Templer HomeBuild is committed to providing all our customers, employees and partners with the highest standards of privacy and data security, in accordance with the EU General Data Protection Regulations (GDPR), and the UK Data Protection Act 2018. Templer HomeBuild is a wholly-owned subsidiary company of Teign Housing.
This Policy explains how Templer HomeBuild uses personal information, and the ways in which we protect your privacy. Templer HomeBuild is registered as a ‘Data Processor’ on behalf of Teign Housing the ‘Data Controller’ with the data governing body the Information Commissioners Office (ICO) under registration number: ZA449416.
Data Protection Principles
The ‘GDPR’ and the Data Protection Act 2018 specifies six key principles to compliant data processing, which Templer HomeBuild will abide by. These principles state that data must be:
- Used lawfully, fairly and in a transparent way.
- Be collected only for valid purposes
- Be relevant to the purposes we have told you about
- Be kept only for as long as necessary
- Be kept securely
The data we process:
We process information about our stakeholders for various business purposes. We will collect and process data about:
- Our customers
- Other stakeholders, suppliers and contractors
When interacting with us, you will be asked to provide personal information in order for us to:
- Respond to your enquiry
- Raise repair orders
- Process your application for employment
- Deal with your complaint
As a subsidiary company of Teign Housing, Templer HomeBuild will have access to customer data through a secure interface with Teign Housing’s housing management system and data bases. The personal data that you are likely to be asked to provide to us will include (but not exclusively):
- Full name(s)
- Date of Birth
- Contact Details (such as telephone numbers and email addresses)
- Responses to Customer Satisfaction Surveys
- Cookies on our website
Our Lawful basis for Data Processing
Under Article 6 of the data protection legislation, we must only collect and process personal data if it satisfies certain lawful purposes. Our lawful basis for processing personal data is:
- To Satisfy the Performance of a Contract – Our customers have Tenancy Agreements with our parent company Teign Housing. Your Tenancy Agreement permits us to share your personal data with Teign Housing and with our sub-contractors for the purposes of providing an efficient repairs and maintenance service. We, alongside Teign Housing, have a contractual duty to ensure your home is safe and well maintained.
- Consent – if we require sensitive or special category data, or if we are using your personal information for a new purpose, we will always seek your explicit consent beforehand. This will be in the form of a tick-box that requires you to actively tick to agree to the data processing or requires a signature to confirm your consent.
- In our Legitimate Interests – We can process personal data if it is genuinely in the interests of Templer HomeBuild, Teign Housing and the Data Subject (you).
- Vital Interests – We can process and disclose personal data if it is in the interests of health and safety. For example, we may share personal data with the emergency services (ambulance, police, fire) if a customer is in immediate danger.
- Legal Purposes – Templer HomeBuild can disclose personal data if it is required by law. For example, if requested by the Police, if it’s needed for Court proceedings, or to share data with government agencies or the DBS service.
The Sharing of Personal Data
Occasionally, Templer HomeBuild may need to share customer personal data with a trusted third-party processor for a range of different purposes such as:
- To enforce your contract with Teign Housing and to inform you of any changes
- To process your application for a job vacancy
- To obtain feedback from you and provide ongoing customer service
- To deal with any complaints
- For regulatory and legal purposes
- For the security, health and safety of tenants and customers
- For the prevention of crime and antisocial behaviour
We will not share your personal data with any other third parties unless required by law or without your prior explicit consent. We do not process or disclose any personal data outside of the European Economic Area (EEA). We will always seek to obtain data sharing agreements or assurances from our third-party processors that they have suitable due diligence procedures in place to process your personal data securely.
The Protection and Retention of Personal Data
We will use appropriate technological & organisational measures to keep your information secure. Databases are password protected and we have security measures in place to prevent the loss, misuse or alteration of information under our control. There is a robust data breach reporting procedure in place and will notify any affected customers and the necessary regulatory body if we are legally required to do so in the event of any data breaches. These security measures may include the following examples:
- Access control passwords
- Secure servers
- Firewalls, antivirus and intrusion detection systems.
Personal customer data is processed and shared with Teign Housing via secure housing management and scheduling systems. Databases in our network are managed by Ian Williams ltd and are password protected and have security measures in place to prevent the loss, misuse or alteration of information under our control.
Your personal data will be securely held in accordance with our Data Retention Policy and industry best practise. This means that your data will not be stored for longer than is necessary, and we will make every effort to ensure the personal data we hold is kept accurate and relevant. Physical documents are kept to a minimum where possible but will be shredded and professionally disposed of when no longer needed.
Online Job Applications
Any personal information supplied via our website for the purpose of completing an online job application will be used solely for the purposes of assessing suitability for the role and for arranging any subsequent interviews. Some of this personal information may be shared with authorised third-party processors if required by law for DBS checks or for the purposes of progressing your application through obtaining references. By submitting a job application through this website, you accept the processing of this data as described above. Your details will be processed via the website by Ian Williams Ltd who manage the recruitment and selection of new Templer HomeBuild colleagues. Ian Williams have an established business relationship with Teign Housing and have all necessary data protection due diligence measures in place including a data sharing agreement, to keep your data safe.
Google Analytics & Cookies
When personal information is supplied via the website, we will ensure that it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol. This is designed to ensure that your information cannot be read as it travels over the Internet.
- How many times a user visits the website,
- which pages a user visits;
- traffic data;
- location data.
This information helps us to build a profile of our users. Some of this information may be aggregated or statistical, which means that we will not be able to identify you individually.
Calls to our Helpdesk
Please be aware that calls made to our contact centre helpdesk may be recorded for training and monitoring purposes. When contacting us, some personal information may be required for the purpose of processing an enquiry. Our helpdesk is managed on our behalf by Ian Williams Ltd.
The data protection legislation gives our customers and staff much greater choice, control and rights over how we handle personal sensitive data. We must offer total transparency around our data processing activities and must provide easy ways for our customers to control their personal information. These rights include:
- The Right to be Informed – We must offer total data transparency, and inform you by way of Privacy Notices, of the ways in which we are collecting and processing your personal data.
- The Right of Access – You can request to have access to the information that we hold about you, this is known as a Subject Access Request.
- The Right to Rectification – If you notice that any of your personal data that is inaccurate or incorrect, you can ask us to correct it and update our systems.
- The Right to Erasure – Also known as the ‘Right to be Forgotten’, you can request that we delete and remove certain information from our systems if it is no longer relevant, inaccurate, or if it is likely to cause you problems or distress.
- The Right to Restrict Processing – You can request that we stop processing certain data for a certain period, if you feel that the processing of this data is going to have negative implications on you.
- The Right to Data Portability – You can request that your personal data is collated and sent directly to a new Data Controller in an easily readable (and usually digital) format.
- The Right to Object – You can object to the processing of certain data if you feel that the processing is unnecessary or has potential to impact on your individual rights and freedoms.
- Rights around Automated Decision Making and Profiling – If we intend on using personal data for research, analysis or statistical work for the purposes of profiling, we must inform you and obtain your explicit consent beforehand, unless the data used is anonymised. You can withdraw consent to profiling projects that involves your personal data, or you can object to its processing in this way.
If you would like to exercise any of the above rights and have a justifiable reason for doing so, please make your request in writing to:
Data Protection Officer
Teign Housing, Millwood House, Collet Way, Newton Abbot, TQ12 4PH
or alternatively, email your request to firstname.lastname@example.org.
Please note that our parent company Teign Housing act as the Data Protection Officer on behalf of Templer HomeBuild, therefore any queries, complaints or requests regarding data protection will be managed by Teign Housing. We have up to one calendar month to respond to/process any requests for the above, and we will require proof of your identity before disclosing any personal information. We can refuse to comply with a data subject’s request if there is a legitimate or legal purpose for us to do so (i.e. the data is vital for us to sustain your tenancy).
You can view our parent companies’ Privacy Policies using the below links:
Teign Housing: http://www.teignhousing.co.uk/privacy-notice/
Ian Williams Ltd: https://www.ianwilliams.co.uk/privacy-notice/
This Policy was last updated on 12.09.2019
Queries & Complaints
If you have already contacted our Data Protection Officer and we have been unable to deal with your query, you have the right to contact the regulatory body for data governance The Information Commissioner’s Office (ICO) if you still have a complaint or query:
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
www.ico.org.uk Tel: 0303 123 1113