Privacy notice

Valleys to Coast does not capture or store any personal information about individuals who browse this website, except where you voluntarily choose to give us your personal details via email or an online form to enquire or apply for any of our services.  We will only do this when we require that information for specific purposes, for example, to answer an enquiry you have submitted or send information that you have requested. 

Cookies

What about Cookies?  

Cookies are small files saved on your phone, tablet or computer when you visit a website.

How this site uses cookies

We use cookies to make this site work and collect information about how you use our service.

Some of these cookies are essential, while others help us to improve your experience by providing insights into how the site is being used.

Necessary cookies enable core functionality such as page navigation and access to secure areas. The website cannot function properly without these cookies, and can only be disabled by changing your browser preferences.

Analytical cookies help us to improve our website by collecting and reporting information on its usage.

We may allow third party organisations, such as Google Analytics, to set cookies using this website in order to help us to better deliver our services. If you would like more information about the cookies used, as well as information on how to opt-out, please check the information below.

Google Analytics

We use Google Analytics to give us insights into how our users interact with our website. 

To obtain these insights, Google Analytics uses a number of cookies. The information collected is anonymous and statistical. 

The Google Analytics cookies are the cookies with names beginning “_utm”. Common Google Analytics cookies are, _utma, _utmb, _utmc, and _utmz. 

To give you additional control over Google Analytics cookies, Google provides an opt-out plug-in for most common website browsers http://tools.google.com/dlpage/gaoptout.

We will use your personal data for a limited number of purposes within the rules set out in the Data Protection Act 2018.  We will process personal data: 

• Schedule 1, Part 1, paragraph 1, when Valleys to Coast Group are required to process data relating to employment, social security and social protection.
• Schedule 1, Part 1, paragraph 2, when Valleys to Coast Group are required to process data relating to Health or social care purposes.
• Schedule 1, Part 2, paragraph 6, when Valleys to Coast Group are required to process criminal offence data to exercise a statutory function. 
• Schedule 1, Part 2, paragraph 8, when Valleys to Coast Group wishes to ensure a developed approach to Equality of opportunity or treatment, with customers. 
• Schedule 1, Part 2, paragraph 10, when Valleys to Coast Group are gathering, for example, CCTV footage to prevent or detect unlawful acts.
• Schedule 1, Part 2, paragraph 11, to allow Valleys to Coast Group to protect the public against dishonesty by processing Criminal Offence data of prospective employees. 
• Schedule 1, Part 2, paragraph 12, to allow Valleys to Coast to ascertain potential criminality and protect the wider public. 
• Schedule 1, Part 2, paragraph 14, to allow Valleys to Coast to share data with anti-fraud organisations as necessary to safeguard public funds.
• Schedule 1, Part 2, paragraph 15, to allow Valleys to Coast to disclose data of parties suspected of money laundering.
• Schedule 1, Part 2, paragraph 16, to allow Valleys to Coast to provide support to customers with particular disabilities or medical conditions.
• Schedule 1, Part 2, para 17, where the Valleys to Coast Group needs to process Special Category/Criminal Offence data in order to provide confidential counselling, advice or support or of another similar service provided confidentially, only where, in the circumstances, consent cannot be given by the data subject, cannot be reasonably obtained from the data subject, or where the processing must be carried out without the consent of the data subject because obtaining consent would prejudice the provision of the service, and the processing is necessary for reasons of substantial public interest.
• Schedule 1, Part 2, para 18 (safeguarding), where the Valleys to Coast Group needs to process Special Category/Criminal Offence data in order to protect the physical, mental or emotional well-being of an individual under the age of 18, or over the age of 18 and at risk, only where, in the circumstances, consent cannot be given by the data subject, cannot be reasonably obtained from the data subject, or where the processing must be carried out without the consent of the data subject because obtaining the data subject’s consent would prejudice the provision of the protection, and the processing is necessary for reasons of substantial public interest.
• Schedule 1, Part 2, paragraph 19, to allow Valleys to Coast Group to protect customers who may be subject to financial abuse.

At no time will your information be passed to organisations external to the Association for marketing or sales purposes.

In deciding what personal data to collect, hold and use we have committed to ensuring that we will: 

• Recognise we have responsibility for any personal data handled by us; 
• Adopt and maintain high standards in respect of the handling and use of that personal data; 
• Only collect, hold and use personal data where it is necessary and proportionate to do so; 
• Securely delete any personal data when no longer needed; 
• Keep your personal data safe and secure; 

• Where appropriate, complete privacy impact assessments when planning to use or hold personal information in new ways, such as when introducing new systems; 
• Be open with you about how we use your information and who we give it to; 
• Make it easy for you to access and correct your personal information; 
• Ensure that there are effective safeguards and systems in place to make sure your personal information is kept securely and does not fall into the wrong hands; 
• Support our Data Protection Officer to fulfil their duties;
• Provide regular training to all staff on effective data handling, and understanding data requests;
• Provide specialist training to staff who regularly handle personal data; and 

• Put appropriate financial and People Team resources into looking after your personal information. 

We may disclose personal data to third parties, this may include local authorities, support services and our contractors, but only where it is necessary to deliver the service or manage the contract, to comply with a legal obligation, or where permitted under the Data Protection Act, for example where the disclosure is necessary to allow a third party working for or on our behalf to provide a service.  This may be providing maintenance to the property, gas surveys and or property surveys.  

We will strive to ensure that any personal data in our care will be kept safe and where your information is disclosed to a third party we will seek to ensure that the third party has sufficient systems and procedures in place to prevent the loss of personal data. 

Where we seek to disclose sensitive personal data, such as medical details, to third parties, we will do so only with your prior express consent or where we are legally required to do.

If we are concerned for your safety and wellbeing, or for another person within your home, then we may need to share your personal information with other agencies to ensure that these concerns are passed to the relevant agencies. We will only do this if we feel that you, or another individual, are at immediate risk of danger, or if in the absence of sharing this information, it would put you at risk of danger. Your information will be handled proportionally and securely. 

We will provide information to third parties, including utility providers, to assist and facilitate the supply, management and billing of utilities at tenanted properties and debt management and collection in relation to tenanted properties. 

People who make a complaint to us 

Valleys to Coast Group takes your concerns and complaints seriously. Valleys to Coast Group are committed to dealing effectively with any concerns or complaints you may have about our service. We aim to clarify any issues about which you are not sure. Where possible, we will try to deal with complaints and concerns quickly and informally.

Where we have got something wrong, we will not be afraid to apologise and, wherever possible, we will put things right. We also aim to learn from our mistakes and use the information we gain to improve our services.

For further information, contact us at governance@v2c.org.uk to access the Concerns and Complaints Policy and Procedure. 

Detection and Prevention of crime, fraud and data matching  

We are required by law to protect the funds we administer.  We process and share the information provided to us to prevent and/or detect potential fraud and crime, by both conducting our own data matching as well as sharing this information with other public bodies, such as the Department for Work and Pensions, Local Authorities, HM Revenues, Customs, the Police, as well as utility companies, credit reference agencies, service providers, contractors and/or partner bodies, where the disclosure of such information is either: 

1. necessary for the purposes of the prevention and/or detection of crime; and/or  
2. is otherwise necessary to comply with any other legal obligation;  
3. assisting in emergency response management 

Data matching involves comparing computer records held by one body against other computer records held by the same or another body to see how far they match.  This is usually personal information. 

Valleys to Coast Group shall only use CCTV where it is a proportionate and necessary measure to achieve a defined business objective – with clear, bilingual signage to inform you of this. Footage may be shared with relevant parties, such as the police, in the event of the identification of criminal activity. All cameras shall be recorded and regularly monitored, and footage will be deleted in accordance with our data retention schedule – unless data is shared externally, as provisioned for above, under the Criminal Law Act (1967). 

Our position on CCTV is explained more fully in our Data Protection Policy. Please contact dpo@v2c.org.uk if you wish to receive this. 

We have to process your personal data in various situations during your recruitment, employment (or engagement) and following termination of your employment (or engagement). We will use your personal data for:

• performing the contract of employment (or services) between us;
• complying with any legal obligation; or
• if it is necessary for our legitimate interests (or for the legitimate interests of someone else). However, we can only do this if your interests and rights do not override ours (or theirs). You have the right to challenge our legitimate interests and request that we stop this processing. Please see details of your rights below.

We can process your personal data for these purposes without your knowledge or consent. We will not use your personal data for an unrelated purpose without telling you about it and the legal basis that we intend to rely on for processing it. 

If you choose not to provide us with certain personal data you should be aware that we may not be able to carry out certain parts of the contract between us, and it might also stop us from complying with certain legal obligations and duties which we have.

We will only process special categories of your personal data in certain situations in accordance with the law. If we asked for your consent to process a special category of personal data then we would explain the reasons for our request. You do not need to consent and can withdraw consent later if you choose by contacting the People team.

We do not need your consent to process special categories of your personal data when we are processing it for the following purposes, which we may do:

• where it is necessary for carrying out rights and obligations under employment law;
• where it is necessary to protect your vital interests or those of another person where you/they are physically or legally incapable of giving consent;
• where you have made the data public;
• where processing is necessary for the establishment, exercise or defence of legal claims; and
• where processing is necessary for the purposes of occupational medicine or for the assessment of your working capacity.

We will process special categories of your personal data for the purposes of and in relation to:

• ensuring all relevant colleagues have current Disclosure and Barring Service certificates;
• your race, ethnic origin, religion, sexual orientation or gender age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation to monitor equal opportunities;
• your sickness absence, health and medical conditions to monitor your absence, assess your fitness for work, to pay you benefits, to comply with our legal obligations under employment law including to make reasonable adjustments and to look after your health and safety; and your trade union membership to comply with our legal obligations in respect of trade union members.

We do not take automated decisions about you using your personal data or use profiling in relation to you.  

Application stage 

If you use our online application system, this will be collected directly by Valleys to Coast.  We ask you for your personal details including name and contact details.  We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for.  The People team will have access to all of this information. 

You will also be asked to provide equal opportunities information.  This is not mandatory information – if you don’t provide it, it will not affect your application.  This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way which can identify you.  Any information you do provide will be used only to produce and monitor equal opportunities statistics. 

Shortlisting 

Our hiring managers shortlist applications for interview.  They will not be provided with your name or contact details or with your equal opportunities information if you have provided it. 

Assessments 

We might ask you to participate in assessments; complete tests; and/or to attend an interview – or a combination of these.  Information will be generated by you and by us.  For example, you might complete a written test or we might take interview notes.  This information is held by Valleys to Coast. 

Conditional offer 

If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks.  You must successfully complete pre-employment checks to progress to a final offer.  We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.  

You will therefore be required to provide:  

• Proof of your identity and right to work in the UK – you will be asked to attend our office with original documents, we will take copies 
• Proof of your qualifications – you will be asked to attend our office with original documents, we will take copies 

• We reserve the right to undertake a DBS check dependent on your role.  If this is required you will be asked to complete a criminal records declaration and make an application for criminal record verification to verify your declaration 
• We will contact your referees, using the details you provide in your application, directly to obtain references 
• We may ask you to complete a questionnaire about your health.  This is to establish your fitness to work and any support you may require in the workplace.

If we make a final offer, we will also ask you for the following: 

• Bank details – to process salary payments 

• Basic equality information
• Emergency contact details – so we know who to contact in case you have an emergency at work
• Whether or not you have a student loan

Post-start date   

Our Code of Conduct requires all staff to declare if they have any potential conflicts of interest.  If you complete a declaration, the information will be held by the Governance Team.  This declaration is required to be completed by all new starters, and then reviewed annually. Significant conflicts of interest will be reported on their identification. Schedule 1 exemptions will be reported on an anonymised basis to the Welsh Government as it is a regulatory requirement.  

Recruitment Agencies 

On occasion we may advertise through a Recruitment Agency. They will provide us with information collected from you. Details relating to privacy will be the responsibility of the agency engaged. 

How long is the information retained for? 

If you are successful in your application, in line with our retention schedule, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment.  This includes your criminal records declaration, fitness to work, records of any security checks and references. 

If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the campaign. 

Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the campaign. 

Equal opportunities information is anonymised and amalgamated with other application data, if appropriate, for 6 months following the closure of the campaign whether you are successful or not. 

How do we make decisions about recruitment? 

Final recruitment decisions are made by hiring managers and members of our People team. All of the information gathered during the application process is taken into account. 

You are able to ask about decisions made about your application by speaking to your contact within our People team or by emailing peopleteam@v2c.org.uk.  

Data processors are third parties who provide elements of our recruitment service for us.  We have contracts and Data Sharing Agreements in place with our data processors.  This means that they cannot do anything with your personal information unless we have instructed them to do it.  They will not share your personal information with any organisation apart from us.  They will hold it securely and retain it for the period we instruct. 

Customers

Customers and management of their Occupation Contracts 

Valleys to Coast is the Data Controller for the information you provide during the process unless otherwise stated.  If you have any queries about the process or how we handle your information please contact us at governance@v2c.co.uk. 

What will we do with the information you provide to us? 

All of the information you provide will only be used for the purpose of progressing your application for housing, to fulfil our duty as a Landlord, as set out in the Occupation Contract and to improve our services. Where you have given your permission, we will also provide you with information on events, activities and opportunities that may be relevant to you.  

In rare occasions we may share the information you provide to us for the purposes of detection or prevention of crime or anti-social behaviour, or where we believe that sharing the information could prevent harm to an individual or in the case of public protection – for example in cases of domestic violence, mental health concerns or children at risk.  We also share the information you give us with software providers in order to host contract related information.  We do not share your information with third parties for marketing purposes or store any of your information outside of the European Economic Area.  The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format. 

Offer and Commencement of Occupation Contract 

In order to offer you a property Valleys to Coast will request some information from you. This information is required for us to offer you a property and without it; we would not be able to do so. These are: 

• Name 
• Address 
• Gender 
• DOB 
• Contact details 
• Photographic ID to prevent contract fraud
• Other occupants or family members moving with you 
• Health or disabilities relevant to your housing needs 
• Some income details, including current welfare benefits 
• Information relation to any previous contract you may have held via a reference from a previous landlord 
• Relevant criminal convictions pertinent to your contract application and where it is legal to do so (you would have supplied this information as part of your initial application with Bridgend Council) 

We will also ask you for other information which you do not have to give, but which assists us in improving services and ensuring they are fair and equal. These are: 

• Ethnicity 
• Nationality 
• Preferred language 
• Religion 
• Gender 
• Sexual orientation 

• Marital status 
• Name of support worker (if relevant) 
• Internet access 
• Next of Kin (NOK) 

• Preferred method of communication 
• Agreement to send you information on events/activities 

During your Occupation Contract with us: 

The following information is collected and retained while you hold a contract with us or in order for us to meet our obligations as a Landlord, as set out in the occupation contract.  

• Your Occupation Contract 

• Details about any benefit claim you may have in relation to Housing (Housing Benefit or Universal Credit) 
• Your rental payments and balance  
• Current occupants in your home 
• All details relating to any contract breaches 
• All appointment and communication with you, either in verbal or written form 

• Any reports of anti-social behaviour against you or made by you, including CCTV footage, photos and noise recordings.  
• All repairs carried out on your home 
• Applications to move home 

When you end your Occupation Contract and retention of data 

If you have held an Occupation Contract with us all the information we have collected about you is retained on file for a maximum period of 6 years after the contract has ended, after which it is destroyed.  

Use of third party data processors for contract management 

Some information you provide to us before and during your Occupation Contract is shared with third party organisations for the purposes of  

1. helping us deliver services or;
2. for the detection and prevention of crime or ASB; or  
3. where we are obliged to provide it by law .

We have contracts or data sharing agreements in place with our data processors.  

Support Services Delivery 

Valleys to Coast is both a Data Controller and a Data Processor of personal information received and shared during the delivery of support services agreed to by Customers. 

What will we do with the information you provide to us? 

All of the information you provide will only be used for the purpose of providing the support service agreed to, including multi-agency data sharing, to fulfil any statutory duty required of us and to improve our services.  

Valleys to Coast collects both personal and sensitive data as part of the service delivery process.  We will receive information from referral agencies and will share information with relevant agencies.  All data shared is done so with data sharing agreements between Valleys to Coast and the relevant agency, unless there are safeguarding concerns or a legal basis for sharing, as described in the below paragraph.  

On occasions we may also share the information you provide to us for the purposes of detection or prevention of crime or anti-social behaviour, or where we believe that sharing the information could prevent harm to an individual or in the case of public protection – for example in cases of domestic violence, mental health concerns or children at risk.  

We also share the information you give us where required to do so with Local Authorities and use software providers to host service related information.  We use Civica as our case management system.  

During your service delivery 

We will continue to collect personal and sensitive data throughout the delivery of the service which you have signed up to.  This will include but is not limited to: 

• Income and financial expenditure  
• Relevant EDI information
• Contract information including rent arrears 
• Substance/alcohol use 
• Disabilities or other medical requirements
• Risk assessments from referring agency and prepare new assessments 
• Prior housing history 
• Work/skills information 
• Support Plans 

Where support is also provided to children or parenting support is being provided additional information will be provided to us by relevant services, in order to be able to deliver full support. This will include information on children as well as parents.  We will also be provided information on family members by the referring agency. 

If you are also a customer we will also refer to occupation contract data which we hold in line with this policy to fulfil our obligations under that agreement. 

When your service delivery comes to an end 

We will retain your data for the minimum period required of Valleys to Coast by law or by the referring contract.  We will continue to hold your data safely and will dispose of it in accordance with our Data Retention Policy. 

Publications and Communication 

If you hold a contract with Valleys to Coast Housing Association, there will be times we need to contact you. Some of these are described below (the list is not exhaustive): 

• To get access to your home to carry out essential maintenance work or inspect your home; 
• To inform you of your rent balance; 
• Regarding any complaints that have been made against you; 
• In other instances where we must contact you to carry out essential functions as a Landlord; 
• To provide you with information relevant to the good management of your contract; 
• To consult on matters of relevance to you as a contract holder; 
• To obtain your feedback on the quality of service delivery; and 
• To engage with you to design our services and delivery to better support us. 

There are other instances where we may wish to contact you to tell you about events, activities, opportunities and local news. This is optional and you will have the ability to opt out of this contact.  

We will never pass on your details to any third party for the purposes of marketing of services.  

Your rights 

Under the Data Protection Act, you have rights as an individual which you can exercise in relation to the information we hold about you. 

You have the right to request that we cease processing your personal data in relation to any of our services.  Where possible, we will seek to comply with your request but there may be some situations where we will not legally be able to do this.  However, ceasing to process this data may cause delays or hinder our ability to provide services to you. 

You are legally entitled to request access to and receive a copy of any information that we hold about you. This is called a Subject Access Request, and you can find more information on this here. We will seek to comply with your request but there may be some situations where it will not be able to do this in full, for example where information held was given in confidence, this may include information given to us by a third party. We may also redact information that relates to a third party. 

For further information about either requesting access to your personal data or to cease processing personal data please contact us. 

We try to ensure that any personal data we hold about you is correct but there may be situations where the information we hold is no longer accurate.  If this is the case, please contact the department holding the information so that any errors can be investigated and corrected.  If you are unsure which department to contact, please contact the Data Protection Officer on: DPO@v2c.co.uk. 

We may monitor and record electronic transactions (website, email and telephone conversations).  This will be used, for example, to help improve our service to you, to prevent or detect a crime, or investigate or detect the unauthorised use of the telecommunications system and only as permitted by the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 or for related business purposes.

Where data is stored outside of the United Kingdom, we complete a Data Protection Impact Assessment, and implement a data sharing agreement, to ensure your data is securely stored.

Valleys to Coast tries to meet the highest standards when collecting and using personal information.  For this reason, we take any complaints we receive about this very seriously.  We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate.  We would also welcome any suggestions for improving our procedures. 

This privacy statement was drafted with brevity and clarity in mind.  It does not provide exhaustive detail of all aspects of Valleys to Coast’s collection and use of personal information.  However, we are happy to provide any additional information or explanation needed. 

If you have a query, or want to make a complaint about the way we have processed your personal information, you can contact us on: DPO@v2c.co.uk. 

We will continually review and update this privacy statement to reflect changes in our services and feedback from Customers, as well as to comply with changes in the law. 

We will comply with the legal requirements set out by the Data Protection Act in relation to the collection, holding and processing of personal data.  If you would like to know more or have any concerns about how your information is being processed please email us on: DPO@v2c.co.uk. 

Or in writing to: 

Data Protection Officer, Valleys to Coast Housing Association, Tremains Business Park, Bridgend, CF31 1TZ

If you require general information about the data protection act, information is available on the Information Commissioner’s Website.