Customer Privacy Notice

Clanmil Housing Group is a not for profit housing association that owns and manages over 5,500 homes throughout Northern Ireland. We take the confidentiality and security of the information we hold about our customers and colleagues very seriously. This Privacy Notice explains how we use the personal information we collect.

Our privacy notice covers the following areas to explain our approach to Data Protection:

How we collect information about you

We collect information in a variety of ways, including:

  • When you apply for a home
  • When you sign a tenancy agreement
  • Through on-going contact with you during your tenancy
  • When you access services by logging onto our website
  • Recording calls to and from Clanmil Housing (not all calls to Clanmil are recorded.  Where they are, the caller will be made of this fact at the beginning of the call stating our reasons for doing so)
  • When customers terminate a tenancy
  • If a customer makes a complaint
  • When dealing with ASB cases
  • When providing money and benefits advice
  • CCTV images

When you apply to become a Clanmil tenant, we request and hold on file any references necessary to assess your application. This may include, but is not limited to, information from other landlords, the PSNI, the Probation Service, Support Services, Social Services, and Health Services.

Legal basis for processing

When you first apply for social housing (by application to the Northern Ireland Housing Executive), 'every applicant' will provide 'consent' which allows Registered Social Landlords to process personal data in connection with your application and any subsequent tenancy you take up. The processing of your personal data is also necessary for the 'Legitimate Interests' (of Clanmil) in managing your tenancy, and the legitimate interests of third parties with whom we may share data (and examples of these agencies are shown below). The legal basis for processing by Clanmil of personal data will be through contract, consent and legitimate purposes.

Who we collect information about

We collect personal information about customers.  This includes current, former and potential tenants, who live in our properties or access our support and other services, and could also include their family and people associated with them. Also, about anyone who makes a complaint or enquiry and visitors to our website and offices.

What type of personal information we collect

For examples of the type of personal data we collect  click here

How we use your information

We use the information we collect so that we can deliver our services to you. We use information to:

  • manage allocations and lettings
  • manage tenancies
  • receive rent and service charges
  • provide a repairs and maintenance service
  • offer welfare benefits advice
  • provide support services
  • provide additional services/assistance e.g. employability/digital inclusion
  • resolve ASB disputes
  • investigate complaints
  • engage with customers to get feedback on our services
  • target customers impacted by welfare reform
  • we use CCTV images at our housing schemes and offices to deter crime and maintain the health and safety of our tenants and employees
  • in printed publications - online (website, social media channels, internal intranet), audio visual material, promotional materials and marketing campaigns.

Sharing your information

We will not share your personal information without your consent, unless allowed by law.

Examples of organisations we may share your information with, where appropriate, are:

  • Contractors
  • Local Authorities
  • NIHE
  • Government Departments
  • Social services
  • PSNI
  • Probation Service
  • Other landlords
  • Utilities companies
  • Courts
  • HMRC
  • NIFRS
  • Support agencies
  • Health services
  • Media outlets (for the promotion of Clanmil's work)

We may share customers' personal information on a collective basis with other organisations to help us gain insights into our customer base, so we can target and deliver our services in a way that maximises benefits for you, our customers. Whenever we do this, we will ensure that your personal information is handled under strictly controlled conditions and in accordance with the requirements of the Data Protection Act. We will not transfer your personal data outside of the UK/EEA without your explicit consent.

Accessing your information

Under DPA 18 individuals can find out if we hold any personal information (including CCTV images of themselves) by making an 'access request'. If we do hold information about you we will tell you what this is and let you have a copy of it. You can also be provided with information about the processing i.e. the purposes of the processing, categories of data processed, data portability, retention periods, rectification, erasure and to restrict or object to processing.

If you wish to exercise any of your rights please complete an online request

Transferring personal data outside the UK/EEA

It is unlikely that we will transfer your personal details outside of the UK/EEA. Where any transfer is made outside of the UK/EEA, it will be in compliance with the conditions for transfer set out in DPA 18.

Retention of personal Data

Personal Data will be retained in line with Clanmil's Data Retention Schedule which is reviewed annually.  To see how long we keep personal data please click here

Visitors to our website

When you visit www.clanmil.org.uk we collect the following information: Name, Email address, Mobile number, Contact Group (e.g. Clanmil Tenant), IP Address.

Further information supplied by you in relation to online services such as home address, subscription preferences and information relating to online services may also be recorded in your user account. You can update your cookie preferences, change your contact details and subscription preferences or choose to delete your account at any time.

 The personal data we collect on our website will be used for the following purposes: 

  • Identify new or returning visitors
  • Allow you to create and maintain a user account
  • Email news and updates on your selected subscription topics using the email address you have provided
  • Provide SMS/text alerts or your selected alerts topics
  • Promote relevant information based on previous visits/ interactions on the site 
  • Improve information and services on the website in line with visitor feedback, search terms used, and topics and pages read 

Analytics

When you visit www.clanmil.org.uk we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out such things as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. 

Cookies (not the kind you eat)

To make our website easier to use, we sometimes place small text files on your device. These are used to deliver personalised marketing information and enhanced functionality to website visitors e.g. remembering if the visitor is new or returning to the site, promoting relevant information based on previous website visits & interactions etc. 

Security and performance

The Clanmil Housing website is subject to periodic security tests to ensure that it is maintained in line with best practice. Secure passwords are required to access the website which is hosted securely. A range of software security/ firewall measures are employed to check that traffic to the site is behaving as would be expected and to detect and reject website behaviour that appears suspicious or a potential security threat. This may involve the processing of visitor IP addresses. The purpose for implementing all of the above is to maintain and monitor the performance of our website and to constantly look to improve the site and the services it offers to our users. 

Changes to our Privacy Notice

We keep our privacy notice under regular review and will place any updates on this webpage. The Notice was last reviewed in November 2021.

 

Registration with the ICO

Clanmil is registered as a Data Controller with the Information Commissioners Office (ICO) and registration is renewed annually. The point of contact within Clanmil in relation to all data protection issues is:

Shirley Johnston
Data Protection Officer
Clanmil Housing
3 Waring Street
Belfast BT1 2DX

02890 876000

dpo@clanmil.org.uk

 

Making a complaint

If you have any concerns regarding the security of the data that Clanmil holds on you, you can raise the matter with Clanmil's Data Protection Officer above, however you can, if you wish, raise the matter directly with the Information Commissioner's Office. Contact 

The Information Commissioner's Office - Northern Ireland 
3rd Floor 
14 Cromac Place 
Belfast 
BT7 2JB 

028 9027 8757 or 0303 123 1114 

Email: ni@ico.org.uk