Privacy notice for HR
Why do we collect personal information?
The Housing Ombudsman Service is set up by law to look at complaints about housing organisations that are registered with us. Under the terms of the Housing Act 1996 as amended, the Housing Ombudsman appoints staff to determine complaints, support landlord tenant dispute resolution by others and to support the delivery of the service.
Personal data is collected and processed by us relating to employees to manage the employment relationship and for job applicants to manage the recruitment process. We are committed to being transparent about how we collect and use your personal data to meet our data protection obligations.
We process personal information some of which may be special category data (see below), which is necessary to enter into an employment contract with you and to meet our obligations under your employment contract. For example, to pay you in accordance with your employment contract.
More detailed information about your rights is contained in an annex to the Notice.
What personal data do we collect about you?
We collect and process a range of information about you, which will also include special category data:
- your name, address, contact details including email address, telephone number(s), date of birth and gender
- the terms and conditions of your employment
- details of your qualifications, skills, experience and employment history
- information about your salary, including entitlement to benefits such as pensions, child care vouchers
- details of your bank account and national insurance number
- information about your marital status, next of kin, dependents and emergency contacts
- information about your nationality and entitlement to work in the UK
- information about your criminal record
- details of your schedule (days of work and working hours) and attendance at work
- details about periods of leave and sabbaticals, and reasons for the leave
- details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence
- assessments of your performance
- information about your training, learning and development
- information about medical or health conditions including whether or not you have a disability for which we need to make reasonable adjustments
- equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.
- Information about your entitlement to work in the UK.
How we will collect information
We will collect information in a variety of ways, for example:
- application forms
- CVs
- from your passport and driving licence or other identity documents
- forms completed by you at the start or during your employment
- correspondence with you
- interview notes
- meetings
- other assessments, for example, DSE risk assessments
- from third parties, such as references supplied by former employers.
Who has access to your personal data?
Your personal information will be shared internally with members of the HR and recruitment team (including payroll), your line manager, IT staff if access is necessary for the performance of their role. Anonymised information may be shared with the Senior Leadership Team to inform decisions and policy development.
Your personal information will be shared with third parties:
- to obtain pre-employment references
- who process data on behalf of us in connection with payroll, provision of benefits and occupational health services.
- to complete identity verification and your eligibility to work in the UK.
How will we protect your information?
We have internal policies and controls in place to ensure your information is safely stored. Your personal information is not accessed except by employees in the performance of their duties (see above).
We will not transfer personal information to countries outside the EEA unless there are adequate provisions in place to safeguard the personal information. Where third parties process personal information on our behalf they do so on the basis of written instructions. They are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of the data.
How long do we keep personal information?
We keep personal information in line with our Retention Policy. It is retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Right to Work checks/ID verification
TrustID
The information that you supply to TrustID will be recorded and processed in line with the UK GDPR / Data Protection Act 2018 / EU GDPR. The Housing Ombudsman is the Data Controller.
Information uploaded to TrustID (your identity documentation and selfie), will be used to perform a facial match assessment and to verify your identity forming your Right to Work check.
TrustID will share your data and the results of the Right to Work check with the Housing Ombudsman for the purposes of proceeding with your application. In the event that TrustID become aware of any illegal documentation, TrustID are obliged to notify the relevant law enforcement agency. TrustID will retain the data for 7 days, the Housing Ombudsman will retain the data for your period of employment plus 6 years, after which the data will be securely destroyed in all instances.
Our lawful basis for processing this data is Contract and Legal Obligation.
Further information on how TrustID handles your data can be found at: Privacy Policy for Data Subjects - TrustID
Employee benefits
We use a third party platform called Edenred to provide you with employee benefits via a benefits portal.
When you commence employment with us, we provide minimal personal details (name, work email address and payroll number) to Edenred to create your employee profile and send you a link to activate your portal account. We disclose this information to Edenred in line with our legitimate interest to provide our employees with benefits.
If you do not want to sign up to Edenred and access employee benefits, you have the right to object to us disclosing your personal information for this purpose. See the ‘your rights’ section of this privacy notice.
If you select a benefit with a salary sacrifice scheme, we will provide a copy of the signed agreement to our payroll partner company for administration of the payment.
Edenred will retain your personal data throughout their agreement with this service and for a period of 6 years thereafter. Further information on how Edenred handles your data can be found at: Privacy Policy (edenred.co.uk)
Photography and video footage
We may take photographs or video footage at events which you attend with the Housing Ombudsman Service for internal and external marketing and promotion purposes.
When we capture your image either by photograph or video, we rely on the lawful basis of either Consent or Legitimate Interest. This depends on the type of photography/videography and our assessment of the associated risks along with your rights and interests.
We may publish the information on internal communication channels and on external platforms managed by the Housing Ombudsman Service such as our website, social media, and newsletters. This means the published images/video may be available to employees and the wider public, but access to the original image is restricted to the necessary employees.
We will retain this information for as long as the information is published and until it is no longer required for the purposes it was captured for.
You have the right to withdraw your consent at any time. Please note that once images are published, we can only remove the image from any websites or accounts under HOS management and cannot control any third parties who have accessed the publication.
You can also object to us capturing your image before the event where consent has not been provided. To do this, we will give you sufficient notice of photography prior to the event.
You can view more about your rights and how to exercise them on the your rights page of this Privacy Notice.
Contact details for the Data Protection Officer
If you have any enquiries in relation to this notice please contact:
Data Protection Officer
Housing Ombudsman Service
PO Box 1484
Unit D
Preston
PR2 0ET
Telephone: 0300 111 3000 Calls to and from the 0300 111 3000 number are recorded for training and quality monitoring purposes. Lines are open Monday to Friday from 9:15am to 5:15pm (except public holidays).
Email: dpo@housing-ombudsman.org.uk
If you have a complaint about how we have handled your personal data under the Data Protection Act 2018, you can complain to the Information Commissioner:
Information Commissioner
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 01625545700