Smart Homes Project – Privacy Notice

1. Introduction

1.1 This privacy notice contains information on our Smart Homes project. The notice is designed to inform you of what the Smart Homes project is, what information we will be collecting, why we are collecting this information and your rights and responsibilities in relation to this.

1.2 The Smart Homes devices (IoT) is a network of physical objects that contain embedded technology sensors that exchange data about a property and its conditions.

1.3 The Smart Homes devices provide an insightful overview of each property’s health and condition, and allows us early identification and proactive resolution of issues that could impact upon your health, safety and/or well-being.

1.4 Using this environmental data we will be able to proactively respond to identified problems within properties, through preventative maintenance and/or advise you on the impacts of your property conditions. In most instances, the processing of the data will support you in

(a) improving your health, safety and wellbeing by detection and/or monitoring of temperature, humidity, smoke, carbon monoxide and carbon dioxide;

(b) Measuring performance and emissions of housing stock;

(d) ensuring we are compliant with our legal obligations to install detectors in your home

1.5 We will install environmental sensors in your home, which collect information on the environmental conditions inside your home in order to send you tailored advice on how to improve the quality of your home. This is at no cost to you. For more information on environmental sensors see section 3 below

1.6 As well as environmental sensors, we will install smart smoke, fire and carbon monoxide detectors where needed. This is in order to comply with the Smoke and Carbon Monoxide (Amendment) Regulations 2022. For more information see section 3 below

1.7 The data will also be used by Poplar HARCA to help us manage our properties and make better informed decisions around the services we provide, including planned maintenance of homes. We have a duty of care to our residents, so we can use the data gathered to identify potential problems before we would otherwise be aware of them. For example, high humidity levels may indicate that there is a leak which we can detect and repair before it causes damage to your home.

2. About this privacy notice

2.1 You have agreed to take part in our Smart Homes Project. This privacy notice:

Sets out our and your respective responsibilities as regards the Smart Home Project;
Explains what devices we are installing;
Explains what data these devices collect, and how and why that data will be used;
Sets out your rights in relation to the data collected;

2.2 Please read this agreement carefully as it provides you with important information about the Smart Homes Project.

3. About the devices and the data collected

3.1 The Smart Home devices installed in your home will normally be manufactured by Aico|HomeLINK and installed by one of Poplar HARCA’s contractors. They will include:

Device 1: Environmental Sensors

Conditions for installation:

All homes will receive 3 Environmental sensors:

· 1 in kitchen

· 1 in bathroom

· 1 in living room

These are battery powered, installed with batteries designed to last 10 years.

Installation required: Fixed into the walls with screws

Data collected: Temperature, Humidity, Carbon dioxide levels, System faults including batteries needing replacing

Use of data: System faults will alert us so that we can investigate and rectify the issue with the devices. When the batteries need replacing, we will replace them at no cost to you. Temperature, humidity and CO2 levels are analysed to provide insights around potential risks such as:

· Damp & mould

· Ventilation

· Fire safety

· Indoor air quality

These insights are available to you via the HomeLINK resident app, and to Poplar HARCA.

Device 2: SmartLINK Gateway

Conditions for installation: All homes will receive one SmartLINK Gateway. The Gateway requires a small amount of electricity to run. On average, this is less than £2.50 per year (based on electricity costs on 17.06.22).

Installation required: Hardwired in by electrician

Data collected: The Gateway itself does not collect data. It facilitates the feedback of data from the other devices to you via the app and to Poplar HARCA.

Use of data:

N/A

Device 3: Smart Smoke Detector

Conditions for installation: All homes will normally receive one on each floor

Installation required: Hardwired in by electrician

Data collected:

· ‘Events’ where detector has been triggered

· Testing frequency

· System fault/tampering

Use of data: When your detector has been triggered, as well as making a loud noise, you will be alerted in real time via the app. Poplar HARCA will also be notified. Detectors should be tested regularly to ensure that they are working as they should. You will be notified via the app if your detector test is overdue. Poplar HARCA will also be able to see this information. System faults will alert us so that we can investigate and rectify the issue.

Device 4: Smart Heat Detector

Conditions for installation: All homes will normally receive one in the kitchen. Heat and Carbon Monoxide Detectors will sometimes be combined.

Installation required: Hardwired in by electrician

Data collected:

· ‘Events’ where detector has been triggered

· Testing frequency

· System fault/tampering

Device 5: Smart Carbon Monoxide Detector

Conditions for installation: All homes with gas appliances will receive one. Heat and Carbon Monoxide Detectors will sometimes be combined.

Installation required: Hardwired in by electrician

Data collected:

· ‘Events’ where detector has been triggered

· Testing frequency

· System fault/tampering

3.2 Products may vary slightly from the above details and we may not install all of the devices identified above.

3.3 Though unlikely, we may need to change the devices or the services they provide:

(a) to reflect changes in relevant laws and regulatory requirements; and

(b) to implement minor technical adjustments and improvements.

3.4 We will own, install and maintain the devices. The installation will be carried out by one of our contractors who will use reasonable care and skill in installing the devices.

3.5 You will not be charged for installing the devices and there is no subscription payments for their use.

3.6 We will take reasonable steps to make sure that the devices are safe, secure and comply with relevant legal standards. This means that we (or the suppliers of the devices) may need to update software or hardware in the devices from time to time. If we need to access your property to do this, we will give you reasonable notice.

4. Data protection

4.1 As outlined in the table in 3.1 above, the smart home devices will gather data about your home and its condition, which will be provided to Poplar HARCA. In installing these devices and obtaining data from them, we are primarily interested in the property you occupy, rather than you yourself. We intend to use the data generated to help us manage it and help us make better informed decisions about our buildings and the services we provide.

4.2 The ‘Data Controller’ in respect of the Smart Homes Project is Poplar HARCA. General details about how Poplar HARCA uses your data are set out in our Privacy Notice.

4.3 The purposes of processing data are:

(a) to provide you with the benefits of the smart home devices;

(b) to gain a better understanding of the condition of Poplar HARCA’s homes;

(c) to help deliver benefits for individual tenants and the organisation – for example in terms of planned and reactive maintenance of homes, in preventing damage caused by mould or leaks, or by supporting residents to maintain healthier living environments with advice or signposting to external agencies.

4.4 The legal basis of processing personal data which may be captured in connection with the Smart Homes Project is a mix of:

(a) Consent. You are agreeing to take part in the Smart Homes Project in the knowledge it will capture data about your home which will be provided to us.

(b) Our legitimate interests. We have legitimate interests in exploring the potential benefits from using smart home devices in efficiently and effectively managing our homes and estates and providing services to our customers (including you).

4.5 We may analyse from the data we collect or combine it with other data to help build profiles of how our properties are being used. We do not intend to use the data to profile our tenants or make decisions about them without human involvement (‘automated decision making’).

4.6 Information collected will be stored for a period of 7 years after which the information will be deleted permanently. Information collected will be the same information you will have access to.

4.7 Our Smart Homes device suppliers, AICO / Home Link will be given your name, address and email address so that you are able to register and login to your Smart Homes app. No other personal data will be shared. The Supplier will also have access to anonymised data from the environmental sensors. This is so that they can gather aggregated data from all of their sensors.

4.8 Our contractors who will be instructed to install the devices will not have access to your data through the smart homes devices. We will only share with our contractors, your name and address, appointment date and time, types of devices to install, any future repairs and notes for repairs.

4.9 Under data protection law, you have rights including:

(a) Your right of access

(b) Your right to rectification

(d) Your right to restriction of processing

(e) Your right to object to processing

(f) Your right to data portability

4.10 If you have any data protection concerns, email us at dataprotection@poplarharca.co.uk.

4.11 You also have the right to complain to the Information Commissioner’s Office if you are unhappy with how we have used your data. The ICO’s address is: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Their helpline number is 0303 123 1113 and their website is www.ico.org.uk.