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 when supporting you as Service User. Additional Privacy Notices are available for residents and current, former and prospective staff.

You have the right to raise a concern about these issues about how your data is handled. 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.

  • 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 employment such as personal details/payroll forms, beneficiary nomination forms, expenses claims forms, training requests etc
    • From correspondence, interviews, meetings or other assessment with you
    • From third parties including
    • Employment references
    • Data from the provider of our online applicant tracking system.
    • Criminal Records Checks permitted by law (DBS etc)
    • Occupational Health Assessments and other medical information related to your employment
    • When you voluntarily complete staff surveys, provide feedback and participate in competitions.

    Our website does not capture or store personal information, but does log the user’s IP address and cookies to record the number of visitors to our website.

  • Who we collect information about
    • Current and former employees
    • Applicants for employment, board vacancies and volunteering opportunities
    • Current and former Board members
    • Current and former volunteers
  • What information do we collect and what do we do with it?

    As an applicant for a job at Hightown

    What data we collect What we do with it
    Name, address and contact details, including email address and telephone number.  To correspond with you.
    Details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers and with Hightown.  To assess your suitability for employment and to request references should we decide to make you an offer.
    Information about your nationality and entitlement to work in the UK. To check your right to work in the UK and enter into a contract with you
    Information about your criminal record (where this is a requirement of the role or relates to unspent convictions).  To ensure you are permitted to undertake the role in question.
    For positions where you are required to drive – details of your driving licence, motoring convictions, vehicle insurance.  To ensure you have the legal capacity for a role that involves driving at work.
    Details of your car/vehicle ownership and registration. To ensure you have the legal capacity for a role that involves driving at work.
    To process expenses claims.
    For parking control and monitoring parking at Hightown locations.
    Information about medical or health conditions, including whether you have a disability for which Hightown needs to make reasonable adjustments. To ensure that reasonable accommodation can be made for interview and for the role in question.
    Equality and diversity monitoring information, including your ethnic origin and date of birth. For the purposes of equal opportunities monitoring to ensure we are being fair in our employment practices.
    Voice recordings of phone calls. Monitor service quality, complaint resolution.

    As an employee
    Hightown needs to process data to enter into an employment contract with you, to meet our obligations under your employment contract and to respond to and defend against legal claims. We will use your data to:

    What data we collect What we do with it
    Name, address and contact details, including email address and telephone number, date of birth and gender. To enter into and manage the performance of an employment contract with you.
    The terms and conditions of your employment. To meet our obligations under your employment contract.
    Details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers and with Hightown. To enter into and performance of an employment contract with you.
    Details of your employment history, including start and end dates, with Hightown.

    Provide references on request for current or former employees.

    To identify staff who qualify for long service awards and publicise long service award recipients to other Hightown staff.

    Information about your remuneration, including entitlement to benefits such as pensions, life assurance cover. To pay you in accordance with your employment contract, deduct tax and to administer pension entitlements.
    Details of your bank account and national insurance number. To pay you in accordance with your employment contract and ensure we are complying with our legal obligations.
    Information about your marital status, next of kin, dependants and emergency contacts. Maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency).
    Your photograph or digital image. Verification of identity, security and fraud prevention.
    Information about your nationality and entitlement to work in the UK. To check your right to work in the UK and enter into a contract with you.
    Information about your criminal record (where this is a requirement of the role or relates to unspent convictions). To ensure you are permitted to undertake the role in question.
    For positions where you are required to drive – details of your driving licence, motoring convictions, vehicle ownership and insurance. To ensure you have the legal capacity for a role that involves driving at work.
    Details of your car/vehicle ownership and registration 

    To ensure you have the legal capacity for a role that involves driving at work.

    To process expenses claims.

    For parking control and monitoring parking at Hightown locations.

    Details of your work pattern (days of work and working hours) and attendance at work. Maintain accurate and up-to-date employment records and to enable you to take periods of leave to which you are entitled.
    Details of periods of leave taken by you, including holiday and career breaks and the reasons for the leave. To enable you to take periods of leave to which you are entitled.
    Details of periods of family leave taken by you and the reasons for the leave. Operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that Hightown complies with duties in relation to leave entitlement, and to ensure that employees are receiving the pay or other benefits to which they are entitled.
    Details of periods of sickness absence. Operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that employees are receiving the pay or other benefits to which they are entitled.
    Details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence. Operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace.
    Assessments of your performance, including PDRs, 1:1 meetings, performance reviews, training you have participated in, performance improvement plans and related correspondence. Operate and keep a record of employee performance and related processes, to plan for career development, and for organisational continuity/succession planning and workforce management purposes.
    Information about medical or health conditions, including whether you have a disability for which Hightown needs to make reasonable adjustments. Obtain occupational health advice, to ensure that we comply with our duties in relation to individuals with disabilities, meet our obligations under health and safety law, and ensure that employees are receiving the pay or other benefits to which they are entitled.

    Equality and diversity monitoring information, including your ethnic origin, sexual orientation, health and religion or belief. 

    For the purposes of equal opportunities monitoring to ensure we are being fair in our employment practices.

    Voice recordings of phone calls

    Monitor service quality, complaint resolution.

    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 we share your information with

    Your information will be shared internally, including with members of the HR team, payroll, your line manager, managers in the business area in which you work and IT staff if access to the data is necessary for the performance of their roles.

    Hightown shares your data with third parties in order to obtain pre-employment references from other employers, and obtain necessary criminal records checks from the Disclosure and Barring Service. Hightown may also share your data with third parties in the context of a sale of some or all of its business. In those circumstances, the data will be subject to confidentiality arrangements.

    Hightown also shares your data with third parties that process data on our behalf for example:

    • Current Payroll Provider to manage your pay and send you payslips
    • Current Provider of our online Applicant Tracking system.
    • HMRC to provide up to date information on tax, NI, pensions etc
    • Pension Providers
    • Office of National Statistics
    • External Training Providers to facilitate your learning and development
    • Occupational Health Providers – to manage your health as it relates to work (in this instance explicit consent will be sought)
    • Disclosure Barring Service
    • Previous Employers (to seek references)
    • Future Employers (to provide references)
    • Solicitors
    • Health & Safety Executive
    • Police
    • Google/Apple/Microsoft etc - Hightown issues some employees with electronic devices such as mobile phones or tablets. 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.
  • How long we keep your data for

    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 the GDPR

    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 so long as the request is not unusually large 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.

    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. Hightown has one automated decision-making process for staff data, this is where a driving licence and access to a vehicle are essential for specific posts. This decision-making is necessary to ensure the applicant has the capacity to enter into a contract of employment where car usage is essential, and to avoid the risk of infringement of relevant road safety legislation such as the Road Traffic Act 1998.

  • 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 the information held on our systems secure. We also have a number of physical security measures in place, such as office security and confidential destruction of waste paper.

    All data will be stored securely within Europe and all data held on our own computer systems is stored locally in the UK.

  • Special Categories of Data

    Information about health or medical conditions is processed to carry out employment law obligations (such as those in relation to employees 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 employees, which can be withdrawn at any time. Employees 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 below.

  • Other websites

    Our websites contain 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 place any updates on our website. Hightown’s privacy policy was last updated on 25/05/2018. Hightown’s full Data Protection & Privacy Policy can be viewed on Hightown’s intranet, Mytown.

  • Lawful basis for processing data

    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 employees or workers and has concluded that they are not.

  • How to contact us

    The Data Protection Officer for Hightown is Mark Carter, Director of Business Transformation. If you have any questions about this Privacy Notice or the information we hold about you, please contact us at DataProtection@Hightownha.org.uk.