The main points
- We keep some information about you. We need it to look after your home.
- The law says we have to look after your information properly.
- We only share it when we have a reason to.
- You can ask to see what we keep about you. It is free.
- If you are not happy about how we use your information, you can tell us.
What information we keep
We keep some information about you. For example:
- your name and your date of birth
- your address
- your telephone number
- your tenancy agreement
- your rent account
- repairs you have told us about
- letters and emails between us
- notes about anything we have agreed with you
We also keep some information that is more private. For example:
- the help you need, so that we can do things in the right way for you
- any adjustments we have agreed, like sending letters in a bigger size
- information about your health, but only if we need it
- information about a safeguarding concern, if there has been one
We only keep what we need.
Why we keep it
We keep information about you so that we can:
- look after your home and do repairs
- keep you safe
- deal with your rent and your Housing Benefit
- answer your questions and deal with complaints
- do the things the law says a landlord must do
- make sure we treat you fairly
We do not use your information to sell you anything.
Who we share it with
Sometimes we have to share your information with other people. We only do this when we have a reason.
We may share information with:
- your support provider, so they can help you and so we can work together about your home
- workers who come to do a repair, so they know where to come and what to do
- the council, about your Housing Benefit
- the council or the police, if we are worried that someone is being hurt
- a solicitor or a court, if there is a legal matter
- the Housing Ombudsman, if you make a complaint to them
If someone else wants to speak to us on your behalf — like a relative or a friend — we will usually need you to tell us that first. This is to keep your information safe. Your support worker can help you do this.
When we might share without asking you
Most of the time we would ask you first, or you would already know.
There are sometimes when we may have to share information without asking you. For example:
- if we are worried that you or someone else is being hurt or is in danger
- if the law says we must
- if a court tells us to
Section 12 explains more about what happens if we are worried someone is being hurt.
We will always try to tell you what we have done and why, unless telling you would put someone in danger.
Keeping your information safe
We keep your information safe. For example:
- we keep paper files locked away
- our computer systems have passwords
- only staff who need to see your information can see it
- we train our staff about looking after information
If something ever went wrong and your information was lost or seen by the wrong person, we would investigate it. If it was serious, we would tell you, and we would tell the Information Commissioner's Office.
How long we keep it
We do not keep your information for ever.
We keep it for as long as we need it, and for a while after your tenancy ends. Then we destroy it safely.
We have a policy that says how long we keep each kind of information. You can ask us for a copy.
CCTV
Some Harbour Light homes have CCTV cameras outside or in shared corridors. There are no cameras anywhere else in the home.
We only use the recordings to keep people and buildings safe.
Your rights
The law gives you rights about your information. You can:
- ask to see the information we keep about you
- ask us to correct it, if something is wrong
- ask us to delete it, in some cases
- ask us to stop using it in a certain way, in some cases
- complain if you are not happy
Asking to see your information is free. It is sometimes called a subject access request, but you do not have to use those words.
How to ask to see your information
- Tell us that you want to see the information we keep about you.
- Tell us in whatever way is easiest — telephone, email, letter, or in person.
- Your support worker, a relative, a friend or an advocate can ask for you, if you have told us that is OK.
- We may need to check who you are, to keep your information safe.
- We will reply within one month. If your request is complicated, we may need longer. If that happens, we will tell you.
- There is no charge.
Ask us by email at hello@harbourlight.org.uk, or ask your support worker to help you.
If you are not happy
If you are not happy with how we have used your information, please tell us first. We will look into it. Section 14 explains how to complain.
You can also complain to the Information Commissioner's Office. They are the organisation that makes sure everybody follows the rules about information. You can go to them yourself. You do not need our permission.
Information Commissioner's Office Telephone: 0303 123 1113 Website: ico.org.uk/make-a-complaint Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Your support provider keeps information too
Your support provider is a different organisation from Harbour Light. Section 2 explains this.
They keep their own information about you, about your care and support. They have their own rules about it.
If you want to see what your support provider keeps about you, ask them. We cannot show you their records, and they cannot show you ours.
Getting help to understand this
If any of this is hard to understand, that is OK. Ask your support worker. You can also ask a relative, a friend or an advocate to help you.
You can ask us for this information on paper, in a bigger size, or in another format. Just ask us or ask your support worker.
More detail
This box is for tenants who want more detail, and for support staff, relatives, advocates and social workers. You do not need to read it to understand the section above.
Legal framework. Harbour Light processes personal data as a controller under the UK General Data Protection Regulation and the Data Protection Act 2018.
This section is not a privacy notice. This section is a plain-English summary. It is not Harbour Light's full privacy notice under Articles 13 and 14 of the UK GDPR.
Lawful bases. Harbour Light relies on performance of the tenancy contract (Article 6(1)(b)); compliance with legal obligations, such as gas and electrical safety and Awaab's Law (Article 6(1)(c)); legitimate interests for certain management activity (Article 6(1)(f)); and vital interests in an emergency (Article 6(1)(d)). For health and other special category data, it relies on Article 9(2)(g) (substantial public interest) with the relevant condition in Schedule 1 to the Data Protection Act 2018, including the safeguarding of individuals at risk.
Sharing with support providers. Harbour Light and each support provider are separate controllers. They share personal data where this is needed to manage the tenancy and the support arrangement, and to keep people safe.
Subject access. The response deadline is one month from receipt, extendable by up to two further months where the request is complex or numerous, provided the data subject is informed within the first month. No fee may be charged unless the request is manifestly unfounded or excessive. Requests made on a tenant's behalf require evidence of authority; where a tenant lacks capacity, a deputy or attorney with the relevant authority may make the request, and this needs to be handled carefully for this tenant group.
Capacity and consent. Consent under the UK GDPR must be freely given, specific, informed and unambiguous, and capable of being withdrawn. Where a tenant may lack capacity to consent, Harbour Light relies on another lawful basis, such as contract, legal obligation or substantial public interest, rather than consent.
Retention. Harbour Light's Data and Document Retention and Disposal Policy sets out how long each kind of record is kept. A copy is available on request.
Personal data breaches. A breach must be notified to the Information Commissioner's Office within 72 hours of becoming aware, where there is a risk to the rights and freedoms of individuals, and to the affected individuals without undue delay where the risk is high.
Registration and Data Protection Officer. Harbour Light is registered with the Information Commissioner's Office (registration number ZA206750). Its Data Protection Manager is the Chief Executive.
CCTV. A few Harbour Light properties have CCTV covering external areas or internal corridors only. It does not cover any other part of the home. CCTV is operated under Harbour Light's CCTV Policy (IDG03), jointly with the relevant support provider.