Thurles Lions Trust Housing Association CLG is committed to protecting your privacy and complying with the General Data Protection Regulations 2018. This Privacy Notice sets out the basis by which we collect, use and disclose the personal data of our tenants and employees / volunteers, as well as your rights in respect of such personal data.
How we collect information about you
We collect and process data for a variety of purposes which largely relates to the tenancy relationship that we undertake, the supports we provide and also for the day to day administration and staffing of the association.
Some examples of where our association may collect, handle, manage, store and/or process data includes:
- Assessing individuals for prospective tenancy with the association
- Assessing and processing a tenant’s rent in accordance with the association’s rent policy or other such rent policy as the association may be obliged to apply
- Performing accounting, rent arrears management and other record-keeping functions
- Applications for employment / volunteering opportunities with the association
- Providing HR, payroll and pension administration services, if applicable.
- Providing volunteer administration and working with and supporting community employment schemes, projects and initiatives
- Monitoring and improving our service delivery by undertaking tenant surveys or research
- Delivery of care supports and mental health supports and services
- Delivery of outreach tenancy support services and community-based initiatives
- Undertaking criminal record vetting checks in particular for Employees, volunteers and applicant tenants
- Providing general information, updates, public relations and advocacy of the association’s activities
- Complying with our legal, regulatory, funding and contractual obligations, in particular, our obligations under capital funding schemes from which our properties are financed and our obligations in respect of compliance with the requirements of the operational grant funding received from both the Health Service Executive and Tipperary County Council.
- Planning for the future delivery of services to meet the on-going needs of our tenants and clients
Examples of data that may be collected/processed in the above procedures include:
- Marital status
- Address and previous addresses
- Contact details (email, phone)
- PPS number
- Income details
- Employment status
- Medical / Disability information
- Information on next of kin
- Criminal convictions
- CCTV images
- Images (photos or film) taken at publicity events
Lawful basis for processing
Lawful grounds for processing personal data, as set out in Article 6 of the GDPR will be applied to each data set (as set out above), as applicable. The lawful grounds are as follows and at least one will be applied to each data set:
- the consent of the individual;
- performance of a contract;
- compliance with a legal obligation;
- necessary to protect the vital interests of a person;
- necessary for the performance of a task carried out in the public interest;
- legitimate interests of company/organisation (except where those interests are overridden by the interests or rights and freedoms of the data subject).
Data Processing means performing any operation or set of operations on personal data, including:
- obtaining, recording or keeping data;
- organising or altering the data;
- retrieving, consulting or using the data;
- disclosing the data to a third party (including publication); and
- erasing or destroying the data.
Who we collect information on
We collect personal information about:
Tenants (current, former and potential tenants) and staff / volunteers (current, former and potential staff / volunteers).
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
- manage rent arrears
- provide a repairs and maintenance service
- provide support services
- provision of additional services/assistance e.g. employability/digital inclusion
- resolve disputes
- investigate complaints
- Recruit and employ staff / volunteers
- Provide HR, payroll and pension administration services
- CCTV Images – we use CCTV images at our housing schemes and offices to deter crime and maintain the health and safety of our tenants and employees
- Publications and eBulletins – we will, on occasions, send you general information about the association’s work, relevant news and upcoming events.
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 (for repairs, maintenance)
- Local Authorities
- Govt. Departments
- Utilities companies
- Support agencies
- Health services
Whenever we share your information, we will ensure that your personal information is handled under strictly controlled conditions and in accordance with the requirements of the GDPR. We will not transfer your personal data outside of the EEA without your explicit consent.
Accessing your information
Under the General Data Protection Regulations 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. Under GDPR, you have the right to:
- Information about how and why your personal data is being processed, how long it will be retained for and the right to obtain access to that personal data.
- Have your access requests processed within 30 days of the request.
- Receive this information free of charge
- Have information corrected if it is inaccurate or incomplete
- Request the deletion or removal of personal data where there is no longer a reason for the continued processing / storage of data and where consent is withdrawn
- Restrict your personal data being processed further than was originally consented to
- Object to direct marketing and scientific, historical or statistical processing
- Lodge a complaint with the Data Protection Commissioner
If you wish to make an access request, please do so in writing (this can include email, text, social media contact) and we will respond to you in accordance with the above-mentioned rights.
Retention of Personal Data
Personal Data will be retained in line with the Association’s Data Retention Policy. If you wish to request a copy of this policy please do so in writing.
Data Protection Contact Person in Thurles Lions Trust Housing Association CLG
The Data Protection contact person for Thurles Lions Trust Housing Association CLG for all queries and subject access requests is John McCormack Email: firstname.lastname@example.org M: 087-2408035 Address: Matthew Bourke House, Gortataggart, Templemore Road, Thurles, Co. Tipperary
Making a Complaint
If you have any concerns regarding the security of the data that this association holds on you, you can raise the matter with the relevant staff member as named above, however you can, if you wish, raise the matter directly with the Data Protection Commissioner; contact details as follows:
Telephone: +353 57 8684800 / 1890 252 231
Postal Address: Data Protection Commissioner, Canal House, Station Road, Portarlington, R32 AP23 Co. Laois
This Notice was last reviewed in August 2018.