privacy policy.

HIDE TOWER TENANT MANAGEMENT ORGANISATION

&

HIDE TOWER RESIDENTS ASSOCIATION

 

General Data Protection Regulation and Data Protection Act 2018

COMPLIANCE & PRIVACY POLICY

 

Hide Tower Tenant Management Organisation [HIDE TOWER TMO], and Hide Tower Residents Association [HIDE TOWER RA) will endeavour to safeguard the privacy of its tenants and lease holders.  

 

Information we collect

We will collect personal details appropriate to the service you require. In some areas, this may simply mean registering your name, address and email details. Other forms will require more information.

 

Please note that calls to the Office may be monitored or recorded.

 

How we use personal information

There are various reasons that we need to collect personal data. For example, we may need your contact details for correspondence purposes. Similarly, we may need information because of legal requirements. Subject to your agreement, we may contact you to let you know about new services, or get your feedback on how we're performing. In any event, we will only ever ask for information that is absolutely necessary and does not constitute an invasion of privacy.

 

Below is a list of categories of information the TMO/ RA is likely to collect. The list is not exhaustive but gives an idea of the sorts of information that constitutes personal data under the GDPR.

 

  • Name

  • date of birth

  • family name

  • gender

  • current and previous address

  • contact details

  • evening, daytime, mobile telephone numbers

  • email address

  • contact preference

  • preferred language

  • family relationships

  • marital status

  • agreement to store data on customer service database

  • citizenship

  • service identifier (eg. parking permit number)

  • service requests and their outcomes

Special Category data

The GDPR Special Category data covers:

 

  • racial or ethnic origin

  • political opinions

  • religious beliefs or other beliefs of a similar nature

  • trade union membership

  • physical or mental health or condition

  • sex life and sexual orientation

  • genetic data and biometric data

 

As a TMO/ RA, Hide Tower collects, holds and processes a considerable amount of information, including personal information about residents, people it provides services to, and other people. It does this to provide its services in the most effective and efficient way that it can.

 

The TMO/ RA recognises that it has a duty to people whose information it holds to treat that information responsibly, keep it safe and secure, and process it correctly and proportionately. This Fair Processing Notice broadly explains what information we collect, the purpose for processing, categories of personal information and who we may share it with.

 

To understand how your own personal information is processed you may need to refer to any personal communications you have received, check any privacy notices the TMO/ RA has provided, or contact the office directly.

 

How we collect your information

 

In order to fulfil our functions as a TMO/ RA, as well as pursue other lawful/ legitimate interests on behalf of our residents and service users we collect information about individuals in a number of ways, for example, by letter, email, face-to-face, telephone, forms, and through referrals made by third parties, and other key stakeholders acting jointly or on behalf of the TMO/ RA.

 

Purpose for processing your information

 

We may collect personal data about you which covers basic details such as name, address, telephone number, and date of birth. We also collect some sensitive information also known as special category data, such as health data, ethnicity or religious beliefs - but only where it is needed to provide a service, fulfil a legal obligation and/ or for monitoring equality of both for customers and employees. We will always explain to you why and how this information will be used. We will always demonstrate to you what our lawful basis is for processing this type of information and where appropriate seek your consent.

 

As described above we collect and process information about you, so that we can carry out our public task functions as a TMO/ RA and to deliver public services. This includes but is not limited to:

 

  • the provision of all commercial services including the administration and enforcement of parking regulations and restrictions

  • the provision of all non-commercial activities including refuse collections from residential properties

  • to prevent and detect fraud or crime and prosecution offenders including the use of CCTV

  • managing our property

  • maintaining our own accounts and records

  • supporting and managing our employees

  • promoting the services we provide

  • carrying out surveys

  • internal financial support and corporate functions

  • managing archived records for historical and research reasons

  • corporate administration and all activities we are required to carry out as a data controller and public authority

 

We collect and process the following categories of personal information:

 

  • personal and family details

  • lifestyle and social circumstances

  • goods and services

  • financial details

  • employment and education details

  • housing needs

  • visual images, personal appearance and behaviour

  • licenses or permits held

 

The TMO/ RA's commitments under the GDPR and UK Data Protection Act 2018

The TMO/ RA's commitment will be to ensure that the data is:

 

  • processed lawfully, fairly and in a transparent manner

  • collected for a specific and legitimate purpose - it will not be used for anything other than this stated purpose

  • relevant and limited to whatever the requirements are for which they are processed

  • accurate, and where necessary, kept up to date.  Any identified inaccuracies will be amended or removed without undue delay

  • stored for as long as required, as specified on our records retention policy

  • secured with appropriate solutions, which protect the data against unauthorised or unlawful processing and against accidental loss, destruction or damage

 

The TMO/ RA will demonstrate its compliance with these principles.

 

How we may share your information

We will sometimes need to share information between The TMO/ RA and Westminster City Council departments, services and elected Members, as well as other organisations such as our partners, third party contractors, government bodies, the police, health and social care organisations, housing associations, landlords and educational establishments.

 

We will only share information where it is appropriate and legal to do so.  We may also share information, for example, if there is a risk of serious harm or threat to life, for the prevention and detection of fraud or crime, assessment of any tax or duty or if we are required to do so by any court or law.  Where this is necessary, we are required to comply with all aspects of the data protection laws.

 

Details for transfers

It may sometimes be necessary to transfer personal information overseas. When this is needed, information may be transferred to countries or territories around the world. Any transfers made will be in full compliance with all aspects of the UK Data Protection Act 2018

 

How long we keep your information

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

We may also anonymise some personal data you provide to us to ensure that you cannot be identified and use this data to allow the TMO/ RA to effectively target and plan the provision of services.

 

Your rights and access to your information

You have the right to request a copy of the information that we hold about you.

 

The new UK Data Protection Act 2018 also gives you additional rights that refer to how the TMO/ RA holds and uses your information.

Consequently, under certain circumstances, by law you have the right to:

 

  • withdraw consent and the right to object and restrict further processing of your data; however, where legally enforceable this may affect service delivery to you.

  • request to have your data deleted where there is no compelling reason for its continued processing and provided that there are no legitimate grounds for retaining it.

  • request your data to be rectified if it is inaccurate or incomplete

  • have your data transferred or copied should you move to another authority

  • not be subject to automated decision-making including profiling

 

Changes in your personal circumstances

You must notify us immediately if there are any changes in your circumstances and personal details so we can maintain an accurate and up to date record of your information.

 

​If you have any concerns

You have a right to complain to us if you think we have not complied with our obligation for handling your personal information.