Andium Homes Limited, referred to as ‘Andium Homes’, ‘we’ or ‘our’, is committed to protecting the privacy and security of your personal information.
This Privacy Notice describes how we collect and use personal information about you during and after your relationship with us pursuant to the Data Protection (Jersey) Law 2018 (“DPJL”).
Andium Homes is a “Data Controller“ meaning we are responsible for deciding how we hold and use personal information. We are also registered with the Jersey Office of the Information Commissioner (“JOIC”) – Registration No. 16312.
We will comply with data protection law, the principles of which says that the personal information we hold about you must be: –
- Used lawfully, fairly and transparently.
- Collected only for valid purposes that we have clearly explained to you and not used in any way incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Keep your data only for as long as necessary for the purposes we collect.
- Kept securely.
Andium Homes is accountable to you and the authorities for showing compliance with DPJL and demonstrating how we are compliant.
The Data Protection Officer (“DPO”)
We have appointed a DPO to oversee compliance with this Privacy Notice.
If you have any questions about this Privacy Notice or how we handle your personal information, contact the DPO at dpo@andiumhomes.je
You have the right to complain to the JOIC at any time.
Contact details for these are outlined at the bottom of this Privacy Notice.
The Kind of Information We Hold About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
To explain this, we will list our different services when we collect or use additional information about you.
How Is Your Personal Information Collected?
When you contact us, engage us to provide a service or provide us with your data for another specific purpose we collect personal information about you.
What information do we collect about you?
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· Name · Title · Date of Birth · Address · Identification documents · Social Security Number · Spouse and sibling’s details · Tax information |
· Telephone number · Occupation · Email address · Signature · Bank details · Tenancy agreement details · Vehicle registration numbers and ownership details |
What Special Category Data do we collect about you?
Andium Homes will only collect data relevant to your ability to gain access to your home address and have adequate accommodation. This data will be any information relating to your health condition and general mobility, which is special category data pursuant to Article 9 of the DPJL.
Special Category data is any health data, amongst other indicators, not collected by Andium Homes.
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· Health information. · Mobility information. |
· Sight or Hearing impairments. · Occupational Therapist assessment. |
Use of CCTV and Audio Recordings?
Andium Homes use CCTV in their main office building reception to capture your image when you enter and any movement within this area. CCTV is also used within some of the residential building’s underground car parks, external car parks, external areas, entrances, stairways, corridors, and elevators. CCTV is used to detect and prevent crime, ensure the safety of residents and visitors to the premises, and ensure the health and safety of any Andium Homes staff or contractors working on the premises. It is also used in any internal team member disputes or disciplinaries. All recordings are retained for 30 days.
When you contact Andium Homes by telephone, the calls are recorded for training and customer service. These recordings can be used as evidence if any party is rude or abusive and will be retained for 7 days only.
How We Will Use Information About You?
We will only use your personal information when the law allows us to.
Most commonly, we will use your personal information in the following circumstances:
- You have entered a Contract with us to provide you with a service; an example would be when you entered into a tenancy agreement with us for one of our properties.
- The processing is necessary for Legal Obligation; this is where Andium Homes has a legal duty to process your information; for example, under the Housing laws, we must ensure you are entitled to live in the property we provided.
- Where the processing is allowed under Public Function, we can share data with other parties, such as the government, to ensure we have accurate details about you and your circumstances.
- Where it is necessary for our Legitimate Interests (or those of a third party), your interests and fundamental rights do not override those interests. An example is when we use CCTV to monitor the safe environments where you live or record telephone conversations for training and customer service purposes.
We may also use your personal information in the following situations, which are likely to be rare:
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- You have Consented to contact us for a specific purpose, such as receiving marketing material about Andium Homes services or being on a waiting list for a home.
Change of purpose
We will only use your personal information for the purposes we collected it unless we reasonably consider that we need to use it for another reason. That reason is compatible with the original purpose.
If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.
Data Sharing
We do not pass on information gained from your engagement with us without a clear legal basis. However, we may disclose your Personal Information to meet legal obligations, regulations, or valid governmental requests.
We use certain third parties, or Processors, to provide or support our services. We have appropriate agreements with those processors to ensure the safety of your information. For information on these processors, please see the table below.
We may share your information with processors for direct marketing purposes if you are on our waiting list of individuals looking to rent or purchase a property. In this instance, we will provide your information to authorised local estate agents who will assist us with the available properties.
The current data processors used by Andium Homes are:
Processors are other organisations/services carefully chosen by Andium Homes to process your information correctly and securely. In the case of organisations outside of Jersey, the United Kingdom and the European Economic Area (EEA):
(a) we have prior written instructions for the transfer or
(b) We have entered specific contractual terms with them to ensure that they treat your personal data in a way that is equivalent to what they would be required to do if they were established in Jersey.
We ensure that your privacy rights are respected in line with this notice and the same protection is given to your data as laid down by the DPJL.
Data Security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, altered, disclosed, or accessed unauthorised. In addition, we limit access to your personal information to those Staff, Agents, Contractors and other third parties on a need-to-know basis.
They will only process your personal information on our strict instructions and are subject to a duty of confidentiality.
Details of these measures may be obtained from our DPO.
We have put in place procedures to deal with any suspected data security breach and notify you and any applicable regulator of a suspected breach where we are legally required.
Data Retention
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data and the potential risk of harm from unauthorised use or disclosure of your data. The purposes for which we process your data and whether we can achieve those purposes through other means and the applicable legal requirements.
You can request our Data Retention Schedule from our DPO if required.
In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use it without further notice.
Access to and control of your personal information
Rights of Data Subjects
You may have certain legal rights concerning the Personal Information processed by Andium Homes pursuant to DPJL.
- the rights of access;
- right to have your data corrected, updated, rectified or erased;
- right to object to the processing of or restrict the processing of your data;
- right to withdraw your consent previously given to the processing of your data and to
- request the transfer of your data to another party.
Please note that the rights set out above are subject to certain exemptions and conditions. We may decline to comply with any request to access, correct, delete or restrict the use of your information if there is a specific legal ground or exemption.
Where we are processing your information based on contractual necessity or legal and regulatory requirements, the provision and processing of such information will likely be mandatory. In addition, where the provision of your Personal Information is generally a contractual or legal requirement or is a requirement for us to enter into a contract if you choose not to provide any Personal Information or to exercise one or more of the rights above to restrict the processing of your information, this may limit the services which Andium Homes can provide.
If you wish to exercise any of your rights, send your request to dpo@andiumhomes.je We will respond to your request in accordance with Data Protection Legislation.
We reserve the right to ask for proof of your identity and address (such as a copy of your driving license or passport – please do not send any original documents), and we also further reserve the right, under DPJL, to request for additional information reasonably required to identify the specific information being requested or referred to, or any additional information reasonably required to confirm your identity.
To complete our Data Subject Access Request online form please click here. If you have any questions about this process or your rights, contact our DPO at dpo@andiumhomes.je . You can also email or verbally make your request over the telephone to one of our team, whatever way you feel more comfortable with.
We will respond to your request without undue delay, but certainly within four weeks after satisfactory identity verification. In some circumstances, we can apply an eight-week extension to this time frame if the request is complex and cannot be answered in four weeks. If this is to happen, we will inform you as soon as possible.
Right to Withdraw Consent
In the limited circumstances where you may have provided your consent to collect, process and transfer your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
To withdraw your consent, contact our DPO at dpo@andiumhomes.je
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to unless we have another legitimate basis for doing so in law.
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates.
We may also notify you in other ways from time to time about processing your personal information or requesting you to confirm the accuracy of the information we hold on you.
Complaints
We want to resolve any complaints you have about how we process your information. You have the right to complain to the JOIC about how we have used your data.
The details for each of these contacts are:
Andium Homes Limited
33 – 35 Don Street, St. Helier, Jersey JE2 4TQ
Telephone +44 (0) 1534 500700 or email dpo@andiumhomes.je
Jersey Office of the Information Commissioner (JOIC)
2nd Floor, 5 Castle Street, St Helier, Jersey JE2 3BT
Telephone +44 (0) 1534 716530 or email enquiries@jerseyoic.org