Riverside

Call recording

Our purpose(s) for processing and lawful basis

We record calls into the Customer Service Centre for training and monitoring purposes, as well as for the purpose of quality control. You will normally be told before speaking to one of our advisors that our calls are being recorded. We may also need to use call recordings as evidence where concerns or issues are raised.

The legal bases which apply to the processing described above are:

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• Where the processing is necessary for a legal obligation or in the public interest, or for official purposes, as set out in legislation (e.g. for safeguarding, anti-social behaviour)
• Where we have your consent, or explicit consent (for use of sensitive information)

How we use your information

We will only use your information collected for this purpose in order to train our staff, monitor calls and to monitor the quality of our engagement and services to you. Where calls raise concerns relating to safeguarding or anti-social behaviour, they may be processed and retained as evidence.

Call recording is automatically stopped when taking payment details and is then restarted again once payment details have been provided.

Who we may share your information with

We will not usually share your information recorded on a call with a third party, other than third party suppliers of telephony and customer services.

Where information recorded on a call is needed for evidential purposes, we may share call recordings with:

• Internal teams (e.g. safeguarding or anti-social behaviour teams)
• Law enforcement
• Health professionals

How long we will keep it

Unless we need to keep the recording as evidence for another purpose, calls to the customer service centre may be recorded and held for up to 6 months. If we are required to keep recordings for another purpose, the applicable retention period for that other purpose will then apply (e.g. 6 years for limitation of liability).

Complaints

Our purpose(s) for processing and lawful basis

We will use your information to investigate and resolve complaints raised by you, our residents, or others (including Councillors and Members of Parliament).

The legal bases which apply to the processing described above are:

• Where we need to comply with legal obligations or substantial public interest set out in legislation (section 193 of the Housing and Regeneration Act 2008 and the associated Homes and Communities Agency Regulatory Standards 2017)
• Where we need to take measures to enter into, and then perform, a contract we have entered into with you (e.g. provision of services set out in a tenancy or leasehold agreement)

How we use your information

We will use your information to thoroughly investigate and respond to a complaint you make, or where we receive a complaint from another person. In order to carry out a substantive investigation, we may request additional information from third parties (as well as the complainant).

We may pass information relating to the complaint to the relevant team(s) within Riverside, or third parties providing investigation and response services on our behalf.

In some instances we may ask customer representative groups or committees to carry out an impartial and autonomous review of your complaint.

Who we may share your information with

We may share information provided as part of the complaint investigation with third parties, including contractors working on our behalf if they are the subject of the complaint. We will also sometimes need to involve external parties such as local authorities to resolve a complaint.

Where you have raised your complaint through a representative (e.g. Councillor, Member of Parliament, Mayor, local authority etc.) we will share information relating to the complaint with the representative authorised by you or their staff with your inferred consent.

On completion of the complaints process, should the complaint be escalated or appealed at your request, we may share information with relevant regulators or non-departmental public bodes such as the Housing Ombudsman Service (HOS). The HOS looks at complaints about registered providers of social housing and their service is free, independent and impartial.

How long we will keep it

We will keep the information for 6 years from when the complaint is closed unless the information is relevant to a later complaint.

CCTV

Our purpose(s) for processing and lawful basis

We survey and monitor our property and buildings, including the areas directly surrounding our buildings, for the following purposes:

• For security purposes in the public interest (including national security)
• For the prevention and detection of crime
• To prevent and investigate anti-social behaviour and nuisance
• To assess property maintenance and assist with estate and property management
• To provide safe and secure places of work for employees
• For insurance purposes as required
• For internal investigations carried out by Riverside in accordance with approved policy (e.g. in response to complaints or disciplinary cases)

The legal bases which apply to the processing described above are:

• Where we need to comply with legal obligations (e.g. provide safe spaces for residents and customers to live, protect the health and safety of our employees)
• Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests (e.g. ensuring the security of our properties and assets, insurance purposes, carrying out internal investigations)

How we use your information

We process personal data captured through CCTV footage in line with our CCTV and surveillance policies. Unless otherwise stated, we do not carry out live CCTV surveillance. We will take a reasonable and proportionate approach to downloading and viewing of CCTV footage which balances your right to privacy, the seriousness of incident and meeting the stated purposes.

CCTV will always be accompanied by adequate signage to inform you that there is CCTV in operation.

Further information on use of CCTV and surveillance is available for our care and support services.

Who we may share your information with

We will not usually disclose CCTV footage to third parties. However, we will consider requests from the following where there is a legal basis for the disclosure and the footage is necessary for a legitimate purpose:

• The police or other law enforcement agencies, where not disclosing the CCTV footage would prejudice an investigation
• Regulatory agencies
• Insurance companies, for example when acting on behalf of Riverside or an individual affected by a crime for which Riverside holds relevant evidence. In such cases, Riverside will assess whether there is a legal basis for the disclosure and seek assurance that disclosing the CCTV footage is necessary. An administrative fee may be charged to cover costs

How long we will keep it

Typically, CCTV footage will be retained for 30 days. Footage identified as necessary for an investigation or one of the other purposes set out above will be downloaded to secure storage and retained for the retention period relevant to that purpose (e.g. 6 years under limitation of liability).

Facilities management

Our purpose(s) for processing and lawful basis

We will use your information to assist in the delivery of our facilities management services that support the functionality, safety, and sustainability of our buildings, grounds, infrastructure, and real estate. This helps us to ensure the safety and security of our buildings, safety of our customers, employees and visitors and facilitates access to buildings for repairs and maintenance.

The legal bases which apply to the processing described above are:

• Where we need to comply with legal obligations (e.g. provide safe spaces for residents and customers to live, protect the health and safety of our employees)
• Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests (e.g. ensuring the security of our properties and assets, insurance purposes, carrying out internal investigations)

Where we need to ensure the safety of our customers and employees, we may need to process your sensitive personal data. The legal basis for this is:

• Where we need to comply with legal obligations relating to employment, social security and social protection or substantial public interest set out in legislation (e.g. health and safety, safeguarding, anti-social behaviour)

How we use your information

Your information will be used by us to keep track of who visits our facilities and whether they have any health and safety requirements (e.g. for emergency purposes). We may also need to contact you to assist us in accessing areas in our facilities in order to carry out repairs and maintenance of our facilities.

Further information about how we process CCTV footage is also available.

Who we may share your information with

We may share your information with carefully selected third parties to deliver services on our behalf. If we do share data, we will only ever share the minimum amount required; and all third parties are contractually required to ensure that your data is secure and not used for any other purpose.

How long we will keep it

Registration and visitor logs recording attendance at our facilities are kept for one month.

Artificial intelligence (AI) and machine learning

Our purpose(s) for processing and lawful basis

We may use your personal data to better inform our ongoing internal research and analysis, using technology to identify patterns, inform decisions and train AI to improve our efficiency and your experience. We’ll always do this transparently and with your consent where required.

The legal bases for the processing described above are:

• Where it is necessary for our legitimate interest (or a third party) and your interests and fundamental rights do not override those interests (please see how we use your information below)
• Where it is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes
• Where we may use the processing to assist in meeting a legal obligation under a regulatory standard (such as the decent home standard)
• Where we are required to do so to assist in meeting statutory or government purposes (e.g where the Secretary of State requests we carry out analysis to identify and address hazards such as damp and mould)

In some instances, we may request your consent to process certain data for these purposes. Where consent is the legal basis we rely on, you have a right to withdraw that consent at any time.

How we use your information

We will use your personal data to identify patterns, inform decision and train AI to improve our service delivery and efficiency, and your experience across the following areas:

• Predict repairs and maintenance based on historical repair data (such as damp and mould)
• Assist our tenants in keeping their rental payments up to date and ensuring that they have timely access to services such as our Money and Benefit Welfare Advice Team
• Assist our tenants in ensuring that they do not fall into increased rent and/or utility related debts and fuel poverty
• Provide assistance in ensuring better standards of living for those on low incomes
• Provide a more personalised service based on your needs and circumstances
• Make better predictions for future housing needs for new and current tenants

Where any decisions are made based on AI/machine learning capabilities, we will ensure that the decision itself is made by a human. You have the right not to be subject to significant decisions based solely on automated processing.

Information which is used for research and analysis will be kept pseudonymised (individuals cannot be directly identified) where possible, and any outputs of the data will be anonymised (individuals cannot be identified at all).

Who we may share your information with

We may share your information with carefully selected third parties who partner with us to deliver system services. If we do share data, we will only ever share the minimum amount required; and all third parties are contractually required to ensure that your data is secure and not used for any other purpose.

Where you have consented, we may share relevant limited information with Riverside support services or third parties offering assistance and advice in areas such as energy savings, affordable warmth, and cost of living.

How long we will keep it

Identifiable information will be retained for up to 6 years from the end of your tenancy. We will keep anonymised data for as long as required to allow us to make informed decisions based on the research and analysis carried out.

The Noise App

Our purpose(s) for processing and lawful basis

The Noise App is a third-party application used to take audio recordings. We use personal data collected through The Noise App to expediate investigations regarding noise nuisance and to determine whether the noise report is anti-social behaviour, domestic living noise or a statutory nuisance.

The legal bases which apply to the processing described above are:

• Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests (e.g. expediating investigations into noise nuisance)

How we use your information

Use of The Noise App is optional. We will use the contact details of residents who choose to use The Noise App to contact them regarding their reports of noise nuisance.

The report/recording consists of a 30 second recording of the noise nuisance that the resident is experiencing, what type of noise it is, where the recording has taken place within the property, how much it is affecting them, and the noise source address/ location.

Once submitted, the information is passed on to the relevant team dealing with noise nuisance for further investigation. Reports and recordings may be used as evidence in investigating and managing anti-social behaviour and statutory nuisance, including where relevant for legal proceedings.

Who we may share your information with

We may share information reported/recorded through The Noise App with:

• Law enforcement
• Third party suppliers providing our systems

How long we will keep it

We retain the information for up to 2 years. However, we may need to keep it for longer in certain cases where an historic noise complaint is re-activated and/or information is needed for the purpose of legal proceedings.

Anti-Social Behaviour

Our purpose(s) for processing and lawful basis

The information we collect is used for investigating, managing and resolving anti-social behaviour (ASB) complaints. In some cases complaints may also lead to prosecution.

The legal bases which apply to the processing described above are:

• Where we need to take measures to enter into, and then perform, a contract we have entered into with you (e.g. meet obligations set out in a tenancy or leasehold agreement)
• Where we need to comply with legal obligations relating to social security and social protection or substantial public interest set out in legislation (Anti-Social Behaviour, Crime and Policing Act 2014)
• Where we need to act to protect the vital interests of an individual (e.g. where your life or that of another individual is in danger and you aren’t able to give your consent)
• Where processing is necessary for establishing, exercising, or defending legal claims

How we use your information

In order to gain evidence to aid in the investigation and resolution of ASB, we use the information provided for this reason to communicate with other teams within the organisation, residents, local governments, other housing associations, third parties, and the police..

We may need to collect information from third parties and work with external agencies in order to resolve the case.

Any information you have supplied to support a complaint you have made about someone else, such as a neighbour, may be used in court proceedings or other legal actions we take against them.. If you do not want your evidence to be used in this manner, please let us know.

Who we may share your information with

We may share your information with the following:

• Local authorities
• Law enforcement
• Other housing associations
• Courts
• Other individuals mentioned/implicated in the case

If you do not want your information shared with a third party, we will endeavour to respect your wishes; but, we are not always able to thoroughly investigate claims anonymously and may be required to act by law.

How long we will keep it

We will generally retain the information up to 6 years from close of the case. However, where information is processed for other purposes as well (e.g. safeguarding, legal claims etc.) other retention periods may apply instead.

Public interests and legal obligations

Our purpose(s) for processing and lawful basis

In some circumstances we may process your information in the public interest to protect someone from harm, to combat crime, or for public health and/or public policy purposes. Combating crime includes preventing and reducing crime, assisting investigations and prosecutions and covers all crimes including unlawful violence, public disorder and fraud.

The legal bases which apply to the processing described above are:

• Where the processing is necessary in the public interest, or for official purposes, as set out in legislation (e.g. where we work with local authorities, central government, law enforcement agencies etc.)
• Where we need to comply with legal obligations (e.g. housing regulations, fraud investigations)

Where we need to act to protect someone from harm where possible we will do so with consent, but where we need to act without consent, the legal bases which apply are:

• Where we need to comply with legal obligations (e.g. safeguarding)
• Where there are substantial public interests set out in legislation (e.g safeguarding of individuals at risk, including children)
• Where we need to protect your vital interests or someone else’s vital interests (in the event of an emergency)

How we use your information

We will carefully analyse the facts of each instance before acting in the public interest. We must be able to demonstrate that the information was used in a specific way as a reasonable response to a pressing need or urgent requirement.

We won’t process your information to protect you from harm without your permission, unless it is an emergency, the harm amounts to a crime or you lack mental capacity.

Who we may share your information with

Where we are acting in the public interest in order to assist in preventing crime, investigations, prosecutions, we may share your information with:

• Law enforcement
• Local authorities
• Central government
• Other housing associations
• Legal representatives

Where we are acting to protect you or another individual, we may share your information with:

• NHS Trusts
• Emergency services
• General Practitioners
• Local authorities

How long we will keep it

Information collected and used for combating crime will be stored for 6 years from the close of the case. Information relating to safeguarding cases will be stored for 10 years from the close of the case, or in the case of children, until they are 25 when the retention will be reviewed.

Communications

Our purpose(s) for processing and lawful basis

We will use your contact details to communicate with you about Riverside and its activities. In some cases we are legally or contractually required to communicate with you.

Where we are legally or contractually obligated to communicate with you, the legal bases which apply are:

• Where we need to take measures to enter into, and then perform, a contract we have entered into with you (e.g. provision of services set out in a tenancy or leasehold agreement)
• Where we need to comply with legal obligations (e.g. housing regulations)

Where we communicate with you to keep you updated about Riverside’s activities and latest news and information, the legal basis which applies is:

• Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests (e.g. informing you of our activities etc.)

Where our legal basis is legitimate interests, you are not obligated to complete surveys and can opt out of receiving future optional communications.

Where you have indicated to us that you need reasonable adjustments made to how we communicate with you (e.g. large print, electronic only etc.) we will use relevant sensitive data about you to ensure we communicate with you in a way that meets your needs. The legal basis for this is:

• Where we have your explicit consent (where appropriate and does not conflict with legal obligation or contractual requirements)

Where the legal basis is consent, you may withdraw your consent at any time.

We may also communicate with you to tell you about community events and to offer additional services.

How we use your information

We will use your contact details to send you electronic or paper communications. We will use the current contact details on your tenancy file, and it is important that you let us know of any changes to your contact details.

For use of photographs etc. in our communications and publications, please see Community events and services

Who we may share your information with

We may share your contact data with carefully selected third parties to deliver electronic and paper communications, including translations where applicable, on our behalf. If we do share data, we will only ever share the minimum amount required; and all third parties are contractually required to ensure that your data is secure and not used for any other purpose.

How long we will keep it

Your contact details are retained on your tenancy files which are retained for six years after the tenancy ends. However, any contact details shared with third parties will only be kept for the duration of that contract.