Protecting your privacy
Clúid Housing Association is committed to respecting and protecting your privacy. We will always take great care to fulfil our responsibilities under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. At Clúid we collect personal information about you and are committed to protecting this information and your privacy. This includes when accessing Clúid’s services, signing a tenancy agreement or visiting our website. This statement sets out the basis on which any personal data we collect, use, and store or obtain from or about you will be processed by us.
Who are we?
When we talk about “Clúid”, or “us” or “we” in this statement, we are talking about Clúid Housing Association of 159-161 Sheriff Street Upper, Dublin D01 R8N0 and we are the data controller for the purposes of the General Data Protection Regulation and Data Protection Act 2018.
Clúid is a registered charity whose principal activities are in the provision of social housing across a wide spectrum of housing needs.
What information do we collect about you?
The information we hold on our records concerns our relationship with you. For example, we could hold the following types of data about you:
Identity and contact data: Includes first name, last name, username, title, date of birth, gender, PPSN and identity documents (e.g. drivers license, passport, PSC), phones numbers, email addresses and next of kin details.
Behavior data: Includes a record of your compliance with your tenancy with us.
Financial data: Includes the amount of money you have paid us, any amounts outstanding and associated recovery action.
Profile data: Includes who lives in our houses, your user name and password (Resident Portal App), feedback and survey responses.
Technical data: Includes internet protocol (IP) address, your login data, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and other technology on the devices used to access this website and Resident Portal App.
Transaction data: Includes details about payments made from and to you.
Usage data: Includes information about how your use our website and Resident Portal App.
Other data: Includes CCTV images, telephone recordings, webchat recordings, criminal conviction data.
We may collect Special Categories of Personal Data about you (e.g. health/medical information). Generally the information we hold will have been provided by you.
We will only ask for personal information that is appropriate to enable us to deliver our services. If you do not provide this information, we may not be in a position to process your request.
We may occasionally receive unsolicited correspondence from members of the public which contains personal data relating to third parties (“Third Party Data”). We may process this data for the purposes of replying to correspondence, dealing with queries or complaints and complying with our legal and regulatory obligations. The legal basis on which we process Third Party Data is that this is necessary for our legitimate interests in conducting our business and ensuring proper management and functioning of Clúid.
How we use your information?
The personal data that you provide to use will enable us to fulfill our obligations to you and provide you with the appropriate services and support that you may require. Clúid must have a legal basis to process your personal data. Usually this falls within our contractual obligations to fulfil your tenancy agreement, however it could be through your consent or may be necessary for the legitimate interests of Clúid.
To enable Clúid to provide you with the best service possible, we may use your personal data:
for market research purposes and to get your views and feedback to help us improve the services you receive.
We may contact you about our services and products and ask you if you would like to get involved in the activities or groups which we hold e.g. National Residency Advisory Group (NRAG) and Clann Residency Advisory Group (CRAG).
Our legal basis for processing your information
Contract: the processing is necessary for a contact we have entered into with you, or because you have asked us to take specific steps before entering into a contract. Failure to provide such personal data would mean that we are unable to provide our service to you.
Consent: You have given clear consent for us to process your personal data for a specific purpose. Where consent is the lawful basis for processing, you have the right to withdraw your consent at any time.
Legal obligation: The processing is necessary for us to comply with the law.
Legitimate interests: The processing is necessary for our legitimate interests, or the legitimate interests of a third party, unless there is as good reason to protect your personal data and rights and freedoms which would override those legitimate interests.
Vital interests: The processing is necessary to protect someone’s life.
Who do we share your information with?
On occasion, it will be necessary to share your personal data with third parties. For example, Clúid uses a number of contractors to maintain and service our properties. We will only share relevant and necessary information with them.
Where personal data is shared, we ensure appropriate technical and organisational safeguards are used to protect your personal data.
Clúid does not share your information with any organisation outside of the European Economic Area (“EEA”).
How do we keep your information safe?
We are committed to holding your personal information securely. Our security measures comply with the law and international standards, access is given only to those that need it and our computers, files and buildings are secure.
Any information you submit during the course of online interaction through our website and Resident Portal App is stored securely in compliance with the law and international standards.
How long we keep your information?
We will not hold your personal information for longer than is necessary. We retain your personal information for as long as we need it for the purposes described in this statement, or to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise between you and us.
You have a range of rights under data protection law in relation to the way we process your personal information, including:
- right to request access to a copy of your personal data;
- right to have personal data rectified if it is inaccurate or incomplete;
- right to erasure (‘right to be forgotten’) in certain scenarios;
- right to restriction of processing, in certain scenarios;
- right to data portability only applies to data you have provided to us;
- right to object to processing, including automated decision-making.
Clúid does not make decisions about you automatically or carry out profiling.
Privacy policies of other websites
Changes to our privacy statement
Clúid keeps its privacy statement under regular review and places any updates on this web page. This privacy statement was last updated in June 2021.
How to contact us
If you have any questions about this privacy statement, the data we hold on you, or you would like to exercise your data protection rights, please do not hesitate to contact us.
You may contact our Data Protection Coordinator on firstname.lastname@example.org
or in writing to Data Protection Coordinator, 159-161 Sheriff Street Upper, D01 R8N0.
How to contact the appropriate authority
Should you wish to report a complaint or if you feel that Clúid has not addressed your concern in a satisfactory manner, you may contact the Data Protection Commission through their website https://www.dataprotection.ie/en/contact/how-contact-us