Housing Repairs Service Privacy Policy

Data related to the Housing repairs online service ("the website") is processed for Camden (the "Data Controller", "We", "Our", "Us"). The Data Controller may collect personal and non-personal information or data about you when you use this website or the services available from this website, and both the Data Controller and any authorised Data Processors (see "Data Sharing Agreements" below) are committed to protecting and respecting your data privacy.

The Data Controller is registered with the Information Commissioner's Office (ICO) under the UK Data Protection Act of 2018. This Privacy Policy (together with any documents or linked content referred to herein) sets out the basis upon which the personal data We collect from you, or which you provide to Us, will be processed and stored.

Personal data we collect

To use the Housing Repairs Service, We may need your personal information, including your name, address, email address, phone number and mobile number if you provide it to Us. We will also collect technical information such as your IP address, and details of which version of the web browser you use, which web pages you visit within the Housing Repairs Service and how you interact with the service. We will not collect any personal data which is not necessary for you to benefit from using our Housing Repairs Service.

Providing images

You have the option of sharing an image of your repair issue. As per the guidance in the application, you should not provide an image that contains any personally identifiable information (images with people’s faces present, images of credit cards, bank statements etc). In the event that you accidentally upload a picture containing personally identifiable information, contact us immediately. We will take action immediately to remove or redact the information.

These images will be securely stored in Amazon S3. Any images supplied will be securely transmitted to the data controller or any third parties responsible for the delivery of housing repairs. This is to ensure the protection of your data and comply with privacy regulations.

By uploading an image of your repair issue, you are providing your consent for the uploaded images to be securely stored in Amazon S3.

Sensitive personal data

The UK Data Protection Act 2018 specifies a set of personal data categories which are considered to be “sensitive”, and which require special consideration by Data Controllers. This website, and any services available from this website, do not knowingly collect or process any sensitive personal data. If you become aware of any sensitive personal data which has been submitted using the Housing Repairs Service, please contact the Data Controller immediately so that appropriate action can be taken.

Children's personal data

This website, and any services available from this website, are not directed to children under the age of 16. If you become aware of any children’s personal data which has been submitted using the Housing Repairs Service, please contact the Data Controller immediately so that appropriate action can be taken.

Where we process and store this information

We will securely store your personal data on secure servers, located within the UK and the European Union (see Data Sharing Agreements section below). By using this Housing Repairs Service, you are providing your consent to this. Both the Data Processor and any sub-processors used are subject to industry standard due diligence, including information security and data protection commitments, and the deployment of technical controls to safeguard information and enable the highest possible levels of data privacy.

Transmitting information over public internet connections is not secure, and the Data Controller cannot guarantee or be held responsible for the security of personal data you provide to Us until the point at which it is securely stored within Our systems. Any personal data you transmit is at your own risk. Your personal data provided into the Housing Repairs Services will be retained for a period of six years following the end of your tenancy. After this period, the personal data will be securely and permanently deleted, unless:

Your personal data or any images you upload to the Housing Repairs Services will be retained for a period of six years following the end of your tenancy. After this period, the personal data will be securely and permanently deleted, unless:

1. You have provided Us with your consent for it to be retained for a longer period, or
2. You have already requested that We delete your personal data, and We have accepted and confirmed the completion of your request
3. There are legal reasons why your personal data needs to be retained for a longer period, and We have notified you of this

Data sharing agreements

The Data Controller uses the following Data Processors to help deliver the Housing Repairs Service, and confirms that each is subject to formal contractual agreements to ensure the security and privacy of data which is collected, processed and stored by the service:

• Made Tech Ltd of 4, O’Meara Street, London, SE1 1TE UK. Made Tech provides and maintains Housing Repairs Service (software) on Our behalf. They act as a Data Processor, and are registered with the ICO (registration number ZA490749). Made Tech’s services are delivered from the United Kingdom only.
• Amazon Web Services (AWS) - selected and used by Made Tech for the secure deployment and hosting of their cloud services, and who in turn process personal data under Standard Contractual Clauses (SCCs) which are acceptable under the UK Data Protection Act 2018. Data is stored within the UK in AWS’s European Region (London) .
• Google Analytics - selected and used by Made Tech for the analysis of user behaviour and who in turn process personal data under Standard Contractual Clauses (SCCs) which are acceptable under the UK Data Protection Act 2018.
• Hotjar - selected and used by Made Tech for the analysis of user behaviour and who in turn process personal data under Standard Contractual Clauses (SCCs) which are acceptable under the UK Data Protection Act 2018. The data is geographically located in the AWS European Region (Ireland).
• NEC Software Solutions UK is Camden’s housing management database platform. It stores personal data about Camden’s tenants such as tenant name, property address and contact details.
• Rapid Information Systems connects to the NEC database and enables housing staff to view tenant data records.
• ROCC Limited provides Camden’s housing maintenance software suite. Tenant contact details are captured before a repair is raised.
• Talkative Limited provides chat functionality for repairs. Residents must provide their name, email and phone number to access this service.

We will not share your personal information with any other organisations for marketing, market research or commercial purposes, or with any other websites without having your prior and express consent for Us to do so.

How we use your personal data

We will collect and use your personal data and related technical data to:

• Enable you to use the Housing Repairs Service, for the purposes of repairing, maintaining and adapting your property.
• Respond to any questions, enquiries or feedback you may send to Us in relation to the Housing Repairs Service.
• Complying with Our legislative and regulatory obligations.
• Tracking expenditure and checking the quality of our Housing Repairs Service.
• To train and manage the employment of our personnel who deliver the Housing Repairs Service for you.

Legal basis for processing personal data

Under the UK Data Protection Act of 2018, we are required to confirm the “legal bases” for the processing of your personal data. These are as follows:

• Delivery of a Contract with the Data Subject: where We have a contract in place with you (e.g. a tenancy agreement) which includes Our responsibilities for the management of housing repairs.
• Consent: if you have provided Us with your consent to process and store your personal data for specific purposes. You have the right to amend or withdraw your consent at any time - see 'Your Rights' section below.
• Legitimate Interest: We have a legitimate interest in helping ensure that We deliver accurate content and secure services which are valuable to Our users.

We do not share your personal information with any other organisations for marketing, market research or commercial purposes, or with any other websites without having your prior and express consent to do so.

Your rights

Under the UK Data Protection Act 2018 you have a number of important rights which can be exercised free of charge. In summary, those include rights to:

• Access your personal data and to certain other supplementary information that this Housing Repairs Service Privacy Policy has recorded.
• Require Us to correct any mistakes or correct any omissions in any of the personal information which We hold.
• Require the erasure of your personal data in certain circumstances.
• Receive the personal data concerning you which you have provided to Us, in a commonly used format and have the right to transmit such data to a third party in certain circumstances.
• Object at any time to the processing of your personal data for direct marketing activities (note: We do not use your personal data for marketing purposes)
• Object to decisions being taken by automated means (where applicable) which could produce legal effects concerning or affecting you.
• Object in certain specific situations to the continued processing of your personal data by the Data Controller.

For further information on each of those rights, including the circumstances in which they apply, please see guidance on the ICO website (www.ico.org.uk)

If you would like to exercise any of those rights, please:

• Contact the Data Controller's Data Protection Officer, using the contact details below.
• Provide Us with sufficient information to properly identify you.
• Provide Us with proof of your identity/address, when we request it.
• Provide Us with the specific information to which your request relates.

Website cookies

This Housing Repairs Service website uses cookies. We use both session-based and persistent cookies, dependent upon how you use or interact with this website, to:

Cookies are small text files sent by Us to your computer, or from your computer or mobile device to Us each time you visit Our website. They are unique to you or your web browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them, or until they expire.

We use cookies which are not specific to your account but are unique and allow Us to undertake website analytics and customisation, among other similar things. If you decide to disable some or all cookies, you may not be able to use some of the functions on Our website. We may use third-party cookies, for example Google Analytics, and you may choose to opt-out of third party cookies directly from the providers’ respective websites.

• to understand visitors' use of Our website, and
• to analyse Our website traffic.

External links

This website may include relevant hyperlinks to external websites not controlled by the Data Controller. Whilst all reasonable care has been exercised in selecting and providing any such links, you are advised to exercise caution before clicking any external links. We cannot guarantee the ongoing suitability of external links, nor do We continually verify the safety or security of the contents which may be provided to you. You are advised, therefore, that your use of external links is at your own risk and We cannot be responsible for any damages or consequences caused by your use of them. Should you identify any issues with external links please contact the Data Controller immediately so that appropriate action can be taken.

Changes to this Privacy Policy

We may change this Housing Repairs Service Privacy Policy from time to time, and if We do We will post any changes on this page. If you continue to access this website or use services available from this website after those changes have come into effect, you will have agreed to the revised policy.

How to complain

We trust that We will be able to promptly resolve any query or privacy concern you raise about Our use of your personal information whilst using Our Housing Repairs Service. See the “Contacting Us” section below if you would like to get in touch. The UK Data Protection Act 2018 also gives you the right to lodge a complaint with the applicable supervisory authority. The supervisory authority in the United Kingdom is the Information Commissioner’s Office (ICO) who may be contacted at http://ico.org.uk/concerns/ or by telephone on 0303 123 1113. Please note that the ICO will not progress a complaint until you have given Us an opportunity to investigate and resolve your concerns.

Contacting us

All questions, comments and requests regarding this Privacy Notice should be addressed to our Data Protection Officer by email at DPA@camden.gov.uk

This version last updated: 06/02/2023