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Melin Homes – COVID-19 Privacy Policy
This policy describes how Melin Homes may handle your data in relation to the current Covid‐19 public health crisis.
If you have any questions in relation to this document or how we use your personal data they should be sent to Melin’s Data Protection Officer. Contact details are in the main Privacy Policy.
This privacy information applies to Melin’s residents.
Melin Homes may collect, store, or disclose information in relation to the Covid‐19 epidemic for the following purposes:
- Safeguarding the health and safety of our residents;
- Providing care and support to our tenants who may need it;
- Safeguarding the most vulnerable among us and helping everybody comply with the government guidelines in the current context;
- To provide support to vulnerable residents who are shielding for their own protection, or the protection of a member of their household or someone they provide care for;
- To ensure that social distancing is maintained, and unnecessary contact avoided;
- Profiling, modelling and analysis that helps us to manage our services.
In order to fulfil the above purposes we may need to process information about your health status and special arrangements for managing urgent repairs or essential servicing.
The information below illustrates how we use the information we collect in relation to Covid 19 including the lawful grounds for processing and retention guidelines.
Relates to
Residents for whom we have a duty of care.
Purpose
- Monitoring the health of residents.
- Referrals to support systems where there is a need for social care.
Legal basis
Article 9.2(h) GDPR: Health and Social Care.
Retention period
When government advice that the medical risks have been eliminated. No later than two months following a government announcement to the end of the pandemic.
Consent
It is not our intention to base processing of personal data or special category personal data on consent. There are other lawful bases on which we can rely.
You have the right to object to our processing of your personal data for Covid 19 purposes. If you wish to object please let us know.
Sharing or Disclosing information
We may share data with the following categories of recipients in line with the purposes and lawful bases for processing outlined above:
- Our contractors and other organisations we may ask to visit our premises
- Other support providers that we recommend and that you agree to be referred to.
Profiling
We may undertake basic profiling to build up a picture of the demand for Covid-19 related support among our residents.
For more information on your rights, or the other ways we process your data, please refer to our Privacy Policy below.
Your privacy is hugely important to us here at Melin Homes. We want you to be confident that the information you give us when using our website or any of our services is safe and secure. In this Privacy Policy we'll explain how we use it.
We'll also tell you how and why we collect your personal info, your rights and choices when it comes to these details, as well as the steps we take to keep it secure and confidential.
Our Data Protection Officer is Melin’s Research & Development Manager. If you have any queries relating to our use of your personal information or any other related data protection questions, please contact us. Email dpo@melinhomes.co.uk or telephone 01495 745910, or you can write to us at Melin Homes Ltd, Ty'r Efail, Lower Mill Field, Pontypool, NP4 0XJ.
Melin’s servers are based in the UK. Most of our processors are based in the UK or European Economic Area (EEA); we only use processors outside of the EEA where there are adequate safeguards in place, such as the US-EU Privacy Shield, approved standard clauses, or binding corporate rules.
Purposes and legal basis for processing
1. Newsletter
We collect your email address when you register to receive our newsletter. We use this to send you our newsletter. This is usually 3 times a year, but sometimes we may send a special edition when we have something really important to share with you. This doesn't happen very often but If we decide to change the frequency of this then we will tell you. We have a legitimate interest in keeping you informed about the services we offer.
2. Application for a home with us
We will ask for information about your name, address, national insurance number and date of birth so that we can confirm your identity. We need to do this to comply with our legal obligations and in order to enter into a contract (rental agreement) with you. We may ask to take a photograph so that we can be sure of your identity when we deal with you in future. We will ask you for information about other people in your household so that we can make sure that any home we offer will be suitable for your needs. We will collect information about your finances so that we can establish that your home will be affordable for you, and will not lead to under- or over-crowding. We will also ask for your permission to provide your name to the company that supplies water, gas, electricity or any other utility to the property so that we can ensure that billing is properly set up. You don’t have to tell us about any health conditions you have, or that any member of your household has. However, if you do this will help us to make sure that we consider how suitable a property is to meet your needs. We may also gather additional information so that we can offer you additional help, or recommend other services to you. When we do this we will explain what information we want, why we want it and what we will do with it. If we need your consent we will collect it at that time and remind you of your data protection rights.
Once you are a tenant of ours we may need to share your contact information – typically name, address and phone number – with external contractors to enable us to carry out repairs or improvements on your home/our property. Our Contractors page shows the main developers, contractors and service providers that we share information with. If you want to know how they process your information, you can find out by looking at their Privacy Notice. Privacy notices can usually be found on the organisation’s website. If you are unable to find it there you may wish to contact them by telephone; you can find details on our Contractors page. Some of these organisations will also share your information with sub-contractors or specialist suppliers depending on the nature of the repair, defect or improvement to be addressed. Please be aware that we do not take responsibility for such websites, which may have different privacy and security policies and procedures to us.
3. Employment service
This is our initiative to help our residents get into employment. With your consent, if you want to use this service we will use the contact information we already have about you. We will ask you about any barriers to employment that you face. You don’t have to tell us about these, but if you do it will enable us to tailor the service to your needs.
4. Homebuy affordable home ownership options
We need to collect certain personal and financial information from you in order to enter into a contract to help you buy a home through us.
5. Y Prentis
In order to enter into a contract of employment with you we will need to collect personal information about you, including your bank details and qualifications. We may carry out pre-employment checks (references).
6. Care & Repair services
We use the personal information you give when you contact Care & Repair to check your eligibility for various grants and services. Often your name, address, phone number and the nature of any disabilities is provided to us by a third party, such as a hospital or social services Occupational Therapist, so that we can fit an adaptation to your home. We use your personal information to organise the installation that they recommend. We process your information to achieve our legitimate business interest.
7. Applying for a job with Melin Homes
When you apply for a job with Melin Homes we will collect personal information to maintain contact with you and in order to enter into a contract of employment with you. We will also collect information about your skills, qualifications and employment history and details of referees.
8. Photographs at public events
We often use photographs to share news about an event, or to publicise future events. Images may be used in press releases, printed publicity and published on Melin Homes’ website. They will be stored securely, and we will delete them after they are no longer needed for publicity purposes. We will not use your image in this way without first asking for your consent. At large events we will display notices warning that photographs are being taken in the area, and who to speak to if you or your child prefer not to be photographed.
9. Telephone calls
When you speak with us by telephone, the call may be recorded for training and monitoring purposes.
10. CCTV
We operate CCTV recording at our offices and some of our schemes. Prominent notices will inform you about the existence of CCTV cameras.
11. 100 Voices
Your experiences and views matter to us. If you agree to join our 100 Voices group we will collect your name, age range, address, phone number and email address so that we can send you surveys in order to improve our services.
Legitimate interests pursued by Melin
1. Newsletters and marketing
Our newsletters contain information about Melin and the services we offer that we believe will be of interest to you. If you are a resident or a shareholder of Melin Homes there is a relevant and appropriate relationship between you and us, so the legal basis for processing your personal data is ‘legitimate interest’. If you would prefer not to receive Melin newsletters you may object to this type of processing. We will not share your personal data with any other marketing organisation.
2. Application for a home with us
Processing is necessary for the performance of, or setting up of, a contract (Rental Agreement) between you and Melin Homes.
3. Employment service
Engaging with this scheme is entirely voluntary and if you choose to use this service it will be based on your consent.
4. Homebuy affordable home ownership options
Processing is necessary for the performance of, or setting up of, a contract (house purchase) between you and Melin Homes.
5. Y Prentis
Processing is necessary for the performance of, or setting up of, a contract (of employment) between you and Y Prentis.
6. Care & Repair services
We use the personal information you give when you contact Care & Repair to check your eligibility for various grants and services. Often your name, address, phone number and the nature of any disabilities is provided to us by a third party, such as a hospital or social services Occupational Therapist, so that we can fit an adaptation to your home. We use your personal information to organise the installation that they recommend.
7. Applying for a job with Melin Homes
Processing is necessary for the performance of, or setting up of, a contract (employment) between you and Melin Homes. We may also ask if you would like us to keep your email address to notify you of new jobs as they become available.
8. Photographs at public events
We use photographs to showcase the ways that we support local communities.
9. Telephone calls
Calls may be recorded for training and monitoring purposes.
10. CCTV
Images are monitored and recorded for the purposes of crime prevention and public safety.
11. 100 Voices
Your views, experiences and opinions are used to inform and improve services.
Period of time that your data will be stored
1. Newsletters and marketing
We will store your contact information until you no longer wish to receive newsletters or communications from us.
2. Application for a home with us
We keep information relating to your tenancy for 7 years after the end of your tenancy. This may be longer if you owe us money when you leave.
3. Employment service
Once you are in sustainable employment we will continue to store your data for up to 18 months.
4. Homebuy affordable home ownership options
We will retain your data for as long as you have an interest in the property. Your financial verification documents will be deleted once the sale is concluded. When you no longer have an interest in the property we will dispose of your personal data after 7 years.
5. Y Prentis
We retain information about our employees for 7 years, from when your employment ceases. If you applied to work with us but did not become an employee we will keep your application for 2 years.
6. Care & Repair services
We keep information for 7 years.
7. Applying for a job with Melin Homes
Application forms, shortlists and interview notes are retained for one year. If you are an employee of Melin Homes employee related information will be kept for 7 years from when employment ceases.
8. Photographs at events
We store photographs for two years. If we would like to continue using a photograph beyond that time we will contact you again to ask if you agree to this. The images will be stored on servers located within the UK or European Economic Area (EEA).
9. Telephone calls
Recordings are stored for three months, or longer where needed in connection with proceedings.
10. CCTV
Recordings are stored for 60 days. For evidence purposes, until such time as the proceedings have been determined.
11. 100 Voices
We will continue to process your personal information until you tell as that you no longer wish to be involved in 100 Voices.
What if you don't give us information
1. Newsletters and marketing
We’d like to be able to tell you about Melin services but can only do this if we have your contact details.
2. Application for a home with us
If you do not provide the information we ask for we may not be able to offer you a tenancy agreement.
3. Employment service
Participation is voluntary, we will work with you to overcome barriers to getting into work. You may need to provide information to help us to help you.
4. Homebuy affordable home ownership options
We will not be able to enter into a contract with you.
5. Y Prentis
If you do not provide the information we ask for we may not be able to consider your application for an apprenticeship with us.
6. Care & Repair services
We might know about other services that you are eligible to receive. If you don’t provide information we may not be able to help you as much as we could.
7. Applying for a job with Melin Homes
If you do not provide the information we ask for we may not be able to consider your application for a job with us.
8. Photographs at events
You are not obliged to agree to us using your image and there will be no negative consequences if you prefer that we don’t.
9. Telephone calls
Recording is automatic.
10. CCTV
Recording is automatic.
11. 100 Voices
You won’t be able to take part in certain surveys but we will always welcome your feedback about the services we provide to you.
The existence of automated decision making, including profiling, as well as the anticipated consequences for the data subject
All our decision making includes human involvement and we do not carry out any automated decision-making (making a decision solely by automated means without any human involvement); or profiling (automated processing of personal data to evaluate certain things about an individual).
Special Categories of data
This may also be known as sensitive data. Special categories of data are those that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, or sex life or sexual orientation, or is genetic or biometric data used for the purpose of uniquely identifying an individual. We may ask you for health information to help us to make sure that we consider how suitable a property is to meet your needs. We may also ask for information from tenants or job applicants in order to monitor equality of opportunity. You are not required to provide this information if you prefer not to. Your decision not to provide this type of information will not be used against you. We will not use equality monitoring information to discriminate or make decisions about you.
On what grounds do we use the information?
The Welsh Government regulates social housing in Wales (The Welsh Ministers have general functions under section 75 of the Housing Associations Act 1985 (as amended)). Among their expectations is that we deliver high quality services – that means providing services that meet people’s needs and expectations.
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