Privacy notice - TechShare

The Wheatley Foundation is the charitable trust set up by the Wheatley Group. It is funded by the Group and its subsidiaries to benefit our customers. Maximising social inclusion, jobs, and training and education outcomes for our customers is a key Wheatley Group priority.

To support this, the Foundation delivers our TechShare project which provide refurbished laptops and iPads to Wheatley Housing and Care customers. The aim of TechShare is to improve digital access for our customers and relieve the financial pressure of buying digital devices.

Frontline staff including Housing Officers, Employability Advisors or Wheatley Care staff can refer you for a device if they are available and you have a specific need for accessing a device.

Wheatley Foundation will be the "data controllers" of the personal information that has been provided to us. This information is required to process your referral and provide the device to you.

Our Data Protection Officer is Ranald Brown who can be contacted on wheatleydataprotectionofficer@wheatley-group.com

Why we need your personal information 

A Wheatley Group member of staff will ask your consent to be referred to Techshare. If you consent, the staff member will provide us with the following information to process the referral:

• Name, address, contact details

• Household composition

• Why you need the device;

• Ethnicity, Age Range, Disability (This data will be used solely for the purposes of analysis and reporting, helping us to understand who we are reaching and identify any gaps or barriers in service provision)

Why we need your personal information – legitimate interest

We will process your personal information in pursuit of our legitimate interest to provide you with support as our tenant, specifically so that we can provide you with a digital device. We will use your personal information to:

• Process the request for an ipad or laptop

We will collect your personal information via a referral form which will be completed by a member of Wheatley staff. This will be processed by a staff member of the Wheatley Foundation and you will be provided with an ipad or laptop that has been requested on your behalf.

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 InformationRequests@wheatley-group.com

If we agree and comply with your objection, this may affect our ability to undertake the tasks above for your benefit.

We collect information relating to equality, diversity and inclusion (EDI), such as ethnicity, age and disability status. This data is used solely for the purposes of analysis and reporting, helping us to understand who we are reaching and identify any gaps or barriers in service provision. We use this information to improve access, tailor support, and ensure fair treatment for all customers.

Other uses of your personal information 

We may ask you if we can process your personal information for additional purposes.  For example, to promote Techshare or to report on the successes of the programme. 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.

Furthermore, in order to carry out research and evaluation around 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 take photographs and video footage at events we organise or take part in, at our offices and in our communities to use for general marketing and publicity. We may also ask you to take part in case studies to demonstrate the impact of the project, and this is entirely voluntary. 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.

Who we share your personal information with

We will not share your information with anyone outside the Wheatley Group.

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

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.

We may need to share personal information with local authorities, government departments and agencies, with our regulator and auditors, with utility companies or with other organisations and agencies where we are legally allowed to do so.

We may be required to share personal information with Statutory or Regulatory authorities and organisations to comply with statutory obligations. We will only share information on the basis of your consent or in accordance with UK data protection legislation.

How we protect your personal information

Your personal information is stored on our electronic filing system and our servers which are based in the UK and is accessed by our employees for the purposes set out above.

How long we keep your personal information

We will keep limited data (name, address and EDI information) for TechShare device recipients for a minimum 5 year period.

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

Your rights

You can exercise any of the following rights by writing to us at 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 the Foundation 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