RBH Privacy Statement
RBH processes various types of information, including information that identifies you as an individual (“Personal Information”) when you are accessing or using our services, employed or volunteering with RBH or interact with us in other ways.
We know you care about how your personal information is used and shared, and we take your privacy seriously. RBH uses several ways to provide you with information about how it treats your information. This Privacy Statement gives extra detail on top of the Privacy Notices we already provide when you directly access an RBH service or business area.
Before collecting your personal information, RBH will normally present you with a Privacy Notice specific to the information we are collecting at that time. Privacy Notices include details such as what our legal basis is for processing that information, how long we will keep it on record and who we might share it with. The Privacy Notice is specific to a particular activity within RBH. However when accessing the RBH Website, RBH Contact Centre or an RBH neighbourhood or offices covered by CCTV the privacy information we are able to provide at the time is limited. For this reason more information on these activities is provided here:
- Information You Provide to Us: You do not have to provide any Information in order to use the website. However access to certain sections and features of the Website are dependant upon the provision of information and without that information we may be unable to provide such access or features. You may be asked to provide Information such as a valid e-mail address and/or your name and address.
- Information we Automatically Collect: We may automatically collect and store the following Information about you: your Internet Service Provider (ISP), your IP address, your web browser type and version, the number of colours your screen is displaying, your operating system, the URL you clicked to get to the website, time/ date, http accept string (e.g. mime data types that the browser accepts), the locale setting of the computer/ browser and any other data made available by your browser. RBH is unable to identify individuals with this information alone.
- How we use the information: We will use the information we collect via our Websites:
- To administer our Website, our events and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
- To improve our Website to ensure that content is presented in the most effective manner for you and your computer;
- Analyse customers’ use of the Websites for trend monitoring purposes (not individuals);
- For purposes made clear to you at the time you submit your information – for example, to process a data subject request or complaint.
- As part of our efforts to keep our Website safe and secure.
- Who we share your information with: Anonymised information collected maybe used by analysis software such as Google Analytics.
- Information You Provide to Us: RBH needs to confirm your identity when you telephone and to do this may ask you to confirm information relating to your contact details, date of birth, family composition and/or national identification numbers.
Access to certain services is dependant upon the provision of Information and without that information we may be unable to provide such access or features. So you may be asked to provide the information in the course of your call. This information will depend on the service you are trying access. If you haven’t already been notified of this processing when you started a tenancy with RBH, then you should be provided with an additional privacy notice at that stage. RBH is not required to provide you with privacy information more than once.
- Information we Automatically Collect: Calls made to RBH may be recorded and/or monitored. This does not include any debit or credit card details used for making payments.
- How we use the information: We use the information you provide to the Contact Centre to communicate with you via email, letter or telephone and, possibly, by other means, regarding provision of RBH services and events we think may be of interest to you. These RBH services have their own privacy notices which will be presented to you at the first point your personal information was collected. Recordings may also be used for the purposes of training Contact Centre employees, as evidence for legal and or insurance claims and/or identifying behaviour which could pose a risk to RBH employees.
- How long we keep this information: Call recordings will normally be kept for 6 months unless they are required for an insurance claim or legal purposes. In the case of an insurance or legal claim the recording may be kept for 6 years following settlement of the claim.
- Who we share your information with: Normally call recordings will not be shared outside of RBH. In the case of legal or insurance claims, information may be shared with RBH’s insurer and the elements of the UK legal system.
- Information You Provide to Us: If you request CCTV footage of yourself recording by the RBH CCTV network RBH will need to confirm your identity. RBH may ask for photo ID, address and descriptions of clothing or vehicle details to help identify you on our recordings.
- Information We Automatically Collect: CCTV footage across our neighbourhoods, customer access points and temporary emergency accommodation is recorded and securely held on our Network Video Recorders (NVR). RBH cameras are not directed into the homes of individuals unless required to do so by law enforcement agencies.
- How we use the information: Images recorded are used for the prevention and detection of crime and disorder. Images may be provided to yourself upon request. Images of any third party data subjects will be obscured to protect their rights. Accesses to these images are restricted to trained and licenced personnel.
- How long we keep this information: Images are stored for up to 31 days on all our recorders. After 31 days, the data is automatically overwritten with new data. Any footage produced for further investigation is kept for 12 months to allow for further copies to be produced.
- Who we share your information with: Recordings may be shared with authorised employees, Law enforcement agencies and the Local Authority.
RBH applies the GDPR six plus principles (EU GDPR Art 5.) when processing all personal information. These state that personal information will be:
- processed lawfully, fairly and in a transparent manner
- collected for specified, explicit and legitimate purposes
- adequate, relevant and limited to what is necessary in relation to the purposes i.e. data minimization
- accurate and kept up to date
- kept for no longer than is necessary
- processed securely
The “plus” is that RBH is accountable for, and can demonstrate compliance with, the six principles above.
We collect, process and store your information to allow you to access and use RBH services. We will only do this when we have a specific purpose and legal basis to do so. The types of information we may collect will vary depending on which services you wish to use. In some cases we may be provided with some of your personal information from a third party (in these cases it is usually from a public authority). In some instances we may share your information with a third party (see below for more information). We will never sell your personal information.
When we collect your personal information we will provide you with a Privacy Notice which explains:
- What personal information we’re collecting
- Why we need it
- Our legal basis for processing it
- Any information that has been provided to us by a third party
- Who we may need to share it with
- How long we will keep it for
- How to contact us or make a complaint
- What your data subject rights are
The information in Privacy Notices is supplemented with this Privacy Statement.
Once we have provided you with information about how we process your information, we are not required to provide it yo you again. However if you have forgotten or have some questions you can use the contact details provided at the end of this Privacy Statement to get in touch with us.
We do not rent or sell your Personal Information to anyone. However to deliver certain services we may share and disclose information (including Personal Information) about our customers, employees and other stakeholders.
The types of organisation that we may need to share your information with are:
- One or more of our contracted suppliers to help us deliver one or more of our services,
- One or more of our partners who have aims and objectives which are either similar or complementary to ours.
- One or more Public Authorities where the sharing of personal information is set out and required by law, for example with the Police or the Department for Work and Pensions (DWP).
For (a) and (b) above RBH first conducts checks to ensure suppliers and partners meet our strict criteria for data processing and that they too are compliant with data protection law. Sharing cannot begin until the checks are satisfactorily completed and a written agreement is in place setting out the responsibilities of each party. Sharing arrangements are monitored for effectiveness on an ongoing basis.
The Privacy Notices we provide you with will tell you who we may share your personal information with.
We use a wide range of security measures to protect your personal information. This includes restricting access to your personal information, training our employees and conducting regular checks.
Unfortunately, no organisation or service can guarantee complete security. In the event of a breach of our data protections procedures RBH employees are trained to take steps to fix the situation and minimise the damage caused. Where there is a serious breach you will be informed.
You must take care to prevent unauthorized access to your account and personal information by not sharing any information about your account with anyone else. If accessing RBH services online, ensure your operating system and Internet browser are updated with relevant security patches. The use of other security products can help improve your online security.
We will only keep your personal information as long as is necessary and legally allowed. How long we keep it for depends on what type of personal information it is and how we have used it. For each particular instance we will provide the retention period on the Privacy Notice at the point we ask to collect your information. Examples of why we keep personal information are: needing to get in touch with and providing services to our customers, for insurance purposes, to be able to respond effectively to any legal action. We will not keep your information just in case we might need it for a purpose yet to be determined.
The EU General Data Protection Regulation 2016 gives you certain rights which you can exercise by:
- Going to www.rbh.org.uk/DataProtection
- Calling the RBH Contact Centre and asking to exercise your data subject rights: 0800 027 7769
- Writing to or emailing the RBH Data Protection Officer (DPO):
4. Contacting the Information Commissioner’s Office (ICO) www.ico.org.uk/global/contact-us/
- To exercise your data subject rights with RBH you will be asked to which right you would like to exercise and to give details of how you would like to exercise it.
- You will also be required to provide proof of identification.
Your data protection rights are as follows:
You have the right to be informed about the collection and use of your personal information. This is important for transparency. This is why we provide you with a Privacy Notice at the time we collect your personal data from you. We provide more information about this in Section 4. above “RBH’s Approach to Processing Personal Information”. There are a few circumstances when we do not need to provide people with privacy information, such as if you already have the information or if it would involve a disproportionate effort to provide it to you. The information we provide to you must be concise, transparent, intelligible, easily accessible, and it must use clear and plain language. We will regularly review, and where necessary, update the privacy information we provide to you.
This gives you (the data subject) the right to obtain from RBH confirmation as to whether or not your personal data is being processed and, where that is the case, access to the personal data and the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored or, if not possible, the criteria used to determine that period;
- the existence of the right to request from RBH rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing;
- the right to lodge a complaint with the Information Commissioner’s Office (ICO);
- where the personal data is not collected directly from you, any available information as to its source;
- the existence of automated decision-making, including profiling and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
RBH will provide a copy of the personal data undergoing processing free of charge. For any further copies you request, RBH may charge a reasonable fee based on administrative costs. Where you make the request by electronic means, and unless otherwise requested, the information shall be provided in a commonly used electronic form – e.g. Microsoft Word, Microsoft Excel or PDF.
When providing access to this information RBH will ensure the rights and freedoms of others data subjects are not breached.
You have the right to request RBH erase personal data concerning you without undue delay. RBH will erase your personal data without undue delay where one of the following grounds applies:
- your personal data is no longer necessary in relation to the purposes for which it was collected / processed;
- you withdraw consent on which the processing is based and where there is no other legal ground for the processing;
- you object to the processing and there are no overriding legitimate grounds for the processing.
- your personal data has been unlawfully processed;
- your personal data has to be erased for compliance with a legal obligation;
If RBH made your personal data public, it shall take reasonable steps to inform other controllers which are processing your personal data that you have requested the erasure of your personal data.
The right does not apply when processing is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation or for the performance of a task carried out in the public interest or in the exercise of official authority vested in RBH;
- for reasons of public interest in the area of public health;
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in so far as the right is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- for the establishment, exercise or defence of legal claims.
You have the right to obtain from RBH, the restriction of processing where one of the following applies:
- you contest the accuracy of your personal data RBH is processing, for a period enabling RBH to verify the accuracy of the personal data;
- the processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead;
- RBH no longer needs the personal data for the purposes of the processing, but you require it for the establishment, exercise or defence of legal claims;
- you have objected to processing pending the verification whether the legitimate grounds of the RBH override yours.
RBH will inform you before the restriction of processing is lifted.
You have the right to receive your personal data which you have provided to RBH, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without hindrance from RBH, where:
- the processing is based on consent,
- the processing is based on a contract; or
- the processing is carried out by automated means.
At any time you can object to RBH processing your personal data when the legal basis for such processing is either:
- necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- necessary for the purposes of RBH’s legitimate interests.
On receipt of such a request RBH shall no longer process the personal data unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. Where your personal data is processed for direct marketing purposes, you have the right to object at any time. This includes profiling to the extent that it is related to the direct marketing. In such instance RBH shall no longer process your personal data in question for such purposes.
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similar significant effects.
This does not apply however if the processing:
- is necessary for entering into, or performance of, a contract between the you and RBH;
- is authorised by law; or
- is based on your explicit consent.
For points (a) and (c) above, RBH has suitable measures to safeguard your rights and freedoms and legitimate interests. You have the right to obtain human intervention on the part of RBH, to express your point of view and to contest a decision.
Your rights In relation to Third Parties
RBH will communicate any rectification or erasure of your personal data or restriction of processing carried out to each recipient to whom your personal data has been disclosed, unless this proves impossible or involves disproportionate effort.
You have the right to make complaints about the processing of your personal information. This includes the right to make an appeal. You can use the RBH Complaints Procedure or for employees, the RBH Grievance Procedure. Submit a Complaint
You also have the option to complain to the Information Commissioner’s Office (ICO). The ICO is the UK’s independent authority set up to uphold information rights in the public interest and promote openness by public bodies and data privacy for individuals. You can contact the ICO to report a concern or a breach here.
RBH does not share Personal Information internationally.
RBH takes extra care when collecting information directly from children. Particularly if there is the intention of creating a profile and/or for marketing, RBH will include a mechanism for obtaining the consent of the holder of parental responsibility, except where if the service relates to counselling or preventative services. For the purposes of processing personal information you are no longer considered a child once you have reached the age of 13. If you believe a child under the age of 13 may have provided RBH with personal information without RBH’s knowledge please contact us at DPO@rbh.org.uk.
If you have any questions about this Privacy Statement or any matter related to the way RBH processes your personal information you can contact us via our Data Protection Officer using one of the methods below:
Telephone: 0800 027 7769 (and ask to speak with the DPO)
Alternatively you can contact the Information Commissioner’s Office (ICO). The ICO is the UK’s independent authority set up to uphold information rights in the public interest and promote openness by public bodies and data privacy for individuals.
RBH and its subsidiary companies are registered with the ICO under the following references:
- RBH – Reg No Z3003566
- RBH Design and Build – Reg No Z3003597
- RBH Professional – Reg No Z300357X
- Safegard Security Solutions Limited – Reg No Z2343929
For more information on data protection legislation and related matters please visit the ICO's website at www.ico.org.uk