Updated: September 2020
During the current COVID-19 pandemic, you may be asked to inform us if you or anyone else in your household are experiencing any symptoms associated with the Coronavirus (i.e. high temperature, or a persistent cough). This information will be temporarily recorded on your tenancy file with Teign Housing in the vital interests of our staff and repair operatives. This data will be reviewed regularly and will only be shared with relevant authorities or contractors working on behalf of Teign Housing/Templer HomeBuild if deemed necessary for us to fulfil our public duty to stop the spread of this virus and to keep everyone safe. Our staff will call ahead of your repair appointment to check that you are well and not in quarantine.
Please be aware that if you contact us to exercise your individual rights as a Data Subject as per the Data Protection Act 2018, we are only able to process requests for information digitally at present, due to staff working remotely. We will endeavour to respond to such requests within timeframe where possible, however we apologise in advance for any delays to this service during a busy time for our staff.
- How we use personal data
Templer HomeBuild is committed to providing all our stakeholders with the highest standards of privacy and data security, in accordance with the UK Data Protection Act 2018 and the ‘GDPR’. 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 Information Commissioners Office (ICO) under registration number: ZA449416.
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
We process information about our stakeholders for various business purposes. We will collect and process data about:
- Our customers
- Our employees
- 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 (for ID purposes)
- 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 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.
- Consent – where we have obtained your prior explicit consent (for ‘sensitive’ personal data)
- 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.
- Data Sharing
Templer HomeBuild may need to share customer data with trusted third-party processors and sub-contractors 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
- To sub-contract works to trusted partners
We will only share data when we have a lawful basis for doing so, and when we have assurances by way of a Data Sharing Agreement with the third party. We do not currently process or share personal data outside of the European Union or for marketing purposes.
- 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. All staff receive regular data protection training.
- 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.
A cookie is a small text file which is placed onto your computer or electronic device when you access our website. Such technologies can be used to track users’ actions and activities, and to store information about them. We use these cookies and/or similar technologies on this website. 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.
- Your personal data rights
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 (Exemptions apply)
- 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 (Exemptions apply)
- The Right to Erasure – 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 (exemptions apply).
- 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 (exemptions apply)
- 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 (Exemptions apply)
- 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:
Craig Manley – Data Protection Officer
Teign Housing, Millwood House, Collet Way, Newton Abbot, TQ12 4PH
or alternatively, email your request to email@example.com
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 (e.g. a valid driving license or passport). 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/
- Queries & Complaints
If 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) by contacting:
Tel: 0303 123 1113