Dumfries and Galloway Housing Partnership Ltd
Privacy Notice
How we use employee and applicant information
This notice explains what information we collect, when we collect it and how we use this. During the course of our activities we will process personal data (which may be held on paper, electronically, or otherwise) about you and we recognise the need to treat it in an appropriate and lawful manner. The purpose of this notice is to make you aware of how we will handle your information.
Who are we?
Dumfries and Galloway Housing Partnership Ltd (“we” or “us”) is committed to a policy of protecting the rights of individuals with respect to the processing of their personal data and adheres to guidelines published in the Data Protection Act 1998 and the General Data Protection Regulation (EU) 2016/679, which is applicable from 25th May 2018, together with any domestic laws subsequently enacted.  We collect and use personal data for a variety of reasons.  
We are notified as a Data Controller with the Office of the Information Commissioner under registration number Z7078924 and we are the data controller of any personal data that you provide to us.
Any questions relating to this notice and our privacy practices should be sent to the Data Protection Officer who can be contacted at dpo@dghp.org.uk or The Data Protection Officer, Grierson House, Bankend Road, Dumfries, DG1 4ZS. 
Information that we hold about you
We hold information about you such as your contact details and emergency contact details, application form and references, your qualifications and career history, your contract of employment and any amendments to it, correspondence with or about you; for example, letters to you about a pay rise, information required for payroll, benefits and expenses purposes, records of holiday, sickness and other absence; information needed for equal opportunities monitoring, records relating to your career history, such as training records, appraisals, other performance measures and where appropriate, disciplinary and grievance records. 
Where necessary, we may keep information related to your health, which could include reasons for absence and GP reports and notes. 
How will we use this information about you? 
We collect and use the above information and personal data primarily for the following purposes:
  • the administration of prospective, current and past employees including self-employed, contract personnel, temporary staff or voluntary workers;
  • payment of salaries;
  • the recruitment and selection process;
  • administration of staff contracted to provide services on behalf of DGHP;
  • to comply with our health and safety and occupational health obligations;
  • planning and management of DGHP’s workload or business activity;
  • administration of agents or other intermediaries;
  • pensions administration;
  • disciplinary matters, staff disputes, employment tribunals;
  • staff training and development;
  • ensuring staff are appropriately supported in their roles;
  • Disclosure Scotland checks;
  • membership of professional bodies; 
  • assessing DGHP’s performance against equality objectives as set out by the Equality Act 2010.
Our lawful basis for using your information
DGHP’s basis in law for holding and using your personal information and sensitive personal information (also known as special categories of personal data) is:
  • performance and compliance with our employment contract with you; 
  • where necessary for health or social care purposes;
  • where necessary for the purposes of performing or exercising obligations or rights of the controller or the data subject under employment law, social security law or the law relating to social protection; 
  • the legal and regulatory requirements which apply to DGHP as a registered social landlord; 
  • where necessary to perform a task in the public interest or under DGHP’s public functions as a registered social landlord;
  • to protect your vital interests; and
  • DGHP’s legitimate interests, including but not limited to necessary for operational, administrative, HR and recruitment purposes and to otherwise manage employment relationship and interaction between employees.
Sharing of Your Information
We may disclose to and share information about you with third parties for the purposes set out in this notice, or for purposes approved by you, including the following: 
  • The Scottish Housing Regulator
  • UK Visas and Immigration 
  • HM Revenue and Customs (HMRC)
  • Pension schemes – LGPS and Scottish Widows
  • Trade unions
  • Occupational Health services
  • Potential employers (where a reference is requested)
  • Benefits Agency as required by the Social Security Administration Act 1992
  • Child Support Agency as required by the Child Support Information Regulations 2008 
  • Care Inspectorate and Scottish Social Services Council
  • Disclosure Scotland
Personal data may also be disclosed when we are legally required to do so, where we need to comply with our contractual duties to you or where there is a legitimate interest, either for DGHP or a third party, taking into account any prejudice or harm that may be caused to you. 
We may also use third party companies as data processors to carry out certain administrative functions on our behalf, such as Jobtrain. Where DGHP uses data processors to process your personal information on our behalf, a written contract will be put in place to ensure that any personal data disclosed will be held in accordance with the data protection legislation. 
When you give us information we take steps to make sure that your personal information is kept secure and safe. 
How long we will keep your information
We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you. Further details can be found in our Document Retention Policy which can be accessed on the staff intranet. 
Your Rights
You have the right at any time to:
  • Ask for a copy of the information about you held by us in our records
  • Require us to correct any inaccuracies in your information
  • Require DGHP to delete or stop processing your information, for example where the data is no longer necessary for the purposes of processing
  • Object to the processing of your information where DGHP is relying on its legitimate interests as the lawful basis for processing or is carrying out a task in the public interest
  • Obtain your information for your own use in specific circumstances
If you would like to exercise any of your rights above please contact the Data Protection Officer, Grierson House, Bankend Road, Dumfries or dpo@dghp.org.uk
You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information.  The Information Commissioner’s Office contact details are noted below:
The Information Commissioner’s Office – Scotland
45 Melville Street, Edinburgh, EH3 7HL
Telephone: 0131 244 9001
Email: Scotland@ico.org.uk