This Privacy Notice will illustrate how your personal data and, if applicable, special categories of personal data will be used by Link.
It provides you with information about your rights under the General Data Protection Regulation (EU) 2016/679 [GDPR] and the Data Protection Act 2018 [the Data Protection Legislation] and how to action these rights.
Who we are
The Link group of companies is committed to protect your privacy.
Each Link group company has entered into a Data Processing Agreement with the other Link companies, which sets out clearly how and why information may be shared. This ensures we can provide you with the services you expect from us at the same time as meeting our data protection obligations.
The Link group is made up of Link Group (the parent company), Link Housing Association, LinkLiving, Link Property, Horizon Housing Association, Larkfield Housing Association and West Highland Housing Association. Each member of the group is registered as a controller with the Information Commissioner’s Office [ICO].
The data protection principles set out how personal data should be managed.
- 1. Lawfulness fairness and transparency
We need to be clear and upfront about what we use your data for.
- 2. Purpose limitation
We will only use your data for specific reasons which are set out in this guide.
- 3. Data minimisation
We will only collect data which is necessary for us to provide a service to you and will delete data when it becomes out of date.
- 4. Accuracy
We will ensure that any personal data we collect is correct and up to date.
- 5. Storage limitation
We will keep only what’s necessary in line with our Data Retention Schedule.
- 6. Integrity and confidentiality
We will ensure we have appropriate security to protect the data we process about you.
We aim for this privacy notice to be clear but comprehensive and provide you with all the information you need to understand how we will manage your data.
To find out about your data is processed by a specific Link service, please click below:
What is Data?
- Personal Data
Means any identifiable information about a living person. This can include:
- Telephone Number
- Date of Birth
- Tenancy Reference Number
- National Insurance Number
- Special categories of personal data
Are defined as personal data relating to a person’s:
- Racial or ethnic origin
- Political opinions
- Religious or other beliefs
- Trade Union membership
- Sex life or sexual orientation
- Genetic or biometric data used to uniquely identify a person
Link is a controller of your personal data. This means that we decide the purpose and conditions of processing of your personal data.
Any supplier, contractor or other third party with whom we share data is called a processor.
What are the conditions of processing?
The conditions of processing are basically the legal reasons for processing your personal data. We have to make it very clear why we process your data.
In processing your personal data or special category personal data, Link will rely on one or more of the following conditions of processing, depending on what we are using your personal data for:
You have given your consent to the processing of your personal data.
Processing of personal data is necessary for the performance of a contract with you or for Link to take pre-contractual steps at your request.
- Legal Obligation
Processing of personal data is necessary for Link to comply with a legal obligation.
- Vital Interests
Processing of personal data is necessary to protect your vital interests or another individual's vital interests (this means life or death situations).
- Public Task
Processing of personal data is necessary for the performance of a task carried out in the public interest or in the exercise of official authority conferred on Link.
- Legitimate Interests
Processing is necessary for Link's legitimate interests or a third party's legitimate interests, unless these interests are overridden by your interests or fundamental rights.
Special categories of personal data
- Explicit Consent
You have given your explicit consent to the processing of your personal data.
- Employment Law
Processing is necessary for carrying out obligations under employment, social security or social protection law.
- Vital Interest
Processing is necessary to protect your vital interests of or another person's vital interests where the data subject is physically or legally incapable of giving consent.
- Legal Claims
Processing is necessary for the establishment, exercise or defence of legal claims.
- Public Interest
Processing is necessary for reasons of substantial public interest, under law.
- Medical Diagnosis and Treatment
Processing is necessary for the purposes of the provision of health or social care or treatment or the management of health or social care systems.
You have a number of rights under the Data Protection Legislation which are outlined and explained below.
- The right to be informed how your personal data is processed
This guide informs you how your data will be processed and sets out clearly Link's lawful basis for processing.
- The right to access your personal data
You can submit a Subject Access Request to access the personal data that Link holds about you. You can do this by writing to:
Data Protection Officer
2c New Mart Road
Or e-mailing: email@example.com
Link will then have one calendar month to respond. As part of the subject access request process we may ask for two forms of identification to be submitted before any information is released.
- The right to rectification
If any of the personal data we hold about you is wrong, you have the right to ask us to correct it.
- The right to erasure
You may request that Link erase any of your personal data that is processed by us. This is also known as the ‘right to be forgotten’. Please note that this is subject to a number of exemptions and so is not an absolute right.
- The right to restrict processing
If you believe that we are processing personal data unlawfully, where it is no longer needed or think that the personal data held is inaccurate you can ask us not to process that personal data.
- The right to data portability
The right to data portability applies when the lawful basis for processing is by automated means and you have provided Link with the personal data then you may request to obtain or reuse your personal data for your own purposes.
- The right to object
You have the right to object to our processing of your personal data. However, if Link can demonstrate that there is an appropriate ‘condition of processing’ in place then we may refuse to stop processing your personal data.
Rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision solely based on automated processing. If a decision is made by an automated process you may ask Link to have the decision investigated by a member of staff.
- How to action your rights under the Data Protection Legislation
If you wish to make a subject access request, object to the use of your personal data, would like to restrict processing or have data rectified, please contact the Data Protection Officer by emailing firstname.lastname@example.org or in writing to Link House, 2c New Mart Road, Edinburgh EH14 1RL
- The right to complain to the ICO
If you have a concern about the way Link is processing your personal data, you may raise a complaint with the Information Commissioner’s Office.
Information Commissioner's Office
0303 123 1113