Privacy Policy
We are committed to protecting and respecting your privacy
What this is about
The Empty Homes Network (‘EHN’)is committed to protecting and respecting your privacy.
This Policy explains when and why we obtain personal information, how we use it, the conditions under which we may disclose it to others, and how we keep it secure.
We may change this Policy from time to time. We’ll always publicise changes to the Policy to our registered Members and Subscribers. Otherwise, you will need to check this page occasionally to learn about any changes. By using our website or communicating with us you’re agreeing to be bound by this Policy.
For further information or enquiries, refer to our contact details below.
Personal data — what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller's possession or likely to come into such possession. Something as simple as a work email address is personal data e.g. jane.smith@company.com. (See https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-personal-data_en for examples).
Summary of our privacy policy
The Empty Homes Network aims to comply with the statutory requirements around the processing of personal data, as expressed in the EU General Data Protection Regulations, which are effective as of 25th May 2018, and the UK’s Data Protection legislation, including the Data Protection Act 2018, which started to come into effect from 23rd May 2018. This means, in particular, that we:
process your personal data lawfully
do so transparently, so you are aware of what we do
make you aware of your legal rights
keep your personal data secure
For fuller details of the framework that governs how we operate, please refer to the Information Commissioner’s Office website at www.ico.gov.uk.
Processing your personal data: key points
The Empty Homes Network is a not-for-profit membership organisation the main purpose of which is to facilitate sharing of information amongst our members relevant to our professional involvement in helping bring empty property back into use for housing. Accordingly:
we aim to collect and retain the reasonable minimum of personal information we need to operate in the legitimate interests of the collective membership
we never sell your personal data to third parties
we never pass on your details to third parties without your permission unless legally required to do so (an eventuality that has so far never occurred)
any advertising which you may occasionally receive from us is first assessed to establish that it contains information that is of broad interest to our members as people who have met the eligibility criteria for membership.
Archive and current data
Current data is data that has a current practical relevance or operational use. It also includes data relating to active matters that came to a definitive end less than one year previously.
Archived data is data retained long-term. It is stored in a separate folder structure and is selected for archiving purposes following a data minimisation process that is compatible with the purpose of the archive. It may be used by us for the strategic management of the organisation, taking into account its development over the longer term.
For details of our data retention policies please refer to our Records Management Plan - Principles and Policies and more particularly to the details in our EHN Records Management Registers .
Purpose and legal basis for processing your data
The purposes for which we process your personal data are set out in more detail below.
The legal basis for that processing is to serve the legitimate interests of the Empty Homes Network:.
As regards current data, it is to serves our legitimate operational interests, which include
facilitating communication amongst our members via the internet
the effective and efficient administration and governance of ourselves as a membership organisation
communicating about policy with interested parties
organising events and liaising with delegates and speakers
dealing with enquiries from members of the public
dealings with suppliers
As regards archived data, it serves our legitimate interests by allowing us to examine trends over longer periods of time, providing strategic oversight; moreover, it is our intention to make our records available – subject to adequate security and anonymization – for historical research purposes, given the unusual organisational profile of the Empty Homes Network and its contribution as a national not-for-profit organisation in an area of public interest.
Your rights
You have a number of rights under data protection rules. If you want to exercise your rights, please see the contact details below and email, phone or write to us in the first instance. The rights listed are based on the EU General Data Protection Directive in force from 25th May 2018. For the Information Commissioner’s view of what your rights are, see https://ico.org.uk/your-data-matters/.
You have the right to be informed: that’s what this Privacy Notice is all about - letting you know about how we handle your personal data.
You have the right to request personal information that is held about you. This is called a ‘subject access request’.
You have the right to have incorrect data corrected and incomplete data completed.
You may have a ‘right to be forgotten’ i.e. to have personal data about you erased. This is not an absolute right and can involve a balancing exercise.
You have a right to restrict the use of data (normally as a temporary measure).
You have the right of data portability, meaning you can request us to give you certain personal data in a structured way so it can be re-used. If the request seems excessive, we may charge a fee or refuse the request.
You have the right to object to us processing your data.
If, preferably after first contacting us, you think we are not responding to any request from you satisfactorily, you may wish to contact the Information Commissioner’s Office. You can phone them on 0303 123 1113, or visit their website at https://ico.org.uk/concerns/ for further information about raising concerns.
How we process the data we control
Casual website visitors
We do not attempt to collect any personal information from people casually visiting our website.
Ex-members
We do not use available personal data to communicate with ex-Members except during the actual administrative processes associated with terminating the membership.
Subscribers and Members: data we collect
We collect minimal information from people registering on our website as Members or Subscribers. This is stored in the Content Management System database in a secure area on the internet.
Your email address is used by the Content Management System to send you automated notifications of new content, the frequency of which is under your control from your Account page.
It is also used to distribute Newsletters by email. You can unsubscribe from these from your Account page.
Occasionally, we send emails to our Members that are outside the framework of newsletters and subscriptions but concern important matters that we feel all our Members should be aware of and are likely to be essential to the effective running of EHN. These might, for example, include notifications about democratic processes, key events such as an Annual Conference or reminders about aspects of how EHN works. If you did not want to receive such emails you would need to terminate your membership of the Network.
Your username is an essential part of your account registration. It appears against any content published by you and, depending on the area of the website within which it is posted may be visible to casual website visitors. Under our Terms and Conditions, you consent for this information to appear as part of the publication process.
Your password is stored in an encrypted form and cannot be decrypted by anyone, including administrators. It can be known only by you.
Your telephone numbers are only visible to administrators and may occasionally be used for membership administration; they may also be used to contact certain individual members when we are conducting research into specific issues or news stories.
Members, if logged in, are able to access the Membership List, which includes current members only. The Membership List provides the names, job titles, employing organisations, if any, and type of membership of our members. These details are also used by EHN in membership administration.
Subscribers (who pay to access EHN materials but are not members) are not listed in the Membership List, and conversely the Membership List is not available to Subscribers.
Our Content Management System keeps temporary records of certain activities such as logging in (or attempting and failing to do so) which identify individual users. These records expire after two months. They are needed for website administration, such as addressing technical issues should they arise.
For details about data retention and personal data in back office files such as emails, finance record and event booking records, refer to our Records Management Registers.
Data security
All digital files are stored encrypted by Windows bitlocker on all hardware storage devices maintained by EHN. This means the information cannot be decrypted by anyone who comes into the possession of the hardware unless they also have the passkey. The passkey is not written down anywhere by the person in possession of the hardware.
A reasonable minimum of data is held online, with older data cleansed at early opportunities.
Access to data online is protected by strong administrator passwords which are not written down.
Passkeys or passwords are retained (but never used operationally) by a maximum of two Officers of EHN, in case the main passkey-holder is incapacitated.
For fuller details about security, refer to our Records Management Plan - Principles and Policies and Records Management Registers.
Automated processing
As noted earlier, our Content Management System by default automatically sends email notifications of new content to registered Members and Subscribers, but you may over-ride the defaults via your account page or stop them altogether.
Accountability
The Data Controller is the Empty Homes Network, an unincorporated association. It is contactable as follows:
By post:
Empty Homes Network
PO Box 703
Exeter
EX1 9PX
By phone on 0303 04 01 008 (leave message)
By email at admin@ehnetwork.org.uk
EHN is registered with the Information Commissioner's Officer. Our certificate can be viewed here.
The Data Protection Officer role is outsourced to David Gibbens, trading as peer2peer services, and contactable as above or by direct mobile at 07528 312932. Additionally, as a Data Processor for EHN, David is contractually bound to comply with and implement the requirements of this policy.
Questions and complaints
Please refer all questions and complaints to the Data Protection Officer in the first instance (see details above). Note that all complaints and any responses to them are notified to the EHN Officer Group as a matter of course.
Cookies
Our website uses cookies. A cookie is a small file of letters and numbers that we put on your computer, if you agree. These cookies allow our website to distinguish your computer from others using the website at the same time. Cookies also help us to provide you with a good experience when you browse our website. Our cookies do not store your personal information.
You can turn cookies off, but if you do so, parts of the website may not work properly.
To learn more about cookies please refer to our About Cookies page.
REVISIONS
2018-05-30 Applied for registration with ICO.
2018-06-06 Changed "This Policy explains when and why we collect personal information" to This Policy explains when and why we obtain personal information "
Noted that EHN is registered with ICO and provided link to the certificate.
Revised the Purpose and legal basis for processing your data. Previous wording:
The legal basis for that processing is twofold.
As regards current data, it is to serve the legitimate interests of the Empty Homes Network, which include
facilitating communication amongst our members via the internet
the effective and efficient administration and governance of ourselves as a membership organisation
As regards archived data, it serves our legitimate interests by allowing us to examine trends over longer periods of time, providing strategic oversight; moreover, it is our intention to make our records available – subject to adequate security and anonymization – for historical research purposes, given the unusual organisational profile of the Empty Homes Network and its contribution as a national not-for-profit organisation in an area of considerable public interest.