In this document the expression ‘we’ or ‘Pennaf Group’ refers to Pennaf Limited (which also trades as Offa Property Management), Clwyd Alyn Housing Association Limited, Tir Tai Limited and Ty Glas Housing Society Limited, that provides housing and related services across North Wales.
Pennaf Ltd is the parent of Clwyd Alyn Housing Association Limited, Tir Tai Limited and Ty Glas Housing Society Limited.
Each entity is the controller of its own personal data although data may be processed by other Group members on its behalf
This privacy notice sets out how the Pennaf Group collects and uses information about you.
Please read this privacy notice carefully to understand how we will use your personal information. If you have any questions or queries in relation to this privacy notice, you can contact our Data Protection Officer at:
72 Ffordd William Morgan, St Asaph Business Park, St Asaph, Denbighshire, LL17 0JD
0800 1835757 (freephone from a landline) or 01745 536800
This privacy notice explains:
What information we may collect about you
How we use your information
Sharing your information
Our legal basis for collecting, holding and using your information
Security and storage of your information
1.What information we may collect about you
The information we collect about you depends on why we are dealing with you. For example, if you make a housing application or become one of our tenants, we will need more information from you than if you are merely making an enquiry.
We may collect the information about you in the following circumstances:
If you call our Contact Centre
When you call our contact centre we collect Calling Line Identification (CLI) information. We use this information to help improve its efficiency and effectiveness.
We record calls for training and monitoring purposes. Additionally, our call handlers will make a record of your call in order to manage your query. We may need to share information with other organisations within or outside Pennaf Group in order to respond to your call, for example so that we can organise maintenance or repairs or other support. We will usually tell you if it is necessary for us to pass information on to other organisations.
If you email us
Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
If you make a complaint to us
When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. If a complainant doesn’t want information identifying him or her to be disclosed to any person that the complaint is about, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
If you use our services
We hold the details of the people who request and use our services so that we can provide these services and for other closely related purposes. For example, we use information about our service users to develop and improve our services and to make sure we are delivering services to different groups fairly.
If you apply for housing or become a tenant, there is certain information that we require in order to process your application and manage your tenancy. If you do not provide us with this information, we will not be able to progress your application.
When you visit our websites
Information we receive from others
We work closely with other organisations, such as local councils, police forces, voluntary sector organisations, other housing providers and our contractors, and we may receive information about you from them.
If you visit our premises
We may ask you to sign in and out if you visit staff or residents at our premises. Access is controlled for the purposes of building and occupant security. Access is recorded to assist with fire and other evacuation procedures. Furthermore, your image may be captured on CCTV to monitor and collect visual images for the purpose of security and the prevention and detection of crime.
If you use our Wi-Fi or computer to access our IT systems, access and activity may be monitored to prevent misuse of Group property, according to our IS Corporate policies.
When individuals apply to work for us, we will only use the information they supply to us to process their application and to monitor recruitment statistics. Where we want to disclose information to a third party, for example where we want to take up a reference or obtain a ‘disclosure’ from the Criminal Records Bureau we will not do so without informing them beforehand unless the disclosure is required by law.
Personal information about unsuccessful candidates will be held for 12 months after the recruitment exercise has been completed; it will then be destroyed or deleted. We retain de-personalised statistical information about applicants to help inform our recruitment activities, but no individuals are identifiable from that data.
Once a person has taken up employment with us, we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once their employment with us has ended, we will retain the file in accordance with the requirements of our retention schedule and then delete it.
If you are a member of one of our Boards, Committees or Panels
We may ask for personal details for managing and statistical purposes.
2.How we use your information
We process your personal information primarily in connection with managing our housing services. If you are a tenant, this includes managing your tenancy and dealing with any applications, queries or complaints that you make.
Examples of how we use your information include:
to confirm your identity
to assess your suitability to access any of our services
to manage your tenancy, care or support
to ensure our properties are appropriately maintained and in accordance with legal obligations, such as periodic gas safety checks
to notify you about important changes to our services
to let you know about other relevant services, both ours and those of other parties whose products and services we have agreed should be made available to you (see the section below on 'Contacting you' for more information about this)
to update and correct our records
to carry out statistical and market analyses, including benchmarking exercises, to enable us to understand you better and improve our services, and in accordance with our operating Regulations
to develop, test and improve our systems
to ensure that content of our website is presented in the most effective manner for you and for your computer
to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
to comply with other legal obligations, such as Health and Safety laws or safeguarding vulnerable people
We may combine information we receive from other sources with information you give to us for the purposes set out above (depending on the types of information we receive).
We will use your contact information to send you important information via letters, emails, text messages, or otherwise to telephone you. We may record telephone calls for security and training purposes.
We may use the information we hold about you in order to provide you with information about our services which we feel may interest you.
You can opt out of receiving marketing communications at any time, although please note that we will continue to send you important messages about your tenancy.
If you have changed your mind about being contacted for marketing purposes, please contact our Customer Services Team on 0800 1835757 (freephone from a landline) or 01745 536800 to update your preferences.
4.Sharing your information
We do not sell your information to any third party, but in certain limited circumstances we may disclose your personal information to:
any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 736 of the UK Companies Act 1985; and/or
other third parties in the following circumstances:
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation;
in order to enforce or apply our terms and conditions and other agreements;
to protect the rights, property, or safety of Pennaf Group, our customers, or others;
to investigate or prevent a crime. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
to obtain any professional advice; and/or
with your consent.
5.Our legal basis for collecting, holding and using your information
Data protection law sets out various lawful legal bases (or ‘conditions’) which allow us to collect, hold and use your personal information:
Where you have entered into a contract or contracts with us, we may need to use your information to provide you with our services. An example of this is where you have a tenancy with us.
Where we are under a legal obligation which requires us to process your personal information. For example, notifications of Health and Safety incidents.
We will sometimes use your personal information based upon your consent. We will always tell you where this is the case and ask you to agree before we process your information. An example of using your personal information with your consent is publishing your image as part of a photograph on our website.
Finally, sometimes it is necessary to process your personal information for the purposes of our own legitimate interests. We will only do so where these interests are not overridden by the interests and fundamental rights or the freedoms of the individuals concerned. An example of this is when we may contact you about your experience of contacting our Customer Services Team or a recent repair to your property.
Data protection law recognises certain "special categories" of personal information, which is information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information for uniquely identifying a person, information concerning health, and information concerning a person's sex life or sexual orientation. Information about criminal offences and records is placed in a similar category.
These special categories of personal information are considered particularly sensitive and so we will only collect and use this information where you have given us your explicit consent or where we consider it necessary to do so.
6.Security and storage of your personal information
The information about you that we collect may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for one of our suppliers.
We will generally keep personal information about you no longer than is needed for as per our Retention Policy.
You have the right to request from us access to your own personal information. This is sometimes known as a 'subject access request'.
You also have the right to ask us not to process your personal data for direct marketing purposes. We will tell you if we intend to use your data for this purpose or if we intend to disclose your information to any third party for this purpose. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data or by contacting our Customer Services Team on 0800 1835757 (freephone from a landline) or 01745 536800.
From 25 May 2018, you will have additional rights to request from us:
That any inaccurate information we hold about you is corrected
That your information is deleted
That we stop using your personal information for certain purposes
That your information is provided to you in a portable format
That decisions about you are not made by wholly automated means
Many of the rights listed above are limited to certain defined circumstances and we may not be able to comply with your request. We will tell you if this is the case.
If you choose to make a request to us, we will aim to respond to you within one month. We will not charge a fee for dealing with your request.
If you are dissatisfied with how we are using your personal information or if you wish to complain about how we have handled a request, then please contact our Data Protection Officer as below and we will try to resolve any issues you may have.
72 Ffordd William Morgan St Asaph Business Park St Asaph Denbighshire LL17 0JD
0800 1835757 (freephone from a landline) or 01745 536800
You also have the right to complain to the Information Commissioner's Office, which is the statutory regulator for data protection law. Details of how to complain to the ICO can be found at https://ico.org.uk/concerns/.