Personal information provided to or to be gathered by Hightown Housing Association is controlled by Hightown Housing Association Ltd, Hightown House, Maylands Avenue, Hemel Hempstead, Hertfordshire, HP2 4XH.
This privacy notice summarises how we will process your personal data as a current or former Board member, Committee member, Co-optee or Shareholder or applicant. Additional Privacy Notices are available for Staff, Service Users and Residents.
This statement does not form part of your agreement for services. Hightown may update this statement at any time.
How we collect information about you
We collect information about you in a variety of ways, including:
• Application Forms and CV’s
• Information on Identity documents including Passports, Driving Licenses etc
• Forms completed by you at the start of or during your term of office such as personal
details/payroll forms, expenses claims forms, training requests etc
• From correspondence, interviews, appraisals, meetings or other assessment with you.
• From third parties including references.
Who we collect information about:
• Current and former Board members, Co-optees and Shareholders
• Applicants for board vacancies
What information do we collect and what do we do with it?
As an applicant for a Board or other role at Hightown
As a Board Member, Co-Optee or Shareholder Hightown needs to process data to enter into an agreement for services with you, to meet our obligations under the agreement and to respond to and defend against legal claims.
Our lenders sometimes require us to share some or all of this information with them in order to assess our suitability and to prevent fraud. We also publish relevant information on the Hightown website and in the Annual Report and Accounts.
We will not provide your information to any other company for direct marketing purposes. We will not sell or lease your personal information to third parties.
Who do we share your information with?
Your information will be shared internally, including with members of the Governance and Executive Teams, payroll, IT staff if access to the data is necessary for performance of their roles.
Hightown shares your data with third parties in order to obtain pre-appointment references.
Hightown also shares your data with third parties where there is an appropriate lawful basis.
For example:
• Auditors
• Funders
• Regulators
• Current Payroll Provider to manage your pay and send you payslips
• IT providers hosting electronic Board papers systems
• HMRC to provide up to date information on tax, NI, pensions etc
• Office of National Statistics
• External Training Providers to facilitate your learning and development
• Named referees
• Organisations with a function of auditing and / or administering public funds for the
purpose of detection and prevention of fraud
• Google/Apple/Microsoft etc - Hightown issues Board members on request with electronic
devices such as tablets or laptops. Many of these devices track your location, browsing
behaviour and use of apps by default and send this information to third parties. Please
refer to these companies’ privacy policies for more information
• The Convene electronic Board Papers system collects information required to provide its service such as your name, username, your company name, job title, email address, phone number. The Azeus Convene privacy policy can be found: Convene customers:
(Trial Users and Paid Customers) | Convene (azeusconvene.com)
How long do we keep your data?
Documents are retained in accordance with the latest Document Retention guidelines for Housing Associations published by the National Housing Federation. These are available on request.
Your rights under Data Protection laws
You have the right to raise a concern about these issues. You can also raise a concern with the Information Commissioner’s Office (ICO) if you are not satisfied with the way Hightown deals with your concern.
The right to be informed
You have the right to be informed about the collection and use of your personal data, including the purpose of processing the personal data, how long it is kept for and who it will be shared with. This information is set out in this Privacy Notice.
Accessing your information
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us using the contact details below. There is no charge for this and we will respond to you within 1 month.
Correction & Removal
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove any information you think is inaccurate or no longer needs to be kept.
Object & Restrict
In certain circumstances, you have the right to object to your personal data being processed, or to request that its use is restricted.
Data Portability
You can request that your data is made available in an electronic format that can be transferred to another organisation, in a safe and secure way, without affecting its usability.
Rights in relation to automated decision making and profiling
You have the right to be informed of any use of your data that involves automated decision making any profiling. Currently Hightown does not profile personal data in relation to Board members.
Security of information
We are committed to ensuring that your information is held securely. In order to prevent unauthorised access or disclosure we have developed separate IT policies which set out how we keep secure the information held on our systems. We also have a number of physical
security measures in place, such as office security and confidential destruction of waste paper.
All data is stored securely in accordance with data protection legislation and all data held on our own computer systems is stored in the UK.
Special Categories of Data
Information about health or medical conditions is processed to carry out legal obligations (such as those in relation to Board members with disabilities and for health and safety purposes). Where Hightown processes other special categories of personal data, such as information about ethnic origin, sexual orientation, or religion or belief, this is done for the purposes of equal opportunities monitoring. Data that Hightown uses for these purposes is anonymised or is collected with the explicit consent of Board members, which can be withdrawn at any time. Board members and applicants are entirely free to decide whether or not to provide such data and there are no consequences of withholding this information. If you wish to withdraw your
consent contact the email address below.
Other websites
Our website contains links to other websites. Hightown’s privacy policy only applies to Hightown’s websites so when you link to other websites you should read their privacy policies.
Changes to our Data Protection & Privacy policy
We keep our privacy policy under review and we will provide and updates to Board members.
Lawful Basis for processing
The lawful basis for most of our personal data processing of your information is where it is necessary for the purposes of Hightown’s legitimate interests. Where Hightown relies on legitimate interests as a reason for processing data it has considered whether or not those
interests are overridden by the rights and freedoms of service users and has concluded that they are not.
The lawful basis may in some instances be because we have your consent to process your personal information. Where this applies this will be made clear to you and you can withdraw your consent at any time. We may also process your information for other reasons, such as where we are under a legal or contractual obligation to process or disclose the information.
Some personal information is treated as more sensitive (for example medical or diversity information). The legal basis for processing these special categories of personal information is more limited. To process special categories of personal data lawfully, we must identify a specific lawful basis for the processing, which may be because we have your consent; you have already made your personal information public; we or another person needs to bring or defend legal claims; there are substantial public interest grounds.
How to contact us
If you have any questions about this Privacy Notice, or the information we hold about you, please contact the Data Protection Officer at DataProtection@Hightownha.org.uk
