Privacy

We collect information about you:

• When you apply for housing with us, become a tenant, request services/repairs, enter into a factoring agreement with ourselves, or otherwise provide us with your personal details
• When you apply for housing through a Common Housing Register in an area that we operate
• When you apply to become a member
• From your use of our online services, whether to report any tenancy/factor related issues, make a complaint or otherwise
• From your arrangements to make payment to us (such as bank details, payment card numbers, employment details, benefit entitlement and any other income and expenditure related information)

We collect the following information:

About You:

• Title
• Name
• Date of Birth
• Gender
• Address
• Telephone numbers
• Email addresses
• Communication Preferences
• National Insurance Number
• Next of Kin
• Power of Attorney
• Household members

About Your Health and Support:

• Health/Medical Information
• Support information
• Information on Pregnancy

About Your Employment, Benefits and Finances:

• Bank details
• Payment card details
• Employment details
• Financial details – income, benefits, debts
• Details of benefits entitlements, claims and payments

Equalities, Diversity and Inclusion:

• Ethnicity
• Religion
• Language Preference
• Disability
• Sexual Orientation

Criminality, ASB and Offences:

• ASB
• Sex Offenders

Other:

• Domestic Abuse/Harassment
• Child Access Details
• Pet ownership
• Previous Address Details – including landlord/mortgage provider and reason for leaving
• Landlord References
• Homelessness
• Digital Inclusion
• Relationship to Cairn Board Members or Staff

We receive the following information from third parties:

• Benefits information. Including awards of Housing Benefit/Universal Credit
• Payments made by you to us
• Complaints or other communications regarding behaviour or other alleged breaches of the terms of your contract with us, including information obtained from Police Scotland
• Reports as to the conduct or condition of your tenancy, including references from previous tenancies, and complaints of anti-social behaviour
• Housing Application details from Common Housing Registers
• Reports from Local Authority partners – including Social Work and Occupational Therapists
• Reports from NHS/GPs

We need your information and will use you information:

• To undertake and perform our obligations and duties to you in accordance with the terms of our contract with you
• To enable us to supply you with the services and information which you have requested
• To enable us to respond to your repair request, housing application and complaints made
• To analyse the information we collect so that we can administer, support and improve and develop our business and the services we offer
• To contact you in order to send you details of any changes to our supplies which may affect you
• For all other purposes consistent with the proper performance of our operations and business, and
• To carry out our obligations around Tenant Participation and Engagement

We may use workflows to make automated decisions based on our published policies and procedures. These are designed to give quicker decisions to customers based on pre-defined criteria. Automated decisions and are not necessarily final and can be challenged.

The information you provide us will be treated as confidential [and will be processed only by our employees within the UK/EEA]. We may disclose your information to other third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:

• If we enter into a joint venture with or merge with another business entity, your information may be disclosed to our new business partners or owners
• If we instruct repair or maintenance works, your information may be disclosed to any contractor
• If we are investigating a complaint, information may be disclosed to Police Scotland, Local Authority departments, Scottish Fire & Rescue Service and others involved in any complaint, whether investigating the complaint or otherwise
• If we are investigating payments made or otherwise, your information may be disclosed to payment processors, Local Authority and the Department of Work & Pensions
• If we are conducting a survey of or products and/or services, your information may be disclosed to third parties assisting in the compilation and analysis of the survey results
• If we require to pursue debt through a debt collection agency
• If we require to engage the services of Lawyers/Solicitors in relation to tenancy or housing management matters

Unless required to do so by law we will not otherwise share, sell or distribute any of the information you provide us without your consent.

Where information is transferred outside the UK or EEA, we ensure that there are adequate safeguards in place to protect your information in accordance with this notice.

We review our data retention periods regularly and will only hold your personal data for as long as necessary for the relevant activity, or as set out in any relevant contract we have with you.

We will generally keep your information for the following minimum periods:

Application and Tenancy Records:	Retention Period:
Applications for accommodation	6 years after offer accepted
Housing benefit notifications	6 years after the date of termination of the tenancy
Rent statements	Permanently
Current tenants’ tenancy files, (including rent payment records and details of any complaints and harassment cases)	6 years after the date of termination of the tenancy
Documentation, correspondence and information provided by other agencies relating to special needs of current tenants	6 years after the date of termination of the tenancy
Records relating to offenders, ex-offenders and persons subject to cautions	6 years after the date of termination of the tenancy
Right to buy purchases	20 years after purchase

After which this will be destroyed if it is no longer required for the reasons it was obtained. Our full retention schedule is available at www.cairnha.com

A “cookie” is a piece of software that attaches to the hard drive of your computer and remembers information about the configuration of your computer. We may use this information to track your movements through our website, to find out how it is being used and to assess its usefulness. Personal information about you is not collected during the tracking process.

You can disable the cookies that we attach if your browser supports this. However, you should bear in mind that if you exercise this option, you may be unable to access certain parts of our site.

Because we want your experience of our Site to be as informative and useful as possible, we provide a number of links to websites operated by third parties (“Third Party Websites”). Please be aware that we do not control such Third Party Websites and that such Third Party Websites may send their own cookies to users, or otherwise collect data or solicit personal information. We assume no responsibility for the information gathering practices of Third Party Websites that you are able to access through our Site, and we encourage you to review each Third Party Website’s privacy policy before disclosing any personally identifiable information.

When you give us information, we take steps to make sure that your personal information is kept secure and safe:

• Paper records are kept in locked offices or cabinets
• Access Control and Password Protection
• Managed Firewalls
• Managed Antivirus/Anti-Malware
• Patch Management
• Device Management
• Encryption

We may amend this policy from time to time. If we make any substantial changes we will notify you by posting a prominent notice on the Site.

You have the right at any time to:

• Ask for a copy of the information about you held by us in our records
• Require us to correct any inaccuracies in your information
• Make a request to us to delete what personal data of you we hold and
• Object to receiving any marketing communications from us

If you would like to exercise any of your rights above, please contact us at enquiries@cairnha.com

You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information. The Information Commissioner’s contact details are noted below:

The Information Commissioner’s Office – Scotland

45 Melville Street, Edinburgh, EH3 7HL

Telephone: 0131 244 9001

Email: scotland@ico.org.uk

The accuracy of your information is important to us – please help us keep our records updated by informing us of any changes to your email address and other contact details.

If you have any queries concerning your personal information or any questions on our use of the information then please contact us at enquiries@cairnha.com or by sending us a letter to Bellevue House, 22 Hopetoun Street, Edinburgh EH7 4GH or by telephoning us on 0800 990 3405.