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This Privacy Notice is a public document available to anyone and applies to customers of Torus 62 Limited to explain how the organisation collects and processes personal information in order to conduct normal business activities as a Registered Social Landlord (RSL) regulated by the Homes and Communities Agency (HCA). Normal activities can be summarised as:
We also provide additional optional services including:
Torus 62 Limited is the Data Controller whose Head Office is located at The Observatory, One Old Haymarket, Liverpool L1 6RA. Tel: 0800 678 1894. The company Data Protection Officer can be contacted at email@example.com. We own and manage over 15,000 properties in the Liverpool Region and employ around 300 staff, based at our Head Office and Clubmoor Office. Our structure includes HMS, Torus Foundation and Torus Developments working together to deliver support and services to our customers.
Torus collects information from you via a variety of sources, including forms, phone calls, written communication or via digital methods such as websites and customer self-service portal.
Our Customer Service Centre phone calls are recorded for training and monitoring purposes and our recordings are held for a period of three months.
We operate a continuous CCTV system at all our office premises for the detection and prevention of crime and recordings are held for two months. CCTV / sound recordings and / or use photography may be used to capture evidence of breach of tenancy, alleged anti-social behaviour or crime.
Photographs may be taken and used for general marketing providing individuals give consent for business related purposes.
The information we require from you, the tenant(s), leaseholder(s) or the applicant, includes:
The above information is required for us to enter into our tenancy or contract with you. Without this information we would not be able to provide our services and so you would not be able to become our tenant as we could not meet our obligations to you or our obligations to our regulator.
Additional information may be requested including:
The information we require from you is used to manage your tenancy or leasehold agreement or other contract between you and Torus.
The processing activities we conduct can be summarised as:
Torus conducts surveys regularly and periodically relating to our services in order to gauge satisfaction and make improvements based on feedback.
Torus operates a range of information and communications systems and technologies for efficient operation of the business. Personal information is stored and managed within those
systems which are maintained to achieve a high level of Confidentiality, Integrity and Availability (CIA) including following best practice cyber security standards.
Information held on IT systems is data protection compliant.
Torus only processes your personal data where we have a proper lawful basis to do so.
We rely on three main lawful bases for our processing activities.
In certain instances, where our processing relates to something not covered above, we may rely on your consent as the lawful basis for that processing. Where you have given consent you may withdraw your consent at any time by contacting firstname.lastname@example.org.
Torus conducts a number of additional voluntary services including organising community events, providing debt advice, adapting the property you live in, selling properties and gathering information to improve our services.
For the additional voluntary services, much of the information contained in our Privacy Notice is still relevant, such as details about Torus as the Data Controller, contact information for the Data Protection Officer and the rights you have under the legislation, including the right to withdraw your consent and the right to complain.
Torus does not normally process children’s information as part of a tenancy, as all tenants are adults. However, we record children’s basic information if they are resident in one of our properties, including their name and date of birth. This is required for checking the property is not overcrowded and to assess other tenancy management issues where all householders and ages are required to be known.
We may receive children’s information if we are involved in the housing and tenancy aspects of a welfare case as part of a multi-agency working solution.
Much of the data we use relates to our properties and their maintenance and repair. We do not consider property information used in conjunction with the property address to be your personal information.
We are usually happy to provide you with answers to questions you may have about the property you are living in and work done to it.
As soon as your name, contact details or other personal information is used in conjunction with property information, such as to complete a property repair visit, then this is treated as personal information.
Torus needs to communicate with our customers and this will usually be in writing or by telephone, but is more commonly becoming electronic and paperless. Many of our services are moving to digital platforms (online) to allow convenient access such as ‘My Account’ – our secure online self-service portal.
If you use the ‘My Account’ service it is important that you keep your account & password secure and do not share your ‘My Account’ details with any other person. In the case of a joint tenancy both parties have their own ‘My Account’.
Our tenants receive our newsletter ‘electronically with information about what is going on within the organisation. We are required by our regulator to keep our tenants informed and to offer opportunities for involvement, but you may opt-out of receiving this by contacting email@example.com.
Torus will operate an opt-in mechanism for receiving direct marketing. You may remove your consent to receive direct marketing or object about direct marketing to firstname.lastname@example.org.
We will only discuss or communicate your tenancy or lease details with those named on the agreement or those authorised (temporarily or permanently) by you. You can authorise someone temporarily verbally over the phone or permanently in writing.
Torus shares limited personal data with our contractors who are carrying out services on our behalf. Our contractors are required to comply with the law and our own Data Processing Agreement to ensure data is managed appropriately and for specified purposes, including to run our out-of-hours telephone service or to complete emergency, responsive or planned property repairs.
We may share your information with a language translation service if it is necessary to translate any information into or from a foreign language for you.
Torus may need to share personal information with government departments and agencies, with our regulator and auditors, with utility companies or with other organisations and agencies where we are legally allowed to do so.
Information relating to a tenancy or lease agreement will be kept for as long as the agreement is active or where money is owed on the account, and for a period not exceeding three years afterwards. The basic history of who held a tenancy at which property and when will be held forever.
We may need to share information with solicitors, agents, mortgage brokers, financial advisors, court agents, surveyors and valuers relating to a property sale.
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 that.
We will not transfer or store your personal data outside of Europe (the European Economic Area) outside of the control of the UK / European regulations.
You have the right to request a copy of the data we hold about you. Please contact email@example.com if you wish to request access to any of your personal data and we will always endeavour to answer your questions as part of our friendly, helpful service.
We will respond within one month of receiving your request. 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 timeframe, as that will assist our search.
You have the right to correct information that we hold. Please advise us of any changes or corrections by contacting our Customer Services team on 0800 678 1894 or via e-mail to firstname.lastname@example.org.
You may withdraw your consent to use any information that was previously provided with your consent. Please advise us if you wish to withdraw any consent previously given to email@example.com. Where your data is no longer required for the purpose for which it was originally collected, you have the right to request that we delete your data. This is sometimes known as ‘the right to be forgotten.’ If you believe this applies to your data and you would like us to delete it, please contact firstname.lastname@example.org.
Where you contest the accuracy of the data that we hold about you, where you have objected to the processing that we carry out in pursuit of our legitimate interest, or where we no longer require your data but you do need it for a legal claim, you have the right to block or suppress our processing of your data. This means that we will cease our normal processing of your data and process only the minimum to ensure that the restriction is respected going forwards. We will continue to store your data. If you believe this applies to your data and you would like us to restrict our use of it, please contact email@example.com.
You have the right to a structured, commonly used and machine readable copy of your personal data that we use to manage your tenancy, your account with us and your property. You have the right to have this data delivered to you or to a third party of your choice. Please contact firstname.lastname@example.org if you would like a copy of your data in this format and our team will be happy to help.
You have the right to object, on grounds relating to your particular situation, to processing that we do in pursuit of our legitimate interest to ensure that tenancy obligations are complied with. We will re-evaluate our processing, and unless we can demonstrate compelling legitimate grounds to continue, we will stop processing your data for those purposes. If you would like to object to this processing please contact email@example.com with your reasons and one of team will be in touch.
We may use your personal data to send marketing information about products or services that we think that you might be interested in. If you would prefer not to receive direct marketing from us, you can let us know at any time by contacting firstname.lastname@example.org.
We do not make any solely automated decisions that produce legal or similarly significant effects for you using your personal data. If this changes, we will let you know.
You can find more information about your rights, and data protection in general, on the website of the Information Commissioner’s Office here: https://ico.org.uk
You have the right to complain about any matter relating to our service, including how we use your personal data:
For further information about Torus, please see our website at www.torus.co.uk/liverpool (including website terms & conditions and information about website cookies) or contact our Customer Services team. This privacy notice will be subject to amends at times and will be available online at www.torus.co.uk/liverpool.