Our commitment to Data Protection

Poplar HARCA is committed to protecting the information we hold on our residents and customers. The following Fair Processing Notice outlines how we use personal information we collect from you.

What is personal data?

Under the Data Protection Act 1998, personal data is defined as data that relates to a living individual who can be identified:

(a) from those data, or

(b) from those data and other information which is in the possession of, or likely to come into the possession of, the data controller,

and includes any expression of opinion about the individual, and any indication of the intentions of the data controller or any other person in respect of the individual.

Personal data will therefore cover the following

•    Name

•    Date of birth

•    Family name

•    Gender

•    Current and previous address data

•    Address type (home, rented, temporary)

•    Start date at current address

•    Start and end date at previous address

•    Contact details (must provide one type)

•    Evening/daytime/obile telephone numbers

•    E-mail address

•    Contact preference

•    Preferred language

•    Family relationships

•    Marital status

•    Agreement to store data on customer service database

•    Citizenship

•    Service identifier (eg library membership number)

•    Service requests and their outcomes

Sensitive personal data

Certain data is classified under the Act as sensitive personal data, for example:

•    Racial or ethnic origin

•    Religious or other beliefs of a similar nature

•    Physical or mental health or condition

•    Sexual life

•    Offences (including alleged offences)

•    Political Opinions or Persuasion

•    Trade union membership or affiliation

•    Commissioned or Alleged Commission of Offences

•    Any proceedings for any offence, committed or alleged, including any sentencing decisions made by the court

Consent is required for both types of personal data, and must be provided for sensitive data. Where we ask you for sensitive personal data, we will always tell you why and how the information will be used.

Why we need to collect and store personal data

For some of our services, we need to collect personal data so we can get in touch, or provide the service. For example, we can't come to your house if we don't know your address. We always try to make sure the information we collect is correct and isn't an invasion of your privacy.

How we use use your information

Poplar HARCA will collect, store and use the information you provide in a way that is compatible with the Data Protection Act. We will try to keep your information accurate and up to date and not keep it for longer than is necessary. In some instances the law sets the length of time information has to be kept, but in most cases we will use its discretion to make sure that we do not keep records outside of our normal business requirements - i.e. providing a service to you.

Our aim is not to be intrusive, and we won't ask irrelevant or unnecessary questions. Also, the information you provide will be subject to rigorous measures and procedures to make sure it can't be seen, accessed or disclosed to anyone who shouldn't see it.

We will use the information you provide for the following purposes:

•    Regulatory, licensing and enforcement functions, which we are obliged to do.

•    All financial transactions to and from Poplar HARCA, such as payments, grants and benefits.

•    Where you have agreed for the purpose of consulting, informing and getting your opinion about our services.

•    To make sure that we meets our statutory obligations, including those related to diversity and equal opportunity.

•    For the service you requested, and to monitor and improve our performance in responding to your request.

•    To allow us to be able to communicate and provide services and benefits appropriate to your needs.

•    To ensure that we meet our legal obligations.

•    To prevent and detect fraud or crime.

•    Where necessary to protect individuals from harm or injury.

•    To allow the statistical analysis of data so we can plan the provision of services.

Information sharing

We may pass your personal data onto the people who provide our services. These providers are obliged to keep your details securely, and use them only to fulfill your request. Once your request has been dealt with or the case has been closed, they will get rid of the information. If we wish to pass your sensitive personal data onto a third party, we will only do so once we have obtained your consent, unless we are legally required to do so.

Partners who we may share some of your information with

•    Police and Safer Neighbourhood Team

•    London Borough of Tower Hamlets

•    Service providers i.e. survey companies

•    National Health Service and Primary Care Trust

•    Solicitors, courts and baillifs

•    Repairs and regeneration contractors

We may give information to our partners where it is necessary, either to comply with a legal obligation, or where permitted under the Data Protection Act. For example where the disclosure is necessary for the purposes of the prevention and/or detection of crime.

Where we need to disclose sensitive or confidential information to our partners, we will do so only with your prior explicit consent or where we are legally required to.

We may disclose information when necessary to prevent risk of harm to an individual. For example, we will inform our contractors of addresses where there may be a potential risk or harm. We do not disclose information to our contractors which details the nature of the risk but advise contractors to take caution, visit with a colleague or speak to a relevant Poplar HARCA officer.

At no time will your information be passed to organisations external to Poplar HARCA for marketing or sales purposes or for any commercial use without your prior express consent.

Retaining information

We will only retain the information if a business need exists. It is not kept longer than is necessary for that purpose. Poplar HARCA has in place and applies a formal retention policy for recorded information.

Detect and prevent fraud or crime

We are required by law to protect the public funds we administer. We may use any of the information you provide to us for the prevention and detection of fraud. We may also share this information with other bodies that are responsible for auditing or administering public funds including the Audit Commission, the Department for Work and Pensions, and other local authorities, HM Revenue and Customs, and the Police.

We will also do our own data matching to identify errors and potential frauds. We take part in national data matching exercises done by the Audit Commission. Data matching involves comparing computer records held by one body against other computer records held by the same or another body to see how far they match. This is usually personal information. Computerised data matching allows potentially fraudulent claims and payments to be identified. Where a match is found it indicates that there is an inconsistency that requires further investigation. No assumption can be made as to whether there is fraud, error or other explanation until an investigation is carried out.

The Audit Commission currently requires us to participate in a data matching exercise to assist in the prevention and detection of fraud usually once every two years. We are required to provide particular sets of data to the Audit Commission for matching for each exercise, and these are set out in the Audit Commission’s guidance, which can be found at Audit Commission - National Fraud Initiative.

Telephone calls

We will inform you if we record or monitor any telephone calls you make to us. This will be used to increase your security, for our record keeping of the transaction and for our staff training purposes.

Emails

If you email us we may keep a record of your contact and your email address and the email for our record keeping of the transaction. For security reasons we will not include any confidential information about you in any email we send to you. We would also suggest that you keep the amount of confidential information you send to us via email to a minimum.

CCTV

We have installed CCTV systems in some of our locations used by members of the public, for the purposes of public/staff safety and crime prevention/detection. In all locations, signs are displayed notifying you that CCTV is in operation and providing details of who to contact for further information about the scheme.

We will only disclose CCTV images to others who intend to use the images for the purposes stated above. CCTV images will not be released to the media for entertainment purposes or placed on the internet.

Images captured by CCTV will not be kept for longer than necessary. However, on occasions there may be a need to keep images for longer, for example where a crime is being investigated.

How we protect your information

Our aim is not to be intrusive, and we won't ask irrelevant or unnecessary questions. The information you provide will be subject to rigorous measures and procedures to make sure it can't be seen, accessed or disclosed to anyone who shouldn't see it.

We have a set of information security policies, provide training to staff who handle personal information and treat it as a disciplinary matter if they misuse or do not look after your personal information properly.

We will not keep your information longer than it is needed or where the law states how long this should be kept

We will dispose of paper records or delete any electronic personal information in a secure way.

Your rights

You are legally entitled to request access to any information about you that we hold, and a copy.

We try to ensure that any information we hold about you is correct. There may be situations where you find the information we hold is no longer accurate and you have the right to have this corrected.

For more information on data protection visit the Information Commission Office website www.ico.org.uk