Sensitive categories of personal data

Updated: 17th May 2018

Introduction

Our Privacy Notice explains how Dot Dot Dot uses personal data and the reasons why we collect certain types of data in the course of carrying out our business activity and operations.

Whilst the Privacy Notice describes our overall approach, this document is intended to clarify in more detail when and where we collect special and sensitive categories of personal data.

Dot Dot Dot recognises that there may be reluctance or misapprehension amongst some individuals when such data is collected, given the sensitive nature of the information requested and the risk of individuals suffering potentially greater detriment if the information were to be misused or inappropriately shared.

We hope that this document can:

  • provide clarity about why we ask for personal data in these more sensitive categories, so everyone is clear about how the information is provided and how it is relevant to Dot Dot Dot’s business operations
  • increase confidence in individuals providing such data, so individuals provide data with the reassurance that it will be carefully stored, and processed fairly and confidentially
  • for diversity information, increase reporting rates which in turn allow Dot Dot Dot to make better business decisions and more accurately report its progress in addressing diversity and inclusion objectives

Categories

There are four categories of sensitive personal data used in our business operations:

Category Applies to:
Applicants for housing People housed by us Applicants for employment[1] and those volunteering directly with Dot Dot Dot
A: Personal financial information including actual or predicted earnings, outgoings, debts whether formal or informal, existence of County Court Judgements, source of funds for licence fees and deposit requirements Required Required Not applicable
B: Proof of identity, nationality and/or immigration status in order for Dot Dot Dot to meet its obligation in law (Right to Rent and employment law, depending on our relationship with the individual) Not required Required Required
C: Self-declared information indicating that an individual has convictions, cautions, custodial sentences that are not ‘protected’ in the meaning of the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (as amended in 2013) Given on a self-declaration basis Given on a self-declaration basis Depends on the job role
D: Demographic information and sensitive personal information sometimes referred to as “protected characteristics” (a term used in the Equality Act 2010) Voluntarily given Voluntarily given Voluntarily given

In this document, we give more detail about each of these categories, and our reasons for collecting personal data of a sensitive nature.

There are currently no other categories of sensitive personal data collected by Dot Dot Dot.

A: Personal financial information including actual or predicted earnings, outgoings, debts whether formal or informal, existence of County Court Judgements, source of funds for licence fees and deposit requirements

We collect this information to conduct affordability assessments when an individual applies for housing. It is in no-ones’ interest to house an applicant who cannot afford to pay the necessary fees to be a guardian, or who cannot afford the returnable deposit that we require before someone becomes a property guardian with Dot Dot Dot.

We will usually require documentary evidence (for example, bank statements, savings account statements or other financial documents) to verify the situation of each individual. We retain this information in accordance with our Privacy Notice and our data and information security arrangements. Information will be retained in accordance with our retention policy.

The information provided in this category is only used by Dot Dot Dot to make informed decisions about the individual’s ability to pay fees for housing on an ongoing basis.

For some properties – where a tenancy is available rather than a licence to occupy – we will ask applicants to participate in a tenancy referencing process carried out by a third party organisation specialising in tenancy referencing. If you are asked to participate in this process, you will be asked to provide information directly to that referencing bureau (normally by web form, or telephone). The referencing bureaus used by Dot Dot Dot are all established, UK entities and have their own privacy notices and ICO registrations. You will be asked as part of the process for a report of the outcome of the reference to be sent to Dot Dot Dot.

B: Proof of identity, nationality and/or immigration status in order for Dot Dot Dot to meet its obligation in law (Right to Rent and employment law, depending on our relationship with the individual)

We need to see a copy of individual’s passport or other suitable identification at the point of confirming an applicant’s suitability for housing by us. To meet our legal obligations, as well as to comply with our internal and external audit requirements, we will create an electronic or paper copy of this and retain this in accordance with our retention policy.

C: Self-declared information indicating that an individual has convictions, cautions, custodial sentences that are not ‘protected’ in the meaning of the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (as amended in 2013)

We ask all applicants for housing to answer a self-declaration question regarding previous criminal records, sentences and cautions. We ask this because most of our housing is shared with other occupants, and because of each property guardians’ responsibility for ensuring the building that they occupy is looked after and kept safe. These responsibilities are over and above what would be expected of an average tenant, so in our view it is proportionate to ask for relevant information in this category.

We ask this question of applicants in the same way that an employer would ask of prospective employees, and we accord the same level of careful and sensitive handling to any information provided.

The question we ask is based on UK Government recommended good practice and is:

Do you have any convictions, cautions, reprimands or final warnings that are not “protected” as defined by the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (as amended in 2013)?

We encourage all applicants for housing to answer this question honestly and openly. If an applicant for housing answers this question in the positive, then more information will be sought by Dot Dot Dot at that point in the application process. This will normally be a telephone discussion.

Decisions are made on a case-by-case basis and a positive answer to the initial question will not necessarily preclude that individual from becoming housed: it depends on the individual’s circumstances and our need to balance a number of business needs whilst also acting fairly and consistently towards the individual.

We do not seek DBS disclosures for guardians because being a property guardian is not – without the presence of other factors (see “Special Projects” section below) – an eligible role for a DBS[2]. Therefore it would be unlawful for us to obtain a DBS in the majority of circumstances.

We ask the same question at recruitment stage for employment roles. The requirement for a DBS disclosure depends on the nature of the job role that the individual holds or is applying to hold.

D: Demographic information and sensitive personal information sometimes referred to as “protected characteristics” (a term used in the Equality Act 2010)

Dot Dot Dot has set out its ambition and business case for Diversity and Inclusion in an Statement of Intent, which recognises three areas:

  • Dot Dot Dot’s role as a housing provider and manager
  • Dot Dot Dot as an employer
  • Dot Dot Dot as a social enterprise with a growing profile

Collecting data is essential ingredient in us being able to make better decisions about how to be more inclusive, to identify opportunities to do different and better and to be able to analyse and review our progress. The types of data we are interested in collecting include:

  • Gender
  • Ethnicity
  • Disability
  • Health (physical health and mental health)
  • Age
  • Sexual orientation
  • Faith or lack of faith
  • Transgender
  • Pregnancy and maternity
  • Paternity
  • Adoptive parenting
  • Socio-economic background
  • Educational attainment
  • Lived experience of homelessness
  • Relationship status

Individuals being asked to provide personal data in this category will always be presented with the possibility to opt out of providing such data. Choosing to opt out will have no effect on that individual’s experience with Dot Dot Dot.

Information will be collected, stored and processed in such a way that it is inaccessible to the majority of employees, and the data will be aggregated and codifed before it is used for analysis, information and reporting purposes. Information in this category about specific individuals will never be used to make individual decisions (for example, whether to offer housing or whether to invite to an interview).

Protecting data

There are a number of general protections, applicable to all categories of personal data. Individuals interacting with Dot Dot Dot benefit from a range of protections, safeguards and rights in terms of how their personal data is collected, stored and processed by Dot Dot Dot. More information can be found in our Privacy Notice {URL}. All of the protections and safeguards in the Notice apply to the sensitive categories of personal data. In addition, special and sensitive categories of data discussed in this document benefit from further enhanced features in terms of processing:

In the case of sensitive personal data of category A, B and C, information is generally only available to the individuals or teams within Dot Dot Dot who need to review this information in order to arrive at a decision. We always aim to arrive at a decision which is fair, consistent and also transparent. Other categories of employee at Dot Dot Dot may have access to information in these categories, but for specific reasons and that access may be time limited or restricted in other technical ways. Examples of this kind of access might include: a manager reviewing a decision or investigating a complaint, or an analyst performing a check that data is held in the correct place and to the correct standard in line with our policies.

In the case of sensitive personal data on category D, information is stored in a way which makes prevents the majority of employees having access to it. This is because the data in this category is intended to be used at a company level, and is aggregated and analysed in order to inform a number of business decisions. Employee’s access to the data therefore mirrors this approach.

Special projects where property guardians live in the same building as vulnerable members of the community

From time to time, Dot Dot Dot will have housing projects in buildings and sites that share communal areas (corridors, lifts, lounges, kitchens) with other people who are not guardians. In these circumstances, we will require to see an existing DBS disclosure for any potential guardian before they take up occupation in these spaces. This DBS disclosure will need to be one connected with an applicant’s existing employment or volunteering.

Dot Dot Dot will store a copy of the DBS in order to demonstrate to its clients that contractual and (where appropriate) legal requirements have been met in terms of assisting client organisations to meet the requirements of their safeguarding and vulnerable adult protection policies, and reduce the risk to their residents.

Statement on restricted lists – otherwise known as ‘blacklists’

Dot Dot Dot is aware that some industry sectors maintain lists of individuals who engage in certain forms of behaviour or who hold certain characteristics and that such lists are sometimes shared or traded between organisations, with the intention of denying certain individuals access or service based solely on their appearance in such a list. Such lists are sometimes referred to as ‘blacklists’. Dot Dot Dot believes such practices are unethical and may indeed be unlawful and does not participate in any such practices.

[1] includes: paid roles whether fixed term or permanent, paid internships, apprenticeships or traineeships

[2] https://www.gov.uk/government/collections/dbs-eligibility-guidance

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