ComMutual | Privacy Policy

Privacy Policy

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1. Summary

This Privacy Notice is a public document available to anyone and applies to customers of ComMutual to explain how the organisation collects and processes personal information in order to conduct normal business activities as a Registered Charity regulated by the Charities Commission. Normal activities can be summarised as:

  1. Providing advice and assistance in relation to employment, health and wellbeing, digital inclusion and financial inclusion
  2. Providing sports and activities
  3. Providing grant funding to build the capacity of other charitable and community Organisations
  4. Provide services to both adult and children in respect of point 1.

2. Who we are

ComMutual is the Data Controller whose Head Office is located at The Observatory, One Old Haymarket, Liverpool L1 6RA. Tel: 0300 123 5809. The company Data Protection Officer can be contacted at info@commutual.org.uk. We are a registered charity (Registration Number 1152903) and employ around 45 staff, based at our Head Office and FireFit Hub Facility located at 115 Upper Warwick Street, Liverpool L8 8HD. The LMH Group structure includes Housing Maintenance Solutions, Commutual and LMH Developments working together to deliver support and services to our customers.

3. How we collect your information

Commutual 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 30 days. CCTV / sound recordings and / or use photography may be used to capture evidence of alleged anti-social behaviour or crime.

Photographs may be taken and used for general marketing providing individuals give consent for business related purposes.

4. What information we collect about you

The information we require from you, the beneficiary, the tenant(s), leaseholder(s) or member(s), includes:

  • Full name (and proof of your identity / photo ID).
  • Date of birth. Contact details (phone, e-mail or correspondence address).
  • Emergency Contact information
  • Details of anyone authorised to act on your behalf if applicable.
  • Basic details (name and DOB) of all household residents.
  • Card details if you pay by card (however card details are not stored).
  • Medical information including allergies, health conditions disabilities or vulnerabilities.
  • Language, religious beliefs, ethnicity, gender
  • Other personal information that will vary on a case by case basis to help us resolve behavioural issues
  • Consent to share information with other parties

The above information is required for us to be able to provide services which meet your specific needs. Without this information we would not be able to provide our services and so you would not be able to benefit from our services and we could not meet our obligations to you or connect you with the organisations we work in partnership with.

Additional information may be requested including:

  • Disabilities or vulnerabilities.
  • Financial information to provide assistance and advice on financial matters.
  • Health information when we require this to support funding for adaptations made to the property you are living in.

5. What processing we do with information collected

The information we require from you is used to provide services which will help you to improve your life conditions, across the 4 areas listed in section 1.

The processing activities we conduct can be summarised as:

  • Complying with relevant legislation and regulation.
  • Sharing data with consent to support your individual needs across the 4 pillars identified in section 1.
  • Use your data to match suitable opportunities to your needs e.g . financial assistance
  • Use your data to manage your membership or your child’s engagement with the services on offer via Firefit Hub or the Community Investment Team.

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

Commutual 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.

6. Lawful Basis

Commutual only processes your personal data where we have a proper lawful basis to do so.

We rely on two main lawful bases for our processing activities:

  1. The processing is necessary for in order for us to comply with our legal obligations. We use this basis for all our processing involved in complying with regulations or laws that apply to us.
  2. The processing is necessary to comply with legal obligations relating to safeguarding adults and child protection.

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 info@Commutual.org.uk.

Where we process data relating to a child (i.e. under the age of 13) and such processing requires consent, we will obtain consent from the child’s parent or guardian. This also apply where an adult lacks the mental capacity to provide consent, in which case if consent is required, we will obtain consent from the appropriate guardian or attorney.

7. Children’s information

Commututal does process children’s information in relation to specific activities which include:

  • Firefit Hub memberships
  • Health bursaries
  • School holiday camps
  • Engagement in health and wellbeing activities
  • Incidents / accidents and safeguarding concerns

This information is required to support the delivery of our 4 pillars

8. How we will communicate with you

Commutual 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 for our customers.

Our customers receive our newsletter ‘electronically with information about what is going on within the organisation. You may opt-out of receiving this by contacting info@commutual.org.uk.

Commutual 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 info@commutual.org.uk.

9. Who we share data with and how long we keep information

Commutua lshares limited personal data with our partners who are carrying out services on our behalf. Our partners are required to comply with the law and our own Data Processing Agreement to ensure data is managed appropriately and for specified purposes as per the 4 pillars.

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.

Commutual may need to share personal information with government departments and agencies, with our regulator and auditors or with other organisations and agencies where we are legally allowed to do so.

Your information will be stored for a retention period of 3 years as standard. However if you are involved in an incident or safeguarding concern we will retain your information for a period of 7 years as per NSCCP guidance.

CCTV images at FireFit Hub will be overwritten after a period of 30 days.

10. 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 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.

11. Your rights, the right to complain and the ICO

You have the right to request a copy of the data we hold about you. Please contact info@commutual.org.uk 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 info@commutual.org.uk.

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 info@commutual.org.uk. 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 info@commutual.org.uk.

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 info@commutual.org.uk.

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 info@commutual.org.uk 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 info@commutual.org.uk 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 info@commutual.org.uk.

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:

  • In the first instance please contact our Customer Services team on Tel: 0300 123 5809 or e-mail info@commutual.org.uk.
  • If you are still not happy with our service you may complain to the Housing Ombudsman Service at http://www.housing-ombudsman.org.uk/.
  • If you wish to complain about our use of your personal data you may complain to the UK Information Commissioner’s Office (ICO) at https://ico.org.uk

12. Further information

For further information about LMH, please see our website at www.commutual.org.uk (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.commutual.org.

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