This Privacy Notice will illustrate how your personal data and, if applicable, special categories of personal data will be used by Lintel Trust. It will provide you with information about your rights under the General Data Protection Regulation (EU) 2016/679 [GDPR] and the Data Protection Act 1998 (as amended) [the Data Protection Legislation] and how to action these rights.
Who we are
The Link group of companies is committed to protecting your privacy. The Link group is made up of Link Group (the parent company), Link Housing Association, LinkLiving, Link Property, Horizon Housing Association, Larkfield Housing Association, West Highland Housing Association and Lintel Trust. Each member of the group is registered as a controller with the Information Commissioner’s Office [ICO].
Each Link group company has entered into a Data Processing Agreement with the other Link companies, which sets out clearly how and why information may be shared. This ensures that we can provide you with the services you expect from us at the same time as meeting our data protection obligations.
The data protection principles set out how personal data should be managed.
What Link has to do
- Lawfulness fairness and transparency - We need to be clear and upfront about what we use your data for.
- Purpose limitation - We will only use your data for specific reasons which are set out in this guide.
- Data minimisation - We will only collect data which is necessary for us to provide a service to you and will delete data when it becomes out of date.
- Accuracy - We will ensure that any personal data we collect is correct and up to date.
- Storage limitation - We will keep only what’s necessary in line with our Data Retention Schedule.
- Integrity and confidentiality - We will ensure we have appropriate security to protect the data we process about you.
This is the Link standard privacy notice. The information on page 6 of this notice contains specific information about how your data will be processed.
We aim for this privacy notice to be clear but comprehensive and provide you with all the information you need to understand how we will manage your data.
What is Data?
Personal data means any identifiable information about a living person. This can include:
- Telephone Number
- Date of Birth
- Tenancy Reference Number
- National Insurance Number
- Special categories of personal data are defined as personal data relating to a person’s:
- Racial or ethnic origin
- Political opinions
- Religious or other beliefs
- Trade Union membership
- Sex life or sexual orientation
- Genetic or biometric data used to uniquely identify a person
Link is a controller of your personal data. This means that we decide the purpose and conditions of processing of your personal data.
Any supplier, contractor or other third party with whom we share data is called a processor.
What are the conditions of processing?
The conditions of processing are basically the legal reasons for processing your personal data. We have to make it very clear why we process your data. In processing your personal data or special category personal data, Link will rely on one or more of the following conditions of processing, depending on what we are using your personal data for:
For Personal Data
Consent - You have given your consent to the processing of your personal data.
Contractual - Processing of personal data is necessary for the performance of a contract with you or for Link to take pre-contractual steps at your request.
Processing of personal data is necessary for Link to comply with a legal obligation.
Processing of personal data is necessary to protect your vital interests or another individual's vital interests (this means life or death situations).
Processing of personal data is necessary for the performance of a task carried out in the public interest or in the exercise of official authority conferred on Link
Processing is necessary for Link's legitimate interests or a third party's legitimate interests, unless these interests are overridden by your interests or fundamental rights.
For Special Categories of Personal Data
You have given your explicit consent to the processing of your personal data.
Processing is necessary for carrying out obligations under employment, social security or social protection law.
Processing is necessary to protect your vital interests of or another person's vital interests where the data subject is physically or legally incapable of giving consent.
Processing is necessary for the establishment, exercise or defence of legal claims.
Processing is necessary for reasons of substantial public interest, under law.
Medical Diagnosis and Treatment
Processing is necessary for the purposes of the provision of health or social care or treatment or the management of health or social care systems.
You have a number of rights under the Data Protection Legislation which are outlined and explained below.
The right to be informed how your personal data is processed
This guide informs you how your data will be processed and sets out clearly Link's lawful basis for processing.
The right to access your personal data
You can submit a Subject Access Request to access the personal data that Link holds about you. You can do this by writing to:
Data Protection Officer
2c New Mart Road
Or e-mailing: email@example.com
Link will then have 30 days to respond to your request. As part of the subject access request process we will ask for two forms of identification to be submitted before any information is released.
The right to rectification - If any of the personal data we hold about you is wrong, you have the right to ask us to correct it.
The right to erasure - You may request that Link erase any of your personal data that is processed by us. This is also known as the ‘right to be forgotten’. Please note that this is subject to a number of exemptions and so is not an absolute right.
The right to restrict processing - If you believe that we are processing personal data unlawfully, where it is no longer needed or think that the personal data held is inaccurate you can ask us not to process that personal data.
The right to data portability - If you wish to move to another landlord, you can ask us to pass on the personal data we hold about you to the new landlord, where you have provided that personal data to us and we have been processing it to perform a contract with you.
The right to object - You have the right to object to our processing of your personal data. However, if Link can demonstrate that there is an appropriate ‘condition of processing’ in place then we may refuse to stop processing your personal data.
Rights in relation to automated decision-making and profiling - You have the right not to be subject to a decision solely based on automated processing. If a decision is made by an automated process you may ask Link to have the decision investigated by a member of staff.
How to action your rights under the Data Protection Legislation
If you wish to object to the use of your personal data, would like to restrict processing or have data rectified, please contact the Strategy and Business Support Team by e-mailing firstname.lastname@example.org.
The right to complain to the ICO
If you have a concern about the way Link is processing your personal data, you may raise a complaint with the Information Commissioner’s Office.
Information Commissioner's Office
0303 123 1113
We will never share or sell your personal data to a third party for marketing purposes.
Electronic information that contains personal information is kept in secure systems. Laptop computers and other devices which may be taken out of the office are encrypted and password protected. Any paper files containing personal information are stored in locked filing cabinets.
We are the only charity in Scotland with a focus on the provision of small grants to help social housing and community-based projects. Since 1979, we have given out over £1 million in grants to thousands of housing related projects to help people suffering disadvantage in social housing.
Our funds are generated through fundraising activities and events; donations, individuals and commercial companies, sponsorship from business partners and the provision of a fund management service with a focus on reporting on social impact.
What data we need
To allow us to provide the service you would expect from us, we process the following information about you:
- Telephone number
- E-mail address
Why we need it
We need your information and will use your information:
- to undertake and perform our obligations and duties to you in accordance with our compliance to the Charities and Trustee Investment (Scotland) Act 2005
- to enable us to supply you with the services and information which you have requested
- to analyse the data we collect so that we can administer, support and improve our business and the services we offer
- to assess the impact of our work and influence future decisions
- to contact you in order to send you details of any changes to our services which may affect you
- for all other purposes consistent with the proper performance of our operations and business
- to contact you for your views on our services.
Where we store your data
Your data will be stored electronically on laptop or desktop computers which are password protected and encrypted. Paper files will be stored in locked cabinets.
How long we will keep your information
We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you.
We will generally keep your information for the following minimum periods after which this will be destroyed if it is no longer required for the reasons it was obtained.
|Grant feedback information
|Project photographs(for website)
|Project case studies(for website)
|Records of donations received
|Email mailing list
||Until advised otherwise
|Trustee contact information
Our full retention schedule is available at the Link website.
What’s the legal justification?
Condition of Processing
Grant application forms
Grant feedback information
Project photographs(for website)
Project case studies(for website)
Records of donations received
Email mailing address
Trustee contact information
Sharing your Information
The information you provide to us will be treated by us as confidential.
We may disclose your information to third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:
Link Group Finance
Receiving data about you
We may receive the following information from third parties:
Payments made by us to you
Payments made by you to us
Information obtained with regards to grant application background checks
Complaints or other communications regarding behaviour or other alleged breaches of the terms of your contract with us
Updating your information
If your details change, please contact Kate Christie on 01324 466873 to inform us, to ensure that all of the information we hold about you is up to date.