Use of Information and Privacy Notices
This privacy notice explains what information we collect, when we collect it and how we use it.
This Privacy Notice will provide you with information about your rights under the General Data Protection Regulation (EU) 2016/679 [GDPR] and the Data Protection Act 2018 [the Data Protection Legislation] and how to action these rights.
During our activities, we will process personal data (which may be held on paper, electronically, or otherwise) about you and we recognise the need to treat it in an appropriate and lawful manner. The purpose of this notice is to make you aware of how we will handle your information.
Who are we?
We are Blackwood Homes and Care, a Scottish Charity (Scottish Charity Number SC007658), a Registered Social Landlord (HEP158), and a registered society under the Co-operative and Community Benefit Societies Act 2014 (Registered Number SP1728RS), having our Registered Office at 160 Dundee Street, Edinburgh, EH11 1DQ.
We take the issue of security and data protection very seriously and strictly adhere to guidelines published in the General Data Protection Regulation (EU) 2016/679 [GDPR], the Data Protection Act 2018 and together with any domestic data protection laws subsequently enacted.
We process your data because we are required to do so in our performance of a public task, and in accordance with our legal obligation to do so – generally under the Anti-Social Behaviour Act etc. (Scotland) 2004, Housing (Scotland) Act 1988, Housing (Scotland) Act 2001, Housing (Scotland) Act 2010 and Housing (Scotland) Act 2014.
Blackwood is registered as a Data Controller with the Office of the Information Commissioner (registration number Z5644613). This means that we are responsible for ensuring that any personal data that you provide to us is protected.
Our Data Protection Officer is the Head of Business Assurance, who can be contacted at 0131 317 7227. Any questions relating to this notice and our privacy practices should be sent to the Head of Business Assurance at cst@blackwoodgroup.org.uk
Blackwood will not collect any information about individuals, except where it is specifically and knowingly provided by them. Examples of such information are:
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Your name
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Your telephone number
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Your email address
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Your occupation
The information collected will be used to send you the information you have requested and to provide information that may be useful to you. We will also analyse the information, we collect so that we can administer, support and improve the services we offer through improvement initiatives and projects such as Peoplehood. Blackwood maintains strict policies to avoid unsolicited correspondence We may share non personal numerical or non-numerical data to examine trends of our site’s visitors with partners or other parties. However, we do not sell or share any information about individual users.
Cookies
Blackwood employs "cookies" to provide a better service to its website users (Cookies are messages that web servers pass to your web browser when you visit Internet sites). We do not use cookies to store any personally identifying information from users except to identify a user who has chosen to log in to the site. We do not use cookies to track user activities beyond our web site.
Computer Profile Information
The Blackwood website automatically detects information relating to the display properties of your computer. This information is collected in order to help understand the ways through which people access the site. This could help us in the future to better support different platforms such as, for example, mobile telephones and other mobile devices).
Data Protection
Any information submitted to this site is used expressly for the use of Blackwood and the purposes for which you provide it. Blackwood will not pass your information to any other parties unless this is made clear to you.
The data protection principles set out how personal data should be managed:
1. Lawfulness, fairness and transparency
We need to be clear and upfront about what we use your data for.
2. Purpose limitation
We will only use your data for specific reasons which are set out in this guide.
3. Data minimisation
We will only collect data which is necessary for us to provide a service to you and will delete data when it becomes out of date.
4. Accuracy
We will ensure that any personal data we collect is correct and up to date.
5. Storage limitation
We will keep only what is necessary in line with our data retention schedule as set out in our Data Protection Policy.
6. Integrity and confidentiality
We will ensure we have appropriate security to protect the data we process about you.
What is Data?
Personal data
Means any identifiable information about a living person. This can include:
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Name
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Address
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Telephone number
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Date of birth
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Tenancy reference number
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National insurance number
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Special categories of personal data
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Are defined as personal data relating to a person’s:
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Racial or ethnic origin
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Political opinions
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Religious or other beliefs
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Trade Union membership
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Health
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Sex life or sexual orientation
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Genetic or biometric data used to uniquely identify a person
Blackwood Homes and Care is a controller of your personal data. This means that we decide the purpose and conditions of processing of your personal data.
Any supplier, contractor or other third party with whom we share data is called a processor.
What are the conditions of processing?
The conditions of processing are the legal reasons for processing your personal data. We have to make it very clear why we process your data. In processing your personal data or special category personal data, Blackwood Homes and Care will rely on one or more of the following conditions of processing, depending on what we are using your personal data for:
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Personal data
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Consent
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You have given your consent to the processing of your personal data.
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Contractual
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Processing of personal data is necessary for the performance of a contract with you or for Blackwood Homes and Care to take pre-contractual steps at your request.
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Legal obligation
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Processing of personal data is necessary for Blackwood Homes and Care to comply with a legal obligation.
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Vital interests
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Processing of personal data is necessary to protect your vital interests or another individual's vital interests (this means life or death situations).
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Public task
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Processing of personal data is necessary for the performance of a task carried out in the public interest or in the exercise of official authority conferred on Blackwood Homes and Care.
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Legitimate interests
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Processing is necessary for Blackwood Homes and Care’s legitimate interests or a third party's legitimate interests, unless these interests are overridden by your interests or fundamental rights.
Privacy Notices
You can read more about our Privacy Notices here –
Special categories of personal data
Explicit consent
You have given your explicit consent to the processing of your personal data.
Employment law
Processing is necessary for carrying out obligations under employment, social security or social protection law.
Vital interest
Processing is necessary to protect your vital interests of or another person's vital interests where the data subject is physically or legally incapable of giving consent.
Legal claims
Processing is necessary for the establishment, exercise or defence of legal claims.
Public interest
Processing is necessary for reasons of substantial public interest, under law.
Medical diagnosis and treatment
Processing is necessary for the purposes of the provision of health or social care or treatment or the management of health or social care systems.
Your rights
You have a number of rights under the Data Protection Legislation which are outlined and explained below.
The right to be informed of how your personal data is processed
This guide informs you how your data will be processed and sets out clearly Blackwood Homes and Care's lawful basis for processing.
The right to access your personal data
You can submit a Subject Access Request to access the personal data that Blackwood Homes and Care holds about you. You can do this by writing to:
Head of Business Assurance
Blackwood Homes and Care Housing Association
160 Dundee Street, Edinburgh, EH11 1DQ
Or emailing: cst@blackwoodgroup.org.uk
Blackwood Homes and Care will then have a calendar month to respond to your request. As part of the subject access request process we may ask for two forms of identification to be submitted before any information is released.
The right to rectification
If any of the personal data we hold about you is wrong, you have the right to ask us to correct it.
The right to erasure
You may request that Blackwood Homes and Care erase any of your personal data that is processed by us. This is also known as the ‘right to be forgotten’. Please note that this is subject to a number of exemptions and so is not an absolute right.
The right to restrict processing
If you believe that we are processing personal data unlawfully, where it is no longer needed or think that the personal data held is inaccurate you can ask us not to process that personal data.
The right to data portability
You can ask us to pass on the personal data we hold about you to a third party, where you have provided that personal data to us and we have been processing it to deliver a service to you.
The right to object
You have the right to object to our processing of your personal data. However, if Blackwood Homes and Care can demonstrate that there is an appropriate ‘condition of processing’ in place then we may refuse to stop processing your personal data.
Rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision solely based on automated processing. If a decision is made by an automated process you may ask Blackwood Homes and Care to have the decision investigated by a member of staff.
How to action your rights under the Data Protection Legislation
If you wish to object to the use of your personal data, would like to restrict processing or have data rectified, please contact cst@blackwoodgroup.org.uk
The right to complain to the ICO
If you have a concern about the way Blackwood Homes and Care is processing your personal data, you may raise a complaint with the Information Commissioner’s Office using the details below:
The Information Commissioner’s Office – Scotland
45 Melville Street, Edinburgh, EH3 7HL
Telephone: 0131 244 9001
Email: Scotland@ico.org.uk
Marketing
We will never share or sell your personal data to a third party for marketing purposes.
Security
Electronic information that contains personal information is kept in secure systems. Laptop computers and other devices which may be taken out of the office are encrypted and password protected. Any paper files containing personal information are stored in locked filing cabinets.
Policy Changes
Any changes to this policy will be posted here. If you have any questions, please contact us on cst@blackwoodgroup.org.uk.
Service Interruption
Blackwood shall have no liability to you for any interruption or delay in access to this site irrespective of the cause.
Credit Cards
Blackwood does not store your credit card details. We use a third party, Allpay, to collect and process payments. Allpay are fully Payment Card Industry Data Security Standard (PCI DSS) compliant and specialise in handling your online payments securely. We also use Call Pay for payments taken over the phone.