Privacy notice for staff and applicants

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 a member of staff. Additional Privacy Notices are available for residents and service users.

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.

This privacy notice summarises how we will process your personal data as a current or former member of staff or a future applicant. Additional Privacy Notices are available for Service Users and Residents.

This statement does not form part of any contract of employment or other contract to provide 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 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 or other role 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, performance, attendance, conduct, training record, disciplinary and grievance information with previous employers and with Hightown	To assess your suitability for employment and to request references should we decide to make you an offer. To keep records of our hiring process
Passport, national insurance details, images and other evidence of identity	Confirmation of your identity
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
Records, emails, correspondence and other communication you created or updated in relation to your application for employment at Hightown.	Share with relevant third parties for the purposes of references, verification and fraud prevention
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 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.

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 performance of an employment contract with you.
Passport, national insurance details and other evidence of identity	Confirmation of your identity
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.
Operational and training records, emails, correspondence and other communication you created or updated during your employment at Hightown.	Provide references, assessments and appraisals Share with relevant third parties for the purposes of references, verification and fraud prevention
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. Contact you/and or your named emergency contact(s) in the event of an emergency.
Your photograph or digital image	Marketing, verification of identity, security and fraud prevention.
Your Hightown work contact details	Routine correspondence and contact related to your employment at Hightown.
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 or training 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 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, ensure that employees are receiving the pay or other benefits to which they are entitled, ascertaining your fitness to work
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
Security information such as CCTV footage, key card information and car park entry systems	Service monitoring, confirmation of work attendance, evidence for insurance claims and crime prevention and investigation
Voice recordings of phone calls	Monitor service quality, complaint resolution
Information about your use of our information and communications systems (such as emails, calls, correspondence and other communications).	To perform our employment contract with you, manage performance, monitor confidentiality and data protection compliance, ensure compliance with our IT policies and manage network and information security, including preventing unauthorised access to our computer and electronic communications systems and prevent malicious software distribution.

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 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 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 or provide services on our behalf for example:

Current Payroll Provider to manage your pay and send you payslips
Current Provider of our online Applicant Tracking system.
IT providers hosting Human Resource, applicant and employee management systems
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)
Insurance providers, for the payment of health related insurance benefits
Criminal records bureau providers carrying out Disclosure Barring Service checks
Previous Employers (to seek references)
Future Employers (to provide references)
Other individuals or organisations who may be affected by any incorrect or fraudulent statements made during your employment at Hightown or in relation to your employment application
Solicitors
Health & Safety Executive
Police
External agents managing debt recovery on behalf of Hightown
Organisations with a function of auditing and / or administering public funds for the purpose of detection and prevention of fraud
Passing your work contact details to authorised suppliers, agents and stakeholders of Hightown for contact in the course of HHA business.
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 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 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.

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. 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 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 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 address below.

Other websites

Our websites 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 place any updates on our website. Hightown’s privacy policy was last updated in December 2019. Hightown’s full Data Protection & Privacy Policy can be viewed on Hightown’s intranet, Mytown.

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; or where we need to protect your vital interests or those of another person.

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; we need to protect the vital interests (health and safety) of you or another person; 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