Privacy Notices - Remote assistance video link communication Privacy Notice
This privacy notice explains what happens to the information we collect from video link communications for the purposes of the repair and maintenance of your home.
The Housing Act 1985 is the legal basis for providing you with the service you require, and the need to collect and store the personal information relating to tenants and their representatives.
We are committed to protecting the personal information we collect about you.
- What is a Privacy Notice?
A Privacy Notice is a statement issued by an organisation which explains how personal and confidential data about individuals is collected, used and shared.
- Who is collecting and using your personal data?
Swindon Borough Council will act as a “Data Controller” for any personal data that you provide to us. We will ensure that the data given to us is processed in line with our Data Protection Act 2018 (DPA 18) and the EU General Data Protection Regulations. (GDPR)
Please note: not providing your personal data may lead to you being unable to use services provided by the Housing department.
- Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of data is governed by the Data Protection Act 2018.
- What personal data do we collect?
We will hold personal information about you such as, your name, date of birth, address and contact details (including telephone number(s) and email addresses).
With video link communication, although it is not our intention to do so, we may also inadvertently capture sensitive and special category personal data along with an inference of information such as:
- household members visual appearance, gender, nationality, marital status, race, ethnicity and religion
- details of where household members work and or which school the household children attend
- information relating to household members physical and mental health medical needs
- images of the tenant, household and extended family or friends along with any visitors within the home environment
- the property content including photographs, personal taste and interests and any items of value or assets that it possesses including vehicles
- audio of personal communications between the household including personal conversations carried out from within the household with voluntary information, opinions and expressions shared within those conversations
- visual observations of the household within private space from recording of images and sound
- recordings of an inappropriate nature, incident exposure, household disagreements and arguments, violence or abusive behaviour
- audio and recording of external affairs which may be taking place in the street, garden or neighbouring properties
- How do we process your personal data?
Swindon Borough Council complies with its obligations under the Data Protection Act by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
- Why do we need your personal information?
We require your personal information to provide assistance regarding housing repair requests and meeting our obligations regarding property maintenance. Scenarios which may benefit from the use of a Remote Assistance video link communication include to:
- triage emergency repair requests to establish if an out of hours visit is required
- provide imminent support and advice to tenant without the need for a home visit
- establish repair requests where imminent support and advice would benefit
- conduct surveys and provisions for work planning and materials without the need for home visit
- provide support from managers to operatives that are in the field conducting repairs within your home
- support managers to assess work progress and job satisfaction levels
- How the law allows us to use your information?
We collect and use this information under Article 6 (lawful processing), and Article 9 (special categories of data), of GDPR 2018.
Article 6 of GDPR
Public task: the processing is necessary for the local authority to perform a task in the public interest or for official functions, and the task or function has a clear basis in law.
For those within tenancy services where the above does not apply:
Consent: the individual has given clear consent for the local authority to process their personal data for a specific purpose.
Article 9 (2) of GDPR – special categories of data and lawful processing
Processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.
The Data Protection Act 2018 (12, Schedule 1, part 2 specifically outlines the responsibilities in relation to processing data for the purposes of safeguarding children and individuals at risk.
- Who do we share your information with?
Your personal information will be seen by Swindon Borough Council staff and may be disclosed to trusted third parties such as contractors if they are carrying out repairs and maintenance on our behalf.
Video recordings that highlight a safeguarding concern may be shared with The Swindon Safeguarding Partnership as part of our safeguarding obligations.
Whenever you provide us with information, you will be told what we will use it for and who we will share it with.
- How do we protect your information?
We will do what we can to make sure we hold records about you (on paper and electronically) in a secure way, and we only make them available to those who have a right to see them.
All recordings and information obtained via Remote Assistance video link communication is held on servers and databases which are protected by industry standard security technology- Azure Cloud. Data in Azure Cloud Storage is encrypted and decrypted transparently using 256 – bit AES encryption, and is FIPS 140-2 compliant.
Remote Assistance is user name and password protected with no data stored locally on mobile devices. All Council mobile devices ensure data are encrypted at rest and in transit. All Council employees and Contractors who have access to personal data will have been trained to handle such data properly and in accordance with the latest regulation.
We will maintain the reliability, accuracy, completeness and currency of personal data in our databases and to protect the privacy and security of our databases. We keep your personal data only for as long as reasonably necessary for the purposes for which it was collected.
- How long do we keep your personal information?
Recordings will be auto deleted 4 weeks after the call has completed, by which time the repair request should be closed. An auto deleting function will be enabled to ensure data is not held for longer than its intended purpose. Only under exceptional circumstances will data be retained such as for potential safeguarding concerns or compliance issues.
- What you can do with your information?
Subject to an exemption under GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of your personal data which Swindon Borough Council holds about you
- The right to request that Swindon Borough Council corrects any personal data if it is found to be inaccurate or out of date
- The right to request your personal data is erased where it is no longer necessary for Swindon Borough Council to retain such data
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing
- The right to object to the processing of personal data
- The right to lodge a complaint with the Information Commissioners Office
For further details on how your information is used, how we maintain the security of your information, and your rights to access information we hold on you, contact firstname.lastname@example.org or contact the Data Protection Officer at:
Swindon Borough Council
Any further questions regarding the data being processed may also be sent to the Data Protection Officer at the above email address.
- Your right to complain
You also have a right of complaint to the Information Commissioner’s Office (ICO) at www.ico.org.uk if you think we have dealt with your information in an inappropriate manner.
- What if you do not provide personal data?
Recordings will only be made with consent from the tenant however you are under no statutory obligation to provide consent for video recording or collection of your personal data to Swindon Borough Council however if you do not provide the consent we may not be able to deal with your request as efficiently or effectively.
- How will we ensure compliance?
The Human Rights Act will remain a priority of concern with the usage of video recording to ensure we remain compliant and lawful with its use. Training will be provided to staff to ensure they understand all tenants are entitled to free, open and fair private life. We will only use the video for its intended purpose and should anything inappropriate occur during the recording we will follow our processes for safeguarding.
A yearly audit will take place on personal data to ensure that we remain legally compliant in accordance with current data protection legislation.
- Main privacy notice
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