Privacy Notice Non-Executive Directors (NEDs)

Author: Carl Dixon / Blake Morgan

Effective Date: December 2024

Next Review Date: December 2027

If you require this document translated or issued in a format which is more appropriate for you, please contact us.

Introduction

Agamemnon Housing Association Limited, is a registered social landlord, regulated by the Financial Conduct Authority, with Register Number 21084R, of Agamemnon House, Lindisfarne Close, Portsmouth, Hants PO6 2SB.  We are committed to protecting your privacy. Please read this notice carefully as it contains important information on how we collect and process your personal information. It applies to our Non-Executive Directors and applicants for Non-Executive Director positions.

Agamemnon Housing Association Limited is a data controller.

1. Where we collect information from

a. We collect information about you from a number of sources, including from you directly and from third parties. We will collect personal information from you when:

i. you fill in one of our forms;
ii. you call, write, e-mail or meet with us;
iii. you visit our website;
iv. you apply to become a Non-Executive Director.

b. We collect information about visitors to our website, this is mostly statistical data about pages visited.

c. We may also collect information such as your image on CCTV or through sound recording equipment at our properties. We sometimes use these to gather evidence of breach of tenancy, alleged anti-social behaviour or crime. We also sometimes take photographs at events, at our properties and in our communities to use in our marketing and publicity materials. Please let us know if you do not wish us to use these photos.

d. We may receive personal information about you from third parties, including:

i. your current and/or previous employer or directorships;
ii. your referees;
iii. HMRC;
iv. other government departments, agencies and regulators.

2. What information we may collect

a. The information about you that we may collect and store includes:
i. Your name and address;
ii. Your contact details including your email address and phone number;
iii. Proof of your identity, your national insurance number and date of birth;
iv. Financial information;
v. Details of your Next of Kin;
vi. Career history and details of positions held;
vii. Recordings of meetings you attend, events and decisions involved;
viii. Statistical information such as postcode, preferences and interests and other information relating to surveys.

b. We may also collect special categories of personal information, including information about your ethnicity.

c. If you do not give us the information we ask for, we may not be able to continue with your application to become a Non-Executive Director or you may not be able to hold a position as a Non-Executive Director.

3. How we use your information

a. We use the information we collect about you to help assess your suitability for the position of Non-Executive Director, consider well how your skills and experience match with our needs and approve your appointment if we choose to appoint you. We will also use your information to support attendance at events and meetings, and manage your role as a Non-Executive Director, if appointed. The information will also be used to fulfil our legal and regulatory requirements and pay you any remuneration and expenses as appropriate.

b. We will also use your personal information to contact you directly. This will usually be in writing, via telephone, verbally during meetings or electronically via email.

c. We may share some of the information we have collected about you with others, including our regulators. But we will only do this where we are allowed to or required to do so by law, or where we have your permission to do so. Before we share your information, we make sure that those we are sharing it with will look after it securely and appropriately. Certain information on Non-Executive Directors is available to our tenants.

d. We have the following lawful basis for using your personal data: (i) for the purpose of considering an application for a position or role with us and managing your role as Non-Executive Director; (ii) with your consent which may be implied if you voluntarily share information with us; (iii) for our legitimate interests as a housing association, and/or administration concerning Association business (as appropriate) which will include ensuring appropriate governance of the Association and obtaining feedback or other information to comply with our statutory obligations as a housing provider.

e. We may share your information with:

i. Government departments and agencies;
ii. The Regulator of Social Housing & Housing Ombudsman;
iii. Our auditors;
iv. Other organisations and agencies where we are legally allowed to do so.

f. We will not give, sell or lease your information to any third parties for marketing purposes. We may use your information to send you details of our events.

4. How we take care of your information

a. All of your personal information is kept on computer systems in the UK. The information on these systems may be copied for testing, backup, archiving and disaster recovery reasons. Our computer systems are maintained carefully to provide a high level of security.

b. We will not transfer or store your personal data outside of Europe (the EEA) or to a country outside of the control of the UK or European regulations.

c. We store personal information for different lengths of time depending on your relationship with us.

i. If you are a Non-Executive Director, information will be kept for a period not exceeding three years after you have left the board of directors, except financial information which will be kept for a period of seven years after you have left the board of directors.
ii. CCTV images are usually only held for 30 days before being overridden, unless there is a specific incident which requires a portion of the CCTV to be recorded for a longer period – when we will hold it as required by the law.
iii. If you do not become a Non-Executive Director, we will keep your information for a maximum period of three years.

d. We will destroy your information securely when we no longer need it.

5. Your Rights

a. You have rights under data protection law to protect and take care of your personal information. Where you have given your consent for us to use some of your personal information, you can withdraw this at any time. You can also ask us:

i. For a copy of the personal information that we hold and process about you;
ii. To give you your information in a portable way;
iii. To correct any inaccurate information about you;
iv. To delete your personal information;
v. Not to make decisions about you in a fully automated way.

b. These rights may apply in limited circumstances, and we may not always be able to comply with your request. We will tell you when this is the case.

c. We will aim to respond to your request within one month of receiving it. If you would like any of your information to be corrected, please contact us using the details below. Where information is corrected, we will provide you with proof of this.

d. If you have any questions or concerns about this notice or how your personal information is being processed, please contact our Data Protection Officer at our head office. The address is: Agamemnon House, Lindisfarne Close, Portsmouth, PO6 2SB; enquires@agamemnon.org.uk.

e. The Information Commissioner can provide independent information about keeping your personal information private, and you can also complain to them about how we have used your personal information if you wish to. Their website is: https://ico.org.uk/

6. Changes to this Privacy Notice

a. This Privacy Notice will be updated from time to time. When this happens, the most up to date version will always be available on our website: https://agamemnon.org.uk.