CUNNINGHAM HOUSE PRIVACY POLICY

This Policy explains when and why we collect personal information about our residents, sponsors, employees, members of the Executive Committee or House Committee, other volunteers, website users, job applicants, donors, Friends and visitors, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

We may change or withdraw this Policy from time to time, so please review it occasionally to ensure that you are happy with any changes. This Policy does not form part of any contract (whether of residence, employment or otherwise) or arrangement with us.

Who are we?

Cunningham House is the operating name of The Abbeyfield Pirbright and District Society Limited, a registered society under the Co-operative and Community Benefit Societies Act 2014 (Number 22478R), an exempt charity and a member of The Abbeyfield Society (we/our/us). Our registered office is at Cunningham House, School Lane, Pirbright, Surrey GU24 0JN.

Any questions regarding this Policy and our privacy practices should be sent to the Chair of the House Committee by email to cunninghamhousepirbright@gmail.com or by post to our registered office.

How we collect your information

We collect information from or about you via a variety of sources, including when you contact us about becoming, apply to become or are a resident, sponsor, employee, member of the Executive or House Committee, volunteer, Friend or visitor, complete one of our forms, call, write, e-mail or meet with us or respond to a survey. We may collect information when you use our website.

We may also take photographs at our events and at Cunningham House to use for general marketing and publicity. However, photographs of individuals will only be used for those purposes with your consent.

We may receive information about you from third parties including:

• Your GP and other medical professionals (physical and mental health information)
• Your council or benefits office relating to your residence at Cunningham House.
• Prior landlords and credit agencies when you apply for residence.
• Welfare or support organisations dealing with you.
• Councillors, MPs or other representatives acting on your behalf/instruction.
• Financial institutions when you apply for residence.
• When we request references or in connection with a DBS check.

What information we collect about you

The information we may collect about you includes:

If you are a resident:

• Full name.
• Date of birth.
• National Insurance number (your unique identifier).
• Contact details (phone, e-mail and correspondence address).
• Details of anyone authorised to act on your behalf (if applicable).
• Other personal information that will vary on a case by case basis, for example to help us resolve breach of tenancy, alleged anti-social behaviour or fraud.
• Disabilities or vulnerabilities. We use this information to tailor our service to better meet your particular circumstances and needs. We may use this information for safeguarding of staff.
• Financial information including to help resolve any rent arrears.
• Physical or mental health information. We may use this information to tailor our service to better meet your particular circumstances or needs and to decide whether or not you are able to continue as a resident. We may use this information for safeguarding of staff.
• Tenancy or guest stay agreement.

If you are a sponsor:

• Full name.
• Contact details (phone, e-mail and correspondence address).
• Details of anyone authorised to deputise as sponsor to act on your behalf if applicable.

If you are an employee:

• Full name (and proof of your identity/photo ID).
• Date of birth
• National Insurance number (your unique identifier).
• Contact details (phone, e-mail and correspondence address).
• Details of next-of-kin.
• Banking details.
• Other personal information that will vary on a case-by-case basis.
• Physical or mental health/sickness information in order to monitor sick leave and take decisions as to fitness for work.
• DBS certificates.
• Immigration status.
• Contracts, appraisals, annual leave records and other personnel records.
• COVID-19 vaccination or exemption status.

 If you are a member of the Executive Committee or House Committee

• Full name.
• Contact details (phone, email and correspondence address).
• Other personal information that will vary on a case-by-case basis.
• DBS reference number and related ID information (which is deleted immediately after use).

If you are a volunteer or Friend:

• Full name.
• Contact details (phone, e-mail and correspondence address).
• If required, DBS reference number and related ID information (which is deleted immediately after use).
• Car insurance details.

If you are a website user:

• Full name.
• E-mail address and phone number.

If you are a job applicant:

• Full name.
• Date of birth
• Contact details (phone, e-mail and correspondence address).
• Other personal information that will vary on a case-by-case basis.

If you are a visitor:

• Full name.
• Contact details (phone, e-mail and correspondence address).
• Other personal information that will vary on a case-by-case basis to help us protect our residents, staff and volunteers.

If you are a Gift Aid Donor

• Full name.
• Contact details (phone, e-mail and correspondence address).

If you do not provide us with certain information we require from you, you may be unable to become or continue as a resident, sponsor, employee, member of the Executive Committee or House Committee, Friend or volunteer, to visit Cunningham House or to continue with your application.

What processing we do with information collected

The information we require from you is used for the purpose of processing your enquiry or application, entering into and performing any contractual arrangements (for example tenancy agreements and employment contracts) between you and us, complying with the law and our legal obligations, and for the purposes of our legitimate interests. Any processing we undertake will be adequate, proportionate and not excessive for the purpose.

The processing activities we conduct include:

• Processing your enquiry or application to become a resident, sponsor, employee, volunteer or donor.
• Entering into and performing your tenancy agreement and your residency with us including ensuring residency conditions are complied with.
• Entering into and performing your employment contract or volunteer arrangement with us.
• Complying with relevant legislation and regulation.
• Understanding how our website is being used to inform website content and help us reach our target audience.

We conduct research and statistical analysis to help improve our business processes and the services offered to our residents, as well as to evaluate our performance against other benchmarks. When possible, statistical information is anonymised or pseudonymised.

We conduct surveys regularly and periodically relating to our services in order to gauge satisfaction and make improvements based on feedback.

We hold information in IT systems which may be copied for testing, backup, archiving and disaster recovery purposes. All data is held within the UK.

Any sensitive personal (or special category) data (such as physical or mental health information and information on disabilities and vulnerabilities) will typically be processed because we need to do so in order to carry out our duties or exercise our rights as a service provider or employer to you; you have given your free, informed and explicit consent to it being processed by us; the information has been made public by you; we are required to process the information by law; or the processing is necessary in order for us to conduct, defend or exercise a legal claim.

How we protect your personal data

We operate a range of information and communications systems and technologies for efficient operation of our business. Personal information is stored and managed within those systems which are maintained to achieve a high level of confidentiality, integrity and availability.

How we will communicate with you

We need to communicate with you and this will usually be in person, by email or by telephone, but occasionally by post.

We operate an opt-in mechanism for receiving direct marketing. You may remove your consent to receive direct marketing or object about direct marketing to the Office Manager at Cunningham House (details as above).

We will only discuss or communicate a resident’s tenancy details with those named on the agreement, a sponsor or those authorised (temporarily or permanently) by that resident. A resident can authorise someone temporarily verbally over the phone or permanently in writing.

Who we share data with and how long we keep information

We treat personal data confidentially and only share it with third parties in limited circumstances where this is necessary to provide our services or conduct our operations.

We share limited personal data within Cunningham House (for example, to our authorised employees and with the Executive Committee and the House Committee) and with our contractors who provide services to us (including payroll and bookkeeping services).

We may need to share personal information with Government departments and agencies, with our regulator, auditors and other advisors, with medical professionals, or with other organisations and agencies where we are legally allowed to do so.

We review our retention periods for personal data on a regular basis and only retain data for as long as is reasonably necessary. We are legally required to retain some personal data to fulfil our statutory obligations. Other personal data is retained to ensure we are able to comply with or enforce our contractual arrangements, respond to enquiries from regulators and others, conduct, defend or exercise claims or other actions or otherwise protect our business interests.

Personal data will be securely disposed of once its retention is no longer necessary.

What we will not do

We will not send you unsolicited marketing material. We will not sell your personal data on to third parties.

We will not pass on your personal data to unrelated third parties unless we are allowed or required to do so by law or we have your explicit permission to do so.

We will not transfer or store your personal data outside the United Kingdom.

Your rights, the right to complain and the ICO

You have the right to request a copy of your personal data.
It will always help if you can be as specific about what personal data you want to see, what it relates to and within what time frame, as that will assist our search.

You have the right to correct and in some circumstances delete your personal data.

You may also have the right to withdraw your consent to the processing of any personal data that was previously provided with your consent.

You may have the right to object to our processing your personal data and other rights.

Details of these and any other rights you may have (and of any limitations on your rights) can be found on the Information Commissioner’s Office (ICO) website (www.ico.org.uk).

Please advise the Chair of the House Committee (details above) if you wish to exercise any such rights.

You have the right to complain about how we use your personal data. In the first instance please refer to our complaints policy. If you wish to complain about our use of your personal data you may also do so to the ICO.

Changes to this Policy

This Policy is reviewed and updated from time to time. This version was updated on 21 March 2022.