Tighean Innse Gall
GDPR Fair Processing Notice
(How we use your personal information)
This notice explains what information we collect, when we collect it and how we use this. During the course of 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?
Tighean Innse Gall, a registered society under the Co-operative and Community Benefit Societies Act 2014 with Registered Number 2410 R(S) and having their Registered Office at 20 Francis Street, Stornoway, Isle of Lewis HS1 2NB take the issue of security and data protection very seriously and strictly adhere to guidelines published in the [Data Protection Act of 1998] and the General Data Protection Regulation (EU) 2016/679 which is applicable from the 25th May 2018, together with any domestic laws subsequently enacted.
We are notified as a Data Controller with the Office of the Information Commissioner under registration number Z5178362 and we are the data controller of any personal data that you provide to us.
Our Point of Contact is Stewart Wilson CEO based at our office and contactable on 01851 706121 or by email on email@example.com.
Any questions relating to this notice and our privacy practices should be sent to Stewart Wilson-CEO as noted above.
We collect information about you:
when you apply for home improvements, home safety visits, energy advice visits, request services or repairs, participate in special projects including EU projects, housing with us via Rent to Buy or Shared Equity, become a tenant, enter in to a factoring agreement with ourselves, howsoever arising or otherwise provide us with your personal details
when you apply to become a member;
from your use of our online services, whether to report any tenancy/ factor related issues, make a complaint or otherwise; from your arrangements to make payment to us (such as bank details, payment card numbers, employment details, benefit entitlement and any other income and expenditure related information);
We collect the following information about you:
- telephone number;
- e-mail address;
- place/country of birth
- Next of Kin/family representative;
- Income details
- Financial status (incl Savings) for entry into low cost home ownership programmes
- Property tenure, council tax band, size, condition, type, heating form, switching history, title deeds and related details
- Benefits information
- Energy provider, usage details, payment method
- Relevant health issues related to energy use, fuel poverty &/or adaptations
- Solicitors details
We receive the following information from third parties:
- Benefits (eligible/non eligible) status information from DWP
- Payments made by you to us;
- Home Energy Scotland
- Comhairle nan Eilean Siar
- Hebridean Housing Partnership
- NHS Western Isles/NHS Highland
- Citizens Advice Bureaux
- TEAS (SCIO)
- Scottish Government
- Project partners
- Utility companies (when authorised by you to do so)
- Complaints or other communications regarding behaviour or other alleged breaches of the terms of your contract with us, including information obtained from Police Scotland;
- Reports as to the conduct or condition of your tenancy, including references from previous tenancies, and complaints of anti-social behaviour
Why we need this information about you and how it will be used
We need your information and will use your information:
to undertake and perform our obligations and duties to you in accordance with the terms of our contract with you
to enable us to supply you with the services and information which you have requested;
to enable us to respond to your repair request, housing application and complaints made;
to analyse the information we collect so that we can administer, support and improve and develop our business and the services we offer;
to contact you in order to send you details of any changes to our or supplies which may affect you;
for all other purposes consistent with the proper performance of our operations and business; and
to contact you for your views on our products and services.
Sharing of Your Information
The information you provide to us will be treated by us as confidential /[and will be processed only by our employees within the UK/EEA]* We may disclose your information to other third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:
- If we enter into a project, joint venture or merged with another business entity, your information may be disclosed to our new business partners or owners;
- If we instruct improvement, repair or maintenance works, your information may be disclosed to any contractor, funder or funders auditors, industry regulator (e.g. Ofgem), certification body, technical monitoring agent, guarantee companies, property owner.
- Scottish Government & Comhairle nan Eilean Siar where you receive a service delivered for them by TIG;
- Specific charitable bodies agreed by you for funding purposes related to your need incl Citizens Advice Bureaux, Land Trusts, Local charitable Trusts, Home Energy Scotland
- If we are investigating a complaint, information may be disclosed to Police Scotland, Local Authority departments, Scottish Fire & Rescue Service and others involved in any complaint, whether investigating the complaint or otherwise;
- If we are entering and updating tenancy details, your information may be disclosed to third parties (such as utility companies and Local Authority);
- If we are investigating payments made or otherwise, your information may be disclosed to payment processors, Local Authority and the Department of Work & Pensions;
- If we are conducting a survey or evaluation of our products and/ or service, your information may be disclosed to third parties assisting in the compilation and analysis of the survey results
Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.
Transfers outside the UK and Europe
Your information will only be stored within the UK and EEA unless you participate in one of our projects involving international partners. In this case we may transfer your information outside the UK and/or EEA and may share your information with the related partners, funders and auditors and thus:
Where information is transferred outside the UK or EEA we ensure that there are adequate safeguards in place to protect your information in accordance with this notice, including the following:
- a decision by the EU Commission that the third country has adequate safeguards
- details of appropriate security provisions in place.
How long we will keep your information
We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you.
We will generally keep your information for the following minimum periods:
Energy Efficiency measures – 7 years from the end of the financial year in which the claim of the measure occurred, or where a guarantee is issued for the period of the guarantee.
Care & Repair Service – 7 years from the end of the financial year in which the service, as concluded, occurred.
Energy Advice – 7 years from the end of the financial year in which the advice or assistance was delivered.
Development Shared equity– indefinitely as a resale process may be required
Development –Rent to Buy – 7 years from the end of the financial year in which the tenancy ended or purchase concluded.
Development – waiting list – annually reviewed at the end of each financial year
after which this will be destroyed if it is no longer required for the reasons it was obtained.
Our full retention schedule is available at our Stornoway office.
You have the right at any time to:
ask for a copy of the information about you held by us in our records;
require us to correct any inaccuracies in your information;
make a request to us to delete what personal data of your we hold; and
object to receiving any marketing communications from us.
If you would like to exercise any of your rights above please contact us at firstname.lastname@example.org
You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information. The Information Commissioner’s contact details are noted below:
The Information Commissioner’s Office – Scotland
45 Melville Street, Edinburgh, EH3 7HL
Telephone: 0131 244 9001
The accuracy of your information is important to us – please help us keep our records updated by informing us of any changes to your email address and other contact details