- The purpose of this notice.
We are committed to protecting the personal data we collect about you. This privacy notice explains what happens to the personal data you provide to us. This notice also explains the rights you have to access and challenge the personal data held by us.
This notice applies to you if you are using our services as
- a prospective, current or former tenant of Byker Community Trust (BCT);
- a job applicant;
- someone making a complaint; or
- a visitor to our website.
- Information about BCT
Our full name is Byker Community Trust Limited. Our address is
17 Raby Cross,
Newcastle upon Tyne,
We are a Registered Society registered with the Financial Conduct Authority No. 31376R.
We are the data controller of the personal data we process for our purposes, which means we are the organisation responsible for looking after and determining how the data we hold is processed.
- Different types of data
There are many different kinds of data that we may use for different purposes. In this privacy notice we refer to these categories of data:
Categories Examples Personal information Name, National Insurance Number, Passport number, nationality, date of birth. Sensitive personal information / Special category information Racial/ethnic origin, gender re-assignment, sexuality, religious beliefs, Union memberships, biometric data. Criminal convictions and offences Including spent convictions, CCJs and anti-social behaviour information. Personal contact information Address, phone numbers, email addresses. Financial information Rent account status, income & expenditure, bank details. Health and disability information Disability status, information about illnesses, health records, medical appointments, requirements for disabled property. Technical computer information Browsing history, IP addresses, method of access to our internet pages. Account logins and passwords. Family data The names, ages and relationship to you of people who live with you in your tenancy. Social network information Information commonly shared by social media platforms like Facebook e.g. profile picture, age, name.
- How we use your personal data
Please select the service:
- Prospective, current or former tenants
Why we need your data
As a prospective, current or former tenant we will collect information to:
- assess your application for housing;
- provide suitable accommodation for you;
- manage your tenancy including collecting rent from you and dealing with anti-social behaviour;
- check you are eligible for social housing;
- check you have the right to rent;
- ensure that there are no unacceptable risks posed to our customers, staff and contractors;
- process your payments to us and to reclaim these when overdue;
- to ensure utility charges are directed to those responsible for paying;
- offer support to customers to maintain your tenancy and stay in your home;
- avoid risks of homelessness;
- involve you in our decision-making process and improving our services; and
- ensure we are fair and transparent with all applicants.
The legal basis for using your data
We need a lawful reason to use your information. The majority of your personal information we process will be processed on one of the following conditions:
- The processing is necessary to take steps towards or for the performance of a contract with you. If you have applied for a home or we have an agreement with you, we will process your personal information to fulfil that agreement (that is, to provide our services to you). If you do not provide the personal information we need for these purposes, we may not be able to fulfil our agreement with you, i.e. carry out our services;
- The processing is required by law;
- We have legitimate interests to process your personal data, as explained further below; or you have consented for us to process your data, for example to keep you updated or involved in BCT’s work.
We will process special category information to ensure that there are no risks posed to you or your household. This could include processing for the purposes of:
- Health information – to ensure your home has any necessary adaptations so that you can live without further risks to your wellbeing.
- Information on your religion, ethnic origin and sexual orientation – to monitor diversity and equality of treatment of customers.
- Data regarding criminal convictions and offences, for safeguarding purposes and/or to meet our legal obligations.
We process special category data where we have a duty under social security and social protection law, where you have given us your explicit consent to do so, and in some cases to protect your vital interests.
We process criminal convictions and offences data to fulfil our obligations in connection with social security and protection law, and where there is a substantial public interest to prevent or detect unlawful acts; for the safeguarding of children or vulnerable adults; or where you have given us your consent or the information is already in the public domain.
Legitimate interest is one of the legal bases on which we may process your personal information.
Taking into account your interests, rights and freedoms we believe on balance we have a legitimate basis to:
- Communicate with you to keep you updated on our service delivery; or to let you know about community engagement events.
- To offer you further support, including referrals to external agencies, to help you stay in your home.
- Carry out customer surveys with a third party to help us improve services to you.
- To identify and investigate possible fraud, corruptions and/or bribery.
- To engage with contractors when carrying out a planned maintenance programme of work.
- To trace former tenants, if we need to contact you if you still have arrears.
- To supply your details to utility companies when you move in and out of your home to ensure correct payment of utility bills.
- In our efforts to prevent homelessness by making local authority homelessness teams aware if you are in the process of being evicted.
Who we share your data with, and who we receive it from
We will share information across employees within BCT and our partner Karbon Homes to enable us to meet your needs to assess your application, manage your tenancy, offer appropriate support, and improve your customer experience. This would include:
- Our Neighbourhood Management Team including our Enforcement and intervention Officer and Welfare Support Officers.
- Our Community Engagement Team.
- Our Finance Team.
- The Income Collection Team at Karbon Homes.
- The Finance Team at Karbon Homes.
- The Repairs and Maintenance Team at Karbon Homes.
So that we can provide effective services to you we will be required to share and receive your information with/from external organisations and people:
- People you have authorised to act on your behalf.
- Your Local Authority to ensure your needs are fully met.
- Your previous landlord.
- Organisations such as the Department of Work and Pensions to verify housing costs and to ensure you receive the right amount of benefits.
- Tyne and Wear Homes from whom we receive your application.
- British Gas when you move in and leave the property to ensure continuation of utility supplies to your home and to ensure utility charges are directed to the correct individual.
- Third party contractors who carry out repairs and maintenance to your home.
- Any specialised support agencies you are involved with.
- Our solicitors to provide advice relating to your tenancy.
- When investigating complaints made by you and others.
- Voluntas and other agencies to carry out customer surveys on our behalf.
- Credit reference agencies if you are a former tenant in arrears.
- AllPay to process your payments to us.
- The relevant Court in any legal proceedings.
- Surveymonkey in order to carry out electronic surveys.
- Your Councillor or local Member of Parliament where they are representing you and your interests. (We won’t share your personal information with anyone who claims to represent you unless we’re satisfied that you have appointed them or they act in some recognised official capacity.)
- Third party IT providers that enable us to provide services to you.
In some cases we may have a duty to disclose your information to:
- other housing associations;
- our regulators and government departments such as the Department of Works and Pensions;
- fire services, health authorities or medical staff;
- utility services if you leave an unpaid bill when moving house; and
- the police and other law-enforcement agencies to perform their duties for the purpose of crime prevention or detection, if we have a legal obligation to do so or it is required by a Court Order.
Transferring Data outside of the European Economic Area (EEA).
We deal with many international organisations to help us manage your tenancy and provide services to you. These are primarily ICT systems: communications and storage providers.
We will try our best to ensure that your personal information is not transferred outside of the EEA, however, sometimes your information will be. Not all countries outside the EEA have data-protection laws that are similar to those in the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe;
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US;
- There is an alternative adequate safeguard in place for the processing;
- You have given us your consent for the transfer; or the transfer is otherwise necessary for a contract we have with you or on your behalf.
Deleting your data
We have a number of different time periods that we may keep your information for. These are based on the following criteria:
- How long you have been a customer and when your tenancy ends.
- How long it is reasonable to show we have met the obligations we have to you under your agreement with us.
- If there is a time period set by law.
- Any time period allowed for us to make or defend a legal claim.
- Any recommended time periods set by our regulators or professional bodies.
Automated decisions and profiling
We don’t use any automated decision-making or profiling in starting, managing or ending your tenancy.
- Job Applicants
For the purpose of your job application, we collect:
- Personal information
- Personal contact information
- We will also ask for criminal convictions and offences data, where applicable.
We require this data so that we can assess your suitability for the role, and check that you are eligible to work in the UK. You do not have to give us this information, but it may affect your application if you don’t.
We only collect the information we need to make a decision about hiring you as an employee.
We will also ask for your consent to collect information about
- Health and disability information
- Sensitive personal information
We use this information to review our recruitment processes to ensure they are fair to all candidates, and for equal opportunities monitoring. You do not have to give us this information. Not giving us the information will not affect your application. Information collected for equal opportunities monitoring purposes will be recorded anonymously.
If you receive a conditional offer of employment, we will request references and may then need to check your criminal record, qualifications or right to work in the UK to meet our legal obligations.
At application stage, all information we process will be that which is provided by you, in the form of the BCT application form, or via an agency in the form of a CV.
The application data you provide will be available to the BCT Office Team and the recruitment panel. Any sensitive personal information you provide will be anonymised by the BCT Office Team and stored securely.
The recruitment team will not have access to this data and it will not form any part of the selection process.
Carrying out checks of references, qualifications, right to work and criminal records will involve us sharing your personal data with third parties.
We will not transfer your job application data outside of the UK other than where set out above.
If you are unsuccessful at interview, we would like to store your application for a period of 12 months in case a similar vacancy arises. We will ask for your consent on the application form to do this.
If you are successful, we will retain your application form during your employment and use some of the personal data you have provided to start the process of setting you up as an employee.
There are no automated decisions used in the recruitment and selection process at BCT.
- CCTV cameras
We use CCTV around the Byker Estate and inside the BCT Offices to:
- To prevent, investigate and detect crime, and to identify and prosecute offenders.
- To protect our staff and the public
- To maintain the security of our buildings.
We do this under our duties as an employer to protect our staff, and our duties as a landlord to provide safe accommodation for our tenants, and so use CCTV on the lawful basis of these legitimate interests.
Images from the CCTV cameras in the BCT offices are recorded and are available for review by the BCT Office team.
Images from our CCTV cameras around the Byker Estate are monitored and recorded by our service provider G&A Security.
In both cases the images are kept for a limited period of time (3 months or less). In cases of suspected crime or disorder, images may be kept for longer periods to aid any investigation and prosecution.
You can request the images that we hold of you under your rights to access personal data.
- Website Visitors
When you visit our website, the following information may be collected by our systems:
- your IP address;
- which browser you use;
- how you use our website (e.g. pages you have viewed); and
- information about your device (e.g. geographical location).
We collect this information in a way which does not identify you. We will not associate any data gathered from this site with any personally identifying information from any source, but we may use statistics from anonymised data, or other website analytics functions.
If we do want to collect personally identifiable information through our web site, we will be up front about this. We will make it clear when we are collecting personal information and will explain what we intend to do with it.
Our legal basis for processing this data is our legitimate interest in improving our website and user experience. We have balanced this against your rights as a data subject.
- Call Recordings
Calls made or received by BCT and its data processors may be recorded. This is done to provide an exact record of a telephone conversations in order to:
- Help identify colleague training needs, improve performance and the customer experience;
- Help protect colleagues from abusive or nuisance calls;
- Provide assurance of the quality standards and policy adherence;
- Support call levelling sessions and individual feedback;
- Ensure that BCT and its data processors comply with regulatory procedures and to provide evidence in the event of a dispute or complaint;
- Ascertain and demonstrate that calls are accurately transcribed onto the case management system;
- Be used as evidence in the event that a colleagues conduct is deemed unacceptable;
- Demonstrate transparency; and
- Prevent or detect crime or safeguarding requirements.
- The existence of each of data subject’s rights
Data Protection law gives you greater control over how we use your information.
You have the following rights:
Right of access
You have the right to request details about how we use your data and to be provided with a copy of that data.
Right to Rectification
You have the right to have inaccurate data corrected.
Right to Erasure
You have the right to have certain information about you deleted.
Right to Restriction
You have the right to request us to limit the use of your personal information in certain circumstances.
Right to Object
You have the right to object to us using your information in certain circumstances. You have an absolute right to stop your data being used for direct marketing.
Right to Data Portability
You have the right to request certain types of information to be provided to you or transferred to a third party in an electronic, machine-readable format.
Right to Withdraw Consent
If we have asked for your consent to process some of your personal information, you have the right to withdraw this at any time. We will never ask for consent to provide a service to you or if you would be disadvantaged if you did not want to consent.
Automated Decision Making
We currently do not make any decisions relating to you in a solely automated fashion i.e. without any human involvement. If we do we will tell you and you will have the right to request us not to unless it is strictly required for a contract, or required by law. You will have been given a simple method to challenge results of automated decisions.
- Making a request
These rights allow you to make requests of us and these can be verbally, electronically (phone or email), or on paper.
When you make a request we need to be sure that it is you applying. We may ask you to provide 2 forms of identification if we have any doubts about the person making the request. We may also need to ask for further details on the information you require or in regards to the request you are making.
We will respond to you within one month of receiving a verified request, and we may charge a fee if the request is complex.
In some cases, we may not be able to comply with a request if it prevents us from carrying out our responsibilities under law. We will let you know if this is the case and the reasons why.
- Email: firstname.lastname@example.org.
- Address: 17 Raby Cross, Byker, Newcastle upon Tyne, NE6 2FF
- Telephone: 0191 223 8797
- How to complain if you’re not happy about how we handle your data
If you wish to raise a complaint on how we have handled your personal data, you can contact us on: email@example.com.
If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law you can make a complaint to the Information Commissioner’s Office (ICO). Our registration number with the ICO is Z3316071
You can contact the ICO at:
Information Commissioner’s Office,
Wycliffe House, Water Lane,
Call 0303 123 1113
Visit the Information Commission website at www.ico.org.uk
- Changes to this privacy notice
Version Updated version effective from 1.0 25.05.18 2.0 09.04.19 3.0 28.01.20