Organization Policies

Horton Housing Privacy Notice

This privacy notice informs you as to how Horton Housing Association (HHA) looks after the personal information of our volunteers, what your privacy rights are and how the law protects you. As a valued volunteer you need to be clear and comfortable with how we collect your personal information and what we do with it.

What information do we have?

  • Personal details about you and sometimes your family e.g. name, address, contact details including telephone number and email address, Date of Birth, National Insurance Number, Emergency Contact details
  • Financial information e.g. reimbursement of expenses, bank details
  • Sensitive (special category) information such as any health problems, details of religion, ethnicity, sexuality, and any information about criminal offences.
  • Training records and supervision notes
  • Your photograph if you are provided with a Horton Housing ID badge

Why do we need your information?

Processing volunteer data allows HHA to:

  • Run volunteer recruitment and appointment processes
  • Assess the suitability of individuals for volunteering activities
  • Maintain accurate and up-to-date volunteer records and contact details (including details of who to contact in the event of an emergency)
  • Ensure that volunteers are receiving appropriate reimbursement of expenses
  • Ensure it meets its obligations under health and safety law including assessments of risk
  • Comply with statutory and/or regulatory requirements and obligations e.g. carrying out Disclosure and Barring Service (DBS) checks if your role is a regulated activity
  • Ensure effective general business administration
  • Respond to and defend against legal claims
  • Maintain and promote equality in the workplace.

What is the legal basis for using your information?

HHA relies on the following legal conditions that are described in the General Data Protection Regulation (GDPR) to use your personal information in the ways described in this privacy notice:

  • Legitimate interest: where we have a legitimate interest to do so in support of our aims and objectives. We also have a legitimate interest in being able to use and process personal information for internal administrative purposes, and when it is necessary to protect our IT network, data security and ourselves from risks such as fraud, criminal conduct or reputational damage
  • When processing your personal information based on a legitimate interest, we will make sure that it is exercised proportionately and is always balanced against the privacy rights and other legal rights you have as an individual
  • Your Consent: We will obtain your consent to process any special category information you provide us with
  • We may use special category personal information about you without your consent only in such instances where:
  • We need to protect your vital interests (or those of someone else) in an emergency
  • We have a need to use such information in connection with a legal claim
  • You have already made such information public, such as religious or philosophical beliefs or political opinions

Who do we share your information with?

  • Your data will be shared with colleagues within HHA where it is necessary for them to undertake their duties. This includes, for example, relevant managers for the purposes of supervision, the HR department for maintaining personnel records, payroll for administering expenses reimbursement and IT staff.
  • We share your data with third parties in order to obtain references from other organisations and obtain necessary criminal records checks from the Disclosure and Barring Service (DBS).
  • We may be required to share your data with third parties such as the local authority, police, courts and statutory agencies, the DBS and Department of Work and Pensions to comply with legal obligations.
  • We will not share your data with third parties for any other purpose without your express consent.

How long will we keep your information?

  • In line with data protection principles, we only keep your data for as long as we need it, which will be at least for the duration of you volunteering with us
  • We will not keep your data if you do not commence volunteering with us
  • We will keep your data for a period of up to 13 months after your volunteering relationship has ended, for the purpose of providing you with a reference
  • Retention periods can vary depending on why we need your data. This may be determined by law

What are your rights?

As a data subject, you have a number of rights. These are:

  • The right to be informed. This means that we must tell you how we use your data, which is the purpose of this privacy notice
  • The right of access. You have the right to access the data that we hold on you and to receive a copy of your data and information about where it was sourced. To do so, you should make a subject access request
  • The right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
  • The right to ask us to erase your data, for example if you believe there is no longer any need for your data to be held for its original purpose, or if you decide to withdraw any consent that you have given for your data to be processed
  • The right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
  • The right to portability. You may request the transfer of the data that we hold on you to another organisation for your own purposes
  • You may have the right to object to the way we use your data if you do not agree that we are using it for our legitimate interests
  • The right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights
  • Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

Where can you get more information?

  • If you have any questions about this privacy notice, how we handle your personal information or would like to exercise any of your rights please contact our Data Compliance Manager:
  • In writing: Data Compliance manager, Horton Housing Association, Chartford House, 54 Little Horton Lane, Bradford, West Yorkshire BD5 0BS
  • By email: datacompliance@hortonhousing.co.uk
  • By telephone: (01274) 370689

What if you have any concerns?

  • Speak to the Volunteer Services Manager or your team manager/supervisor if you are worried or unhappy with how we are managing your personal information/data.
  • Contact the Information Commissioners Office on 0303 123 1113 or www.ico.org.uk

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