Privacy Statement

Tuath Housing Association

 

Tuath Housing Association “Tuath” is committed to maintaining the privacy of your personal information and take our obligations under data protection legislation very seriously.  Personal information means any information relating to an identified or identifiable living person.  

 

This statement explains how Tuath use your data and what rights you have in relation to your personal information.  It explains what information we collect, why we collect it, how we use it and who we might share it with. 

 

1.       Who we are

We are Tuath Housing Association “Tuath”.  Tuath is an Approved Voluntary Housing Association.  Our aim is to provide long-term, good quality, secure homes that people can afford by investing in people and places.  For more information about Tuath, see our website at www.tuathhousing.ie

 

1.       Our Contact Details

If you have any questions with regard to how we process your personal information or any requests concerning your personal information, we would be happy to help.  You can contact us by writing to, emailing or phoning our head office:

 

Tuath Housing Association
33 Leeson Street Lower	[email protected]
Dublin 2 D02 KD68	+353 1 6761602

 

Or by contacting our Data Protection Officer (DPO), Rebekah Fozzard, using the contact details below:

 

Data Protection Officer Tuath Housing Association
33 Leeson Street Lower	[email protected]
Dublin 2 D02 KD68	+353 1 6761602

 

2.       The information we collect about you

In order to provide you with the services you require, we will collect and process personal information. 

 

This information includes:

• Personal information to identify you, including your contact details
• Your financial details and financial circumstances
• Your marital status
• Your family status
• Information about you provided to us by others – e.g. local authorities through the nomination process
• Information about you that you have provided to us e.g. information about your employment history
• CCTV images, photographic ID, telephone recordings
• Other information relevant to the safe provision of housing

Some personal information is considered ‘special’ under data protection legislation and needs extra protection because its misuse can cause more harm than other types of personal data.  The special data we might collect and use includes data relating to your physical and mental health, data relating to criminal convictions and other information relevant to support the safe provision of your housing. 

 

3.       How we collect information about you

We collect information in a number of ways:

• Information you give us
• Information provided to us by third parties, including local authorities
• Information from your use of our website

 

4.       How we use your information

We use and share your data if:

• It is required to do so in relation to a service or a contract that you have entered into e.g. Tenancy Agreement
• Use is necessary because Tuath has to comply with a legal obligation e.g.
  • Complying with, and reporting to regulatory authorities and law enforcement
  • To protect the health, safety and welfare of Tuath employees, customers or residents
• Use is necessary to protect your ‘vital interests’ in certain circumstances
• You have agreed or explicitly consented to the using of your data in a specific way (you can withdraw your consent at any time)
• It is required to support our legitimate interests relating to:
• Health, safety and welfare and crime prevention and detection. E.g. we have CCTV cameras across our Housing communities. If you visit or live there you might be recorded on our cameras.
• The provision of good quality, secure homes that people can afford
• Research, programme evaluation and service improvements. This may be where you are asked to complete a survey or participate in tenant, employee or other feedback
• Communicating with you and informing you of our services

 

Processing Special Categories of Personal Data

We treat all residents and customers equally regardless of your health status, racial or ethnic origin, philosophical or religious beliefs, sexual orientation or criminal convictions.  

 

When we use sensitive data, we need a clear reason to do so. We might use this data for the following reasons:

• For our legitimate activities as a non-profit organization, with proper protections in place
• If you have made the information publicly available
• If the information is needed for legal claims or defences
• If the information is needed for legal advice or proceedings
• If you have given us explicit permission to use the data

 

5.       Profiling and Automated Decision Making

You have the right not to be affected by decisions made only by computers or automated systems, especially if those decisions could have a big impact on you.  Tuath uses automated decision-making during the initial stage of the Cost Rental application process to determine if an applicant is eligible or not to apply for Cost Rental housing.  Tuath may also use automated decision-making as part of the annual rent review process.  You are entitled to request that a Tuath staff member review decisions made by automated decision-making.

6.       Data Sharing

Tuath may share your information with organisations outside of Tuath to help us operate.  Below are some examples of when your data may be shared.

 

• Data Processors – we use services and systems from other companies to help us with our work. Sometimes we need to share your personal data with these companies. They must follow strict security rules to protect your data according to data protection regulations.  They can not use your data for their own purposes unless they are allowed to by law.  They can only use your data for specific tasks that Tuath has asked them to do, and they must keep your information confidential.  For example, external contractors whom Tuath use to repair and maintain our housing stock.

 

• Third Party Recipients – we need to share data with third parties who are not working directly for us or on our behalf. These include tax authorities, law enforcement, statutory bodies, solicitors, insurers and financial institutions.

 

• Local Authorities – through the nomination process

 

• Your authorised representative/s – person or organisation that has been given permission to act on your behalf.

 

Where Tuath shares your personal data with third parties, this is done under strict conditions to ensure compliance with data protection regulations.   Tuath stipulates that any personal data shared must be deleted once the personal data is no longer required for the purpose for which it was given. Tuath does not share your information with non-EEA countries, other than those granted approval under the EU GDPR Adequacy provisions.

 

7. How long we keep your data for

We only keep your personal data for as long as necessary for the provision of our services to you or as required by law. For example:

 

CCTV Recordings	30 days from the date the footage was recorded
Phone Call Recordings	30 days from when the call was recorded
Tenancy Files	7 years after the tenancy ceases, unless another legal basis in which to keep the data (e.g. rental arrears)

 

8. Security of your data

Tuath cares about keeping your personal data safe and secure.  We do everything we can to protect any personal data you give us. 

 

Our IT systems meet international standards of security as part of our Information Security Policy.  Our laptops have encryption., we use multi-factor authentication as an extra layer of security and our mobile devices are protected with passwords or FaceID/TouchID.  

 

Physical file storage is subject to safeguards, such as secure premises and filing systems.  We have security cameras and alarms at our buildings and all our employees get regular training on how to protect the personal data that they use.

 

9. Cookies

When you are using our website, Tuath uses cookies.  A cookie is a small piece of data (text file) that a website asks your browser to store on your device in order to remember information about you. Some cookies are necessary for the functioning of the website, while others are used to track performance and possible marketing efforts.   Before planting cookies on your device (other than strictly necessary cookies) we will seek your explicit consent through the cookie banner when you land on our webpage.

Within your browser you can choose whether you wish to accept cookies or not. Different browsers make different controls available to. Generally, your browser will offer you the choice to accept, refuse or delete cookies at all times, or those from providers that website owners use (“third party cookies”), or those from specific websites. You can amend your cookie and tracking technology consent at any time on our website.

Our website may contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy settings and cookie notices, and these are not endorsed by us.  We do not accept any responsibility or liability for these third-party websites.

If you have any questions, concerns or comments about our cookie policy, please send us a description of your concern via email to [email protected]  or phone +353 1 6761602.

 

10. Your Rights

Under Data Protection Legislation, including the General Data Protection Regulation (GDPR), you have the following rights in relation to your data.  You can send us a request about any of the rights outlined below.  This can be done by contacting Tuath directly by emailing: [email protected]  /  [email protected] or phoning +353 1 6761602.  

 

We will do our best to handle your request as soon as possible and within one month of receiving your request.  However, restrictions may apply in certain circumstances.  Where a restriction applies, or where we may need more that one month to fulfil your request, we will take you the reason for the delay or the restriction within one month.

 

• Access: You can ask to see the personal data that Tuath, or any company, has about you. This is called a subject access request (SAR)
• Correction: If the personal data that Tuath, or any company, has about you is incorrect, inaccurate or incomplete, you can ask for it to be corrected
• Restriction: You can limit how Tuath, or another company, uses your personal data
• Objection: You can say no to certain types of uses of your personal data
• Deletion: You can ask Tuath, or another company, to delete your personal data when it is no longer needed or if processing it is unlawful
• Data Portability: You can copy, move and transfer your personal data easily from one IT environment to another in a safe and secure way, without affecting its usability
• Automated Processing: You have the right to avoid decisions being made about you based solely on automated processing, including profiling, which have significant effects on you

 

Withdrawing and Amending Consent

If we’re using your personal information because you consented to us using it, you can change your mind at any time. If you want to do this, please contact Tuath directly, email [email protected] or [email protected] or phone +353 1 6761602.    If you withdraw and/or amend consent, we may not be able to continue providing or maintaining services to you where we relied upon consent. 

 

11. Right to Complain to the Data Protection Commissioner

The Data Protection Commissioner (DPC) is the organisation responsible for ensuring that organisations follow data protection regulations. For example, if you give your name, phone number, or address to an organisation like Tuath, the Commissioner makes sure we don’t share it with others without asking you first.  If you think your personal data isn’t being used correctly, you can complain to the DPC.  Before you do that though, you might find it helpful to contact Tuath’s DPO, Rebekah Fozzard first, at: [email protected].

 

If you do decide you would like to complain to the DPC, you can do so by:

• Phone: (01) 7650100 / 1800 437 737
• Email: [email protected]
• Postal Address: Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28

Should you need assistance when engaging with the services provided by the Data Protection Commission, please contact their accessibility officer at: [email protected]

 

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