Privacy notice - Community benefit programme

When you start your new job or training course, created as a result of a Wheatley Housing Group contract, we will ask you for information about yourself and your background.  The information is only used to monitor jobs and training opportunities resulting from Wheatley Group contracts.

We will ask you for the following personal information:

• Contact details – name, address, email address, date of birth, National Insurance number etc
• Employment status
• Education history
• Housing status
• Financial circumstances
• Equality information – for example, disability, ethnic origin.

We will process your personal information through our legitimate interest to check that our contractors and suppliers meet the terms of their agreement with Wheatley Housing Group to create employment or training opportunities for our customers.

It is necessary for relevant information regarding yourself, and relating only to your placement, training and/or the subsequent course of your employment, to be passed to Wheatley Group to enable it to monitor Contractor and Employer performance in delivering Community Benefits.

Where we process your personal information in pursuit of our legitimate interests, you have the right to object to us using your personal information for the above purposes. If you wish to object to any of the above processing, please contact us on 0141 274 8514 or email foundation@wheatley-group.com.  If we agree and comply with your objection, this may affect our ability to undertake the tasks above for the benefit of our customers.

We are also under a legal obligation to process certain personal information relating to our community benefits to support the completion of an annual procurement report for the Scottish Government as required by the Procurement Reform (Scotland) Act 2014.

We may ask you if we can process your personal information for additional purposes.  For example, in order to evaluate the performance of the programme we may ask you to complete questionnaires issued by or on behalf of Wheatley Group, and to participate in evaluations that Wheatley Group or it’s representatives may conduct. We may also ask you to take part in a case study. Where we do so, we will provide you with an additional privacy notice with information on how we will use your information for these additional purposes.

We may transfer information about you to other Wheatley Group companies for purposes connected with the Community Benefits programme or the management of the company’s business.

We may share personal information with our professional and legal advisors for the purposes of taking advice.

Collated Community Benefit data will be provided in reports to our Board, partners and funders including the Scottish Government. Your specific personal information will not be shared in any of these reports.

Wheatley Group employs third party suppliers to provide services, including our case management system Advice Pro. These suppliers may process personal information on our behalf as "processors" and are subject to written contractual conditions to only process that personal information under our instructions and protect it.

Our contractors are required to comply with the law and our own Data Processing Agreement or Data Processing Clauses within our contracts to ensure data is managed appropriately and for specified purposes.

In the event that we do share personal information with external third parties, we will only share such personal information strictly required for the specific purposes and take reasonable steps to ensure that recipients shall only process the disclosed personal information in accordance with those purposes.

Your personal information is stored on our paper and IT filing systems which may be copied for testing, backup, archiving and disaster recovery purposes. All data is held within the UK.

If any of your personal information is transferred out with the European Union or the European Economic Area by any of our contractors we will ensure that there are adequate safeguards in place to protect your personal information in accordance with the General Data Protection Regulations and applicable UK Data Protection Legislation.

We will only keep your personal information for as long as necessary to monitor the performance of the contract with our contractor or supplier and to safeguard the Wheatley Group in the event of any claims, complaints, litigation, enquiries or investigation relating to your training or employment opportunity.

We have a data retention policy that sets out the periods for retaining and reviewing all information that we hold. This sets out different retention periods and you can request a copy by contacting us at 0141 274 8514 or by emailing foundation@wheatley-group.com

You can exercise any of the following rights by writing to us at 25 Cochrane Street, Glasgow, G1 1HL or foundation@wheatley-group.com

Your rights in relation to your personal information are:

• you have a right to request access to the personal information that we hold about you by making a "subject access request";
• if you believe that any of your personal information is inaccurate or incomplete, you have a right to request that we correct or complete your personal information;
• you have a right to request that we restrict the processing of your personal information for specific purposes; and
• if you wish us to delete your personal information, you may request that we do so.

Any requests received by Wheatley Housing Group will be considered under applicable data protection legislation. If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner's Office at www.ico.org.uk

The accuracy of our information is important to us - please help us keep our records updated by informing us of any changes to your personal details.

Our Privacy Notice is regularly kept up to date and this version was updated on 15 June 2018. The latest version is always available on our website.