Freedom of Information and Environmental Information Requests
As a Scottish Public Authority, Link is subject to the Freedom of Information (Scotland) Act 2002 and the Environmental Information (Scotland) Regulations 2004.
- Who are we?
The Link group of companies is committed to protecting your privacy. The Link group is made up of Link Group (the parent company), Link Housing Association, LinkLiving, Link Property, Horizon Housing Association, Larkfield Housing Association, West Highland Housing Association and Lintel Trust. Each member of the group is registered as a controller with the Information Commissioner’s Office [ICO].
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 that we can provide you with the services you expect from us at the same time as meeting our data protection obligations.
- Data Protection Principles
The data protection principles set out how personal data should be managed.
What Link has to do
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We will only collect data which is necessary for us to provide a service to you and will delete data when it becomes out of date.
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.
This is the Link standard privacy notice. The information on page 6 of this notice contains specific information about how your data will be processed.
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.
- Personal 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
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
- What are the legal bases for processing?
The legal bases for 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 legal bases of processing, depending on what we are using your personal data for.
- Legal bases for processing personal data
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.
Processing of personal data is necessary for Link to comply with a legal obligation.
Processing of personal data is necessary to protect your vital interests or another individual's vital interests (this means life or death situations).
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
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.
- Legal bases for processing special categories of personal data
You have given your explicit consent to the processing of your personal data.
Processing is necessary for carrying out obligations under employment, social security or social protection law.
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.
Processing is necessary for the establishment, exercise or defence of legal claims.
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.
- What data we need
To allow us to process your request for information we need the following information:
- Correspondence address (either postal or email)
- Details of your request
- Why we need it
Requests under the Freedom of Information (Scotland) Act 2002 are valid when they are in writing (including email) or other permanent form and contain the name and correspondence address of the requester. We also need your contact details to allow us to respond to your request.
- Where we store your data
Your personal data will be securely stored electronically on laptop computers and other devices which are password protected and encrypted. Paper files will be stored in locked cabinets.
- How long we will keep your information
Your personal data will be stored for three years before being deleted. The response to your request (which will not include any personal data) will be made available through Link’s Freedom of Information Disclosure Log.
To view Link's full data retention schedule please click here.
- What’s the legal justification?
Link will process your personal data under the legal obligation basis for processing.
- Sharing your Information
We may be required to disclose your information to the Office of the Scottish Information Commissioner in the event that you apply for a decision on whether your request for information was dealt with in accordance with the legislation.
- Receiving data about you
It is unlikely that Link will receive data about you from a third party as part of your request for information under the Freedom of Information (Scotland) Act 2002 and the Environmental Information (Scotland) Regulations 2004.
- Updating your information
If your details change, please contact Strategy and Business Support on 0330 303 0124 to inform us to ensure that all of the information we hold about you is up to date.
- Data Protection Officer
You can contact our data protection officer at firstname.lastname@example.org or by post to Link House, 2c New Mart Road, Edinburgh EH14 14L.
- Changes to our privacy notice
Our privacy notice is regularly kept up to date and this version was updated on 8 November 2021. The latest full version is always available from our website.