Non Violentiam CIC Privacy Notice
What this notice covers
Non Violentiam CIC is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you, in accordance with the General Data Protection Regulation (GDPR) and data protection legislation.
Identity of the data controller
Non Violentiam CIC is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This notice does not form part of any contract of an offer of accommodation, goods or other contracts to provide services. We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice(s) we may provide in the future, so that you are fully aware of the detail and rationale in relation to us using such information when collecting or processing personal information about you.
Categories of personal data we process
We will collect, store, and use the following categories of personal information about you:
personal contact details, for example - name, title, addresses, telephone numbers, personal email addresses, date of birth, gender, marital status, dependents, etc
next of kin and emergency contact information
National Insurance number
bank account details, (in relation to service charges, as applicable)
salary details, pension and benefits information including Housing Benefits information
payment dates, working hours
copy of driving licence or other relevant form of recognised ID
information obtained through electronic means such as swipecard records and biometric means of identification
details in relation to your use of our information and communications systems
information about your race or ethnicity, religious beliefs, sexual orientation and political opinions
information about your health, (including any medical condition(s), health and sickness records and details of any disabilities for which we may need to make reasonable adjustments)
genetic information and biometric data
information about criminal convictions and offences
Sources of personal data
We collect personal information about you through the application and assessment process, either obtained directly from you, from an external supporting agency or from a background check provider. We may, on occasion, collect additional information from third parties including former housing providers and reffering agencies.
We also collect additional personal information during the course of support-related activities throughout the period you are supported by us.
Our lawful basis for processing your data
We will use your personal information in the following circumstances:
where we need to perform the contract we have entered into with you, offering supported accommodation
where we need to comply with a legal obligation
where it is necessary for our legitimate interests or those of a third party and your interests and fundamental rights do not override those interests (safeguarding).
Our purposes for processing your data:
making a decision about your offer of accomodation
determining the terms on which you engage with us
checking you are legally entitled to housing and benefit support in the UK
collection of service charges
positive support outcomes
liaising with your managing agency and support team
administering the contract we have entered into with you
business management and planning, including accounting and auditing
conducting performance reviews, managing performance and determining performance requirements
making decisions about reviews
assessing qualifications for a particular job or task,
gathering evidence for possible grievance complaints
making decisions about your continued engagement of support
making arrangements for the termination of accomodation offer or any contract you have with us
education, training and development requirements
dealing with possible legal disputes involving you, or employees, workers and contractors, including accidents and incidents and inappropriate behaviours
managing sickness and / or missed support appointments
complying with health and safety obligations
to prevent fraud
to monitor your use of our information and communication systems to ensure compliance with our IT policies
to ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution
to conduct data analytics studies to review and better understand employee retention and attrition rates
equal opportunities monitoring
some of the above grounds for processing will overlap and there may be several grounds that justify our use of your personal information
Who has access to your data?
We may share your personal information with third parties if required by law or where we have a legitimate interest in doing so.
Recipients of your data may include former housing providers, police, probation, NHS official medical professionals, people whom we obtain reference information from, organisations who carry out background checks, and any regulatory bodies where enhanced checks are required, (DWP, Housing, Birmingham City Council).
When sharing your information with third parties, we will ask that they respect the security of your data and treat it in accordance with the law.
Security of your data
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we will ensure that access to your personal information is limited to those employees, agents, contractors and other third parties who have a business need to access this.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How we decide how long to retain your data?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data. We also consider the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means.
You have the right to:
request access to, and obtain a copy of, your personal information
request edits of the personal information that we hold about you if any of the information is incorrect
request deletion of your personal information
object to the processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground
If you believe we have not complied with your rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
If you do not provide personal data, it is likely to be impossible for Non Violentiam CIC to enter into, or to continue with, any form of accommodation and support relationship with you.
Non Violentiam CIC may make use of electronic automated decision-making systems. We would only do so in the following circumstances:
where we have notified you of the decision and given you 21 days to request reconsideration
where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights
in limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights
decisions are not based solely on automated decision–making.
Changes to this privacy notice
Non Violentiam CIC reserves the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you by alternative means, periodically, about the processing of your personal information.