Privacy Notice: How we use your personal information
Who we are
emh group is a non-asset owning parent company, with two largely ring-fenced functional divisions: EMH Housing and Regeneration Limited, trading under the name emh homes, which is a Registered Provider regulated by the Regulator of Social Housing, and EMH Care and Support whose regulated activities fall within the remit of the Care Quality Commission.
Our Privacy Promise
- To keep your data safe and secure
- Treat any data concerns you may have as priority
What is the purpose of this notice
This privacy notice aims to give you information on how we collect and process your personal information through your use of this website. It makes you aware of how and why your personal information will be used, namely for the purposes of the performance of our contract with you as our customer, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation (EU) 2016/679 (‘the GDPR’), the Data Protection Act 2018, and any subsequent legislation.
This notice primarily covers how we use information relating to our customers, website visitors, and people who interact with or do business with us by using our website. In these cases, we will be the “data controller” for the purposes of data protection law.
What information we collect about you
We collect information when you register with us or express interest in any of the services we provide. Information about you may be passed on to us via local authority bodies as we are providing social housing/care and support. For further information please see our General Needs Privacy Notice which covers customers and tenants.
If you apply to work for us or you work for us the information we hold about you will have been provided by yourself. We also collect information about you from internal sources, such as your manager, and in some cases external sources, such as referees and government agencies like the Disclosure and Barring Service. For further information please see our Privacy Notice for job applicants and employees.
We also collect information from you if you act on behalf of anyone who receives care and support from us. For further information please see our Privacy Notice for service users.
When using our websites we collect four main types of information from visitors:
- Feedback (general questions and specific feedback on the website)
- Requests for information
- Survey responses
- Site usage information (from session cookies and log files)
We do not pass on any personal information you have given us to any other site. The system will record your email address and other information if volunteered to us by you, for example on the feedback forms. This will be treated as proprietary and confidential.
Purposes for which we use your personal information
We need all the categories of information in the list above (see what information we collect about you) primarily to allow us to perform our contract with you and to enable us to comply with our legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.
The situations in which we will process your personal information are listed below:
- To register you as a customer
- To perform our contract or service to you
- To manage our relationship with you, including notifying you about changes to our contract or services or asking you to provide us with feedback
- To administer and protect the organisation and this website
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We do not use automated decision making or profiling, however there may be occasions where inadvertently we identify special category information about you. For example, your ethnicity, religion, sexual orientation, or disability may be evident from:
- Photographs, or
- Video footage, or
- Face to face meetings, or
- Statements you provide to us, or
- Declaration of Interests or
- Social media.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How we use your information
Data protection law says that we are allowed to use personal information only if we have a proper reason to do so. The law says we must have one or more of these reasons:
- To fulfil a contract we have with you, or
- When it is our legal duty, or
- When it is in our legitimate interest, or
- When you consent to it
Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to such marketing at any time.
Sharing your information
Personal information we have on you is used to make sure the services we offer continue to be the most appropriate for you.
We will use your information to manage our relationship with you, for example keeping our records up to date and to enable us to assist in the coordination of support services.
We will also use your information to carry out the contractual obligations we have to our customers, for example arranging repairs, planned maintenance, surveys, and inspections to properties.
We will not normally share your information with anyone else. However, there a certain circumstances where we will be required to share your information with other organisations and will comply with Data Protection law when disclosing this information. Where it is required or necessary in accordance with Data Protection law, we may share information:
- To third parties under the provisions of Crime and Disorder Act
- To the Housing Benefits department
- In response to legislative or court orders
- To collection agencies and legal representatives for the purpose of collecting rents or other monies owed to us
- To regulatory authorities in response to formal requests
If information is requested from a third party not covered by the above, we will seek written consent from the customer.
How do we keep information secure
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
All personal information you provide to us is stored on our secure servers within the UK. However, there may be occasions where your information may need to be stored in or sent to companies, service providers, agents, subcontractors and regulatory authorities in countries outside of the European Economic Area (‘EEA’) which may not have the same level of security and protection as we have under UK legislation. If we have to do this, we will make sure that suitable security measures are in place.
We have put in place procedures to deal with any suspected data security breach and will notify you and the Information Commissioner’s Office of a suspected breach where we are legally required to do so.
How long we keep your information
We will keep your personal information for as long as you are a tenant, service user, and/or employee of emh group. After you stop being a tenant, service user, and/or employee, we may keep your data for up to 10 years for one of these reasons:
- To respond to any questions or complaints
- To show that we treated you fairly
- To maintain records according to rules that applies to us
We may keep your data for longer than 10 years if we cannot delete it for legal or regulatory reasons.
From time to time we would like to send you information about services of ours and other members of the group we feel may be of interest to you.
Despite your consent to receive marketing information, should you change your mind you have the right at any time to stop us using your information for marketing use by withdrawing your consent. Consent can be withdrawn by contacting us.
Access to and correction of the information we hold on you
You can find out if we hold any personal information about you by making a ‘subject access request’ under the GDPR. If we do hold information about you, we will:
- Give you a description of it
- Tell you why we are holding
- Tell you who it has been disclosed to, and
- Let you have a copy of the information in an intelligible form
You may also have the right for your personal information to be transmitted electronically to other organisations in certain circumstances.
You can access your personal information we hold by writing to us at this address:
- emh group, Quality & Standards Team, Memorial House, Stenson Road, Coalville, and Leicestershire, LE67 4JP
You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this. If you do, we will take reasonable steps to check its accuracy and correct it.
You may also have the right, in certain circumstances, to request that we delete your personal information, to block any further processing of your personal information, or to object to the processing of your personal information. There are some specific circumstances where these rights do not apply and we can refuse to deal with your request.
If we are processing your personal information based upon your consent (e.g. as part of our marketing or promotional activities or to make a voluntary referral to an external agency), you have the right to withdraw your consent at any time.
If you require any further information about your right to rectification, erasure, or restriction, or you object to processing or wish to withdraw your consent, please contact us (see How to contact us below).
We take any complaints we receive about the collection and use of personal information very seriously. We would encourage you to bring it to our attention if you think that our collection or use of information is unfair, misleading or inappropriate. You can make a complaint at any time by contacting us (see How to contact us below).
If you think our collection or use of personal information is unfair, misleading or inappropriate or if you have concerns about the security of your personal information, you also have the right to make a complaint to the Information Commissioner’s Office. You can contact the Information Commissioner’s Office at the following address:
- Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
How to contact us
- Email: email@example.com
- Post: Quality & Standards Team, emh group, Memorial House, Stenson Road, Coalville, Leicestershire, LE67 4JP.
- Tel: 01530 276000