Handling Personal Data
CityWest Homes Ltd (CWH) handles personal information in compliance with Data Protection legislation and General Data Protection Regulations (GDPR). We recognise the importance of the correct and lawful processing of personal data in maintaining confidence in our operations. We fully endorse and adhere to the principles set out in legislation.
As a provider of services for Westminster City Council (WCC), CWH 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.
CWH 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 notices CWH has published or contact us directly to ask about your personal circumstances.
This Notice applies to the handling of personal data. This is data relating to a living individual who can be identified from the data, or from that data and other information which we hold or which is likely to come into our possession. It includes any expression of opinion about an individual or any indication of our intention in respect of them.
Personal data will therefore cover basic details such as name, address, telephone number, email address and date of birth.
CWH’s registration as a data controller
CWH is a ‘data controller’ under the Act. CWH holds information for the reasons given to the Information Commissioner and may use the information for any of those reasons.
Our contact details are:
Head of Governance
CityWest Homes Ltd
21 Grosvenor Place
CWH has notified the Information Commissioner’s Office (ICO) that we will process personal data to enable us to provide our services to our customers, to maintain our own accounts and records and to support and manage our staff.
The ICO describes the processing in a register which is available to the public for inspection at http://www.ico.org.uk/. CWH’s entry on this register can be viewed here.
CWH'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 - iIt 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 data/document retention policy;
• secured with appropriate solutions, which protect the data against unauthorised or unlawful processing and against accidental loss, destruction or damage.
CWH will ensure that it meets the conditions necessary for processing personal data lawfully and will ensure this is adequately recorded. There are a number of ways that processing can be lawful. Consent is one method, but it is important to know that consent is not always required and CWH can lawfully process personal data as long as a condition is met. You can find out more about the conditions on the ICO website.
As a wholly owned subsidiary of WCC, we have a duty of care to our residents. This includes ensuring that we are delivering the services which meet both individual and community needs. In order to monitor our performance, we may ask questions that include information which the law defines as sensitive.
When seeking sensitive personal data, for example, ethnic origin or disability, we will always try to explain why we want the information and how we intend to use it. In some instances, we will need sensitive information to give you the right service, for instance where you require special help due to a disability.
Why CityWest Homes collects personal data
We collect personal data in the administration of the Landlord’s responsibilities and the delivery of services managed by CityWest Homes, e.g. for the following purposes;
• To legally identify customers and for contact purposes, including informing, consulting and gaining feedback about our services;
• To ensure we are not discriminating against anyone because of their age, gender, disability or ethnic origin;
• So that we provide services that meet our customer’s needs;
• For audit and monitoring purposes; to improve our standards of customer service;
• Where WCC requires us collect information for service performance reporting purposes (although these reports are anonymised).
How we collect your information
In order to deliver our services, 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, online forms, social media and through referrals made by third parties, and other key stakeholders acting jointly or on behalf of CWH or WCC.
Processing information fairly and lawfully
CWH processes information only where:
a) the law allows us to; or
b) you have given your consent; or
c) we have received a court order
CWH will process (that means collect, store and use) the information you provide in a manner that is compatible with Data Protection legislation. We will endeavour to keep your information accurate and up to date and not keep it for longer than is necessary. In some instances the law sets the length of time information has to be kept, but in most cases CWH will use its discretion to ensure that we do not keep records outside of our normal business requirements - i.e. providing a service to you.
Our aim is not to be intrusive, and we won't ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to make sure it can't be seen, accessed or disclosed to anyone who shouldn't see it.
We are keen to ensure that we are providing our customers with services that they need. To support this legitimate interest, you may receive occasional e-mail or SMS messages from CWH on matters that we consider may be of interest to you.
CWH will sometimes need to share information with other organisations such as WCC, our partners, third party contractors, government bodies, the police, health and social care organisations, housing associations, and landlords.
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, 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 Data Protection legislation.
For example, we may pass your personal data onto the people who provide services for us, such as a repairs contractor. These providers are obliged to keep your details securely, and use them only to fulfil your request.
We will not use your information for third party marketing purposes.
If you would like to know more or have any concerns about how your information is being processed please contact the Head of Governance at firstname.lastname@example.org.
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 CWH to effectively target and plan the provision of services.
CWH will only contact individuals who are customers of CWH’s products and/or services, or who have otherwise provided their active consent (which may be withdrawn at any time).
Your rights to access your personal information
Under the Act you have the right to ask to see the information what CWH holds about you and why. You have the right to request a copy of the information that we hold about you.
You also have additional rights that refer to how we hold and use 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.
If you want to see the information we hold about you then you must ask for the information in writing and give your full name and address. You should send your request to:
CityWest Homes Ltd
21 Grosvenor Place
Where it is appropriate for CWH to respond directly to requests for access to personal data, we aim to comply as quickly as possible. We will ensure that we deal with requests within 20 working days of receipt, unless there is a reason for delay that is justifiable under the Act.
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.
Contacting CWH – call recordings
There are various ways in which CWH may be contacted: by letter, face to face, email, telephone, online forms, voicemail, social media. In all cases we are committed to protecting the personal data you provide. When contacting us by phone, in line with our policy, calls to Customer Services may be recorded. The recording is needed to quality manage the performance of our customer service advisers, to ensure the quality of service information provided, and to measure and improve the quality of the customer experience. Recordings are retained for a specified timeframe and then deleted in line with our policies.
Personal information collected via online forms
Our policy is to respect and protect the privacy of anyone who visits our website. Where we ask you for personal information via an online form, this information will only be used for the purpose indicated and will be held in a secure manner. It will not be used for any other purpose without your permission and will not be kept for longer than necessary. If you are concerned about providing your personal information online please contact us and we will arrange alternative means for you to provide this information.
Use of IP addresses and cookies
Cookies enhance your experience using our website. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work more efficiently, as well as to provide information to the owners of the site.
We collect IP addresses only for the purposes of system administration and to audit the use of our site. We do not link IP addresses to anything personally identifiable, which means that while your user session will be logged you will remain anonymous to us.
Links to other websites
CWH is not responsible for the content or reliability of linked websites. Linking should not be taken as an endorsement of any kind. We cannot guarantee that links will work all of the time and we have no control over the availability of the linked pages.
Complaints about how we process your personal information
You have a right to complain to us if you think we have not complied with our obligations for handling your personal information. In the first instance, an individual should contact CWH. Complaints should be addressed to:
Head of Governance
CityWest Homes Ltd
21 Grosvenor Place
If you are not satisfied with our response you have a right to complain to ICO. You can report a concern by visiting the ICO website.
Changes to our Fair Processing Notice
As we create new services, this may generate a need to amend this Notice. Any changes with regard to how CWH processes your personal data will be posted on this page