personal information we process must be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.

Personal information (‘personal data’) means any information about an individual from which that person can be identified. This includes, for example, your employee number or business email.

We also collect sensitive personal data (‘special category information’) which requires a higher level of protection.

We collect, store, and use the following categories of personal data about you:

• Contact details such as name, title, addresses, telephone numbers, and personal email addresses.
• Date of birth.
• Gender.
• Marital status and dependants.
• Next of kin and emergency contact information.
• National Insurance number.
• Bank account details, payroll records and tax status information.
• Salary, annual leave, pension, and benefits information.
• Start date.
• Location of employment or workplace.
• Copy of driving licence.
• Recruitment information (including your nationality and copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
• Employment records (including job titles, work history, working hours, training records and professional memberships).
• Compensation history.
• Performance information.
• Disciplinary and grievance information.
• CCTV footage and other information obtained through electronic means such as swipe card records.
• Information about your use of our information and communications systems.
• Photographs.

We may also collect, store, and use the following sensitive personal information:

• Information about your race or ethnicity, religious beliefs, disability, sexual orientation and political opinions.
• Trade union membership.
• Information about your health, including any medical condition, pregnancy and health and sickness records, and vaccination status including:
  • Details of any absences (other than holidays) from work including time on statutory parental leave and sick leave.
  • Where you leave employment and the reason for leaving is related to your health, information about that condition is needed for pensions purposes.
• Biometric data.
• Information about criminal convictions and offences

We collect personal information about employees, agency workers and contactors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider.  We may sometimes collect additional information from third parties including former employers and credit reference agencies.

We will collect additional personal information during job-related activities throughout the period of you working for us.

We will only use your personal information when the law allows us to.

Most commonly, we will use your personal information in the following circumstances:

• to perform the contract we have entered into with you.
• to comply with a legal obligation.
• 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.

We may also use your personal information in the following situations, which are likely to be rare:

• to protect your interests (or someone else’s interests).
• where it is needed in the public interest or for official purposes.

We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

• Making a decision about your recruitment or appointment.
• Determining the terms on which you work for us.
• Checking you are legally entitled to work in the UK.
• Paying you and, if you are an employee, deducting tax and National Insurance contributions.
• Providing benefits to you which can be found on the Reward page on the intranet and in the Employee Handbook 
• Consulting with your pension provider.
• Administering the contract, we have entered into with you.
• Business management and planning, including accounting and auditing.
• Conducting performance reviews, managing performance, and determining performance requirements.
• Making decisions about salary reviews and compensation.
• Assessing qualifications for a particular job or task, including decisions about promotions.
• Gathering evidence for possible grievance or disciplinary hearings.
• Making decisions about your continued employment or engagement.
• Making arrangements for the termination of our working relationship.
• Education, training, and development requirements.
• Dealing with legal disputes involving you, or other employees, agency workers and contractors, including accidents at work.
• Ascertaining your fitness to work.
• Managing your sickness absence.
• Complying with health and safety obligations.
• To prevent fraud.
• To ensure your use of our information and communication systems are in compliance with our IT policies.
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
• To recover or locate lost, stolen, or missing business issued devices.
• To conduct data analytics studies to review and better understand employee retention and attrition rates.
• Equal opportunities monitoring.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing an employee benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our employees).

We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, and only where this is required or permitted by law.

Special Category information requires higher levels of protection. We need to have further justification for collecting, storing, and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

• In limited circumstances, with your explicit written consent.
• Where we need to conduct our legal obligations or exercise rights in connection with employment which include but is not limited to conducting enhanced DBS checks for regulated activities.
• Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. 

We may also process such information about employees or former employees in the course of legitimate business activities with the appropriate safeguards.

We will process your sensitive personal information in the following ways:

• We will use information relating to leave of absence, which may include sickness absence or family related absence, to comply with employment and other laws.
• We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
• We will use information about your race or national or ethnic origin, religious, philosophical, or moral beliefs, disability or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
• We will use trade union membership information to pay trade union premiums, register the status of a protected employee and to comply with employment law obligations. 
• We will use information relating to criminal convictions and offences to assess suitability to work with vulnerable adults in a regulated activity.

We do not need your consent if we use your special category personal information in accordance with our written policy to conduct our legal obligations or exercise specific rights in the field of employment law. 

In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to conduct our obligations and provided, we do so in line with our data protection policy and the legislation.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it may be required to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We may also process such information about former employees during legitimate business activities with the appropriate safeguards.

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally required to do so. We will not use information about criminal convictions or offences inappropriately to unlawfully discriminate against applicants or employees with a criminal record. 

Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you during your employment with us.  We will use information about criminal convictions and offences to assess suitability to work with vulnerable adults and to meet regulatory requirements.

Automated decision-making takes place when an electronic system uses personal information to decide without human intervention. Profiling is when an automated processing of personal data to evaluate certain things about an individual and may be manual or electronic. 

• We can use automated decision-making and profiling in the following circumstances:
• Where we have notified you of the decision and given you 21 days to request a reconsideration.
• Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
• In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision or have engaged in profiling based on sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making or profiling unless we have a lawful basis for doing so and we have notified you.

Personal data may be contained within documents uploaded onto AI Tools used by Housing 21. Where this is the case, we are the data controller, and our approved AI supplier/contractor is the data processor. We have carried out the appropriate due diligence with each supplier/contractor (‘Processor’) to ensure that your personal data is protected, when processed with the use of the AI Tools, in accordance with the UK GDPR and our various information governance data protection and IT security policies.

None of your personal data will be used solely by the AI technology provider to improve their AI products. For full details please refer to our Artificial Intelligence (AI) Privacy Notice .

We may have to share your data with third parties, including third-party service providers and other entities.

We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the EU.  If we do, you can expect a similar degree of protection in respect of your personal information.

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

These include third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are processed by approved third-party service providers: payroll, pension administration, benefits provision and administration, IT services, Workplace.

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

We will share your personal information with selected third-party suppliers as part of our regular reporting activities on company performance, in the context of a business reorganisation or restructuring exercise, or for system maintenance support and hosting of data.

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business.  We may also need to share your personal information with a regulator or to otherwise comply with the law.

We only transfer the personal information we collect about you to the United States of America, to perform our contract with you, in relation to Workplace provided by Facebook.

There is an adequacy decision in place in respect of that country. This means that the country to which we transfer your data is deemed to provide an adequate level of protection for your personal information. To reinforce this protection, we have an Enterprise Agreement with Workplace. If you require further information about this protective measure, you can request it from the Communications Team.

We have put in place measures to protect the security of your information. Details of these measures are available upon request and can also be found on the intranet.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure, in line with our data protection and security policies and procedures. 

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. Additionally, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

We will only retain your personal information 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. Details of retention periods for different aspects of your personal information are available our Document Retention Schedule, which is available on the intranet. 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, the National Housing Federation’s Document Retention Schedule, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. 

Once you are no longer an employee, agency worker or contractor of Housing 21, we will securely destroy your personal information in accordance with our Document Retention Policy & Procedure and applicable laws and regulations.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us. It is your duty to inform us of any changes to your circumstances. Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct, or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer (DPO) in writing.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the DPO. 

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Housing 21 has appointed Sonia Hawley as the Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. 

You also 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.

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact the Data Protection Officer at:

Housing 21
10th Floor
Tricorn House
51-53 Hagley Road
Birmingham
B16 8TP. 

Or send an email or ring 0300 790 1325.