Vivid Living which is part of CBH takes a ‘layered approach’ – shorter notices containing key privacy information that have additional information in a more detailed overarching Privacy Notice maintained here on the Vivid Living website. It relates to customers, other service users and employees and is set out below as a series of questions, clicking on the ‘more’ option will reveal a detailed answer and clicking ‘less’ will close that back up again.
Vivid Living which is part of Cheltenham Borough Homes Ltd is the Controller of personal data collected and managed for Vivid Living tenancies, recruitment and employees.
We welcome any queries you may have about how we use your personal data, or any information we hold about you. Please contact us at the address above or email us at email@example.com
We collect personal data about:
Customers – this includes:
Employees – this includes current, former and potential colleagues, as well as Board Members, apprentices and volunteers.
Other service users – Anyone who makes a complaint or enquiry, visitors to our website and offices, or who may attend a community event that is open to the public or who may rent a garage.
For our customers and other service users we may collect:
For employees (including contractors or temporary workers) we collect:
We may not be able to provide full services and support without this information.
We collect personal data in a number of ways, including, but not limited to:
anonymous statistical information is collected by cookies. These are small text files that are placed on your machine to help the site provide a better user experience. Please see the ‘cookies’ page on our website for more information
if you request a call back or information from us via an email, online form, or register your interest in a service we will use your information to fulfil that request
Some of the properties may have CCTV in external public areas to prevent and detect crime and promote public safety by helping to identify and prosecute criminal offenders. Where cameras are in use signs are publicly displayed in the vicinity.
We collect and use personal data about prospective, current and former customers’, plus members of their household and other relevant contacts to provide/manage:
We may collect other service users’ personal data to:
We collect and use prospective, current and previous employees’ personal data to:
For processing personal data to be legal CBH/Vivid Living must identify a ‘lawful basis for processing’, set out in UK data protection legislation. Where we process more sensitive personal data (‘special category’, criminal offence or children’s data) extra conditions are required to be met.
Whenever we collect personal data we will notify you why, how we will use it and our legal basis for processing (for example to perform a contract with you, or if it is with your consent).
The legal bases under which we process personal data will be one or more of the following:
Where we process special category personal data, which includes; health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, trade union membership or genetic and biometric data.
We also meet one of the following conditions:
Where we process criminal offence data we meet at least one of the lawful bases and have either legal authority for the processing. Where we do need to collect information relating to criminal offences we do so providing appropriate safeguards for the people to whom the data relates. We do not maintain a comprehensive register of criminal convictions.
Children need particular protection when we are collecting and processing their personal data because they may be less aware of the risks involved. Where we process children’s personal data we consider the need to protect them from the outset, and design approach and processes with this in mind. We must meet at least one lawful basis and should consent be the most appropriate this is only applicable for children aged 13 or over, below this age requires consent from the person/s with parental responsibility. Children have the same rights as adults over their personal data.
More detailed information on the lawful bases and these three areas of more sensitive personal data can be found on the ICO’s website.
Your personal data will be kept secure and confidential.
We may sometimes need to share information with contractors who may deliver services on our behalf or other third parties, agencies or organisations to help support you. This may occur when we believe that it is in your or the public’s interest to do so, or is required by law or where it is necessary to do so for the prevention and detection of crime, including fraud. It may also be necessary to provide statistical data to government departments. Where this is necessary, we are required to comply with data protection legislation.
Examples of organisations we may share your information with, where appropriate, are:
Where we share personal data it is always carried out securely and with clear guidelines as to what is being shared, why, with whom, and for how long.
We are committed to ensuring that your information is kept safe and secure. We have a protected IT infrastructure, which restricts access to systems and personal data by using effective password management. Measures are also in place to mitigate the likelihood of cyber attacks being successful.
Should it be accessed using mobile devices, these are encrypted and are capable of being wiped clean of all data remotely. Where we need to transfer personal data we will do this via a secure transfer or using an encrypted removable storage device.
Personal data is held within the European Economic Area (EEA) where we store and process this information on our IT systems. Where it is necessary to transfer personal data outside the EEA, this is done in compliance with data protection legislation.
We also have a number of physical security measures in place, such as secure office access, office security and confidential destruction of all waste paper. For more information please contact us
We carry out regular training and awareness-raising with all colleagues to highlight the need to keep personal data safe.
We keep your information in line with statutory periods of retention, or where we have a legitimate business need and dispose of any personal data securely.
Information relating to homelessness or housing applications will be kept for up to 3 years following a decision being made or a successful application. Information relating to either that has been withdrawn or removed will be kept for up to 6 months. After this it will be securely destroyed.
Information relating to benefit and money advice will be kept for up to one year before it is securely destroyed.
We keep personal data relating to tenancies for the duration of the tenancy and a limited amount of information for up to 6 years after that. We may keep certain data for longer than this, for example should there be any debts owed.
We keep employees’ personal data for the duration of their employment and up to 6 years following the ending of that employment. We may keep certain data for longer than this, for example should there be any ongoing disputes.
Where an application for employment has been unsuccessful and not shortlisted for interview we will securely dispose of that information after 6 months. Where an applicant has reached interview but has been unsuccessful we will securely dispose of that information after 1 year.
Further details about how long we keep data is set out in our retention schedules.
Data Protection law includes rights for individuals
This means that we are obliged to provide you with clear and transparent information about how we use your personal data when we collect it. This Privacy Notice explains how we use the personal data we collect; and explains how you can contact us if you have any questions or concerns about how your personal data is being used.
Right of access and how to access your personal data
You have the right to request access to the personal data that we hold about you so that you can be aware of and verify the lawfulness of the processing. You can request copies of personal data we hold about you by making a ‘subject access request’. This is free and we must provide that data at the latest within one month of receipt of your request. (extendable to two months where the request is complex)
You can write to us or email us with your request for the CBH SAR Application Form which you can post or email back to us. We may require proof of your identity and address – we will let you know this when we receive your request.
Please be aware that we may need to edit or remove some information if it relates to other people, as we must protect the privacy rights of all individuals. If you have any queries about accessing your personal data please contact us using the details above.
You are entitled to have your personal data rectified if it is inaccurate or incomplete. We will investigate and respond ASAP and at the latest within one month (extendable to two months where the request is complex)
You have the right to request the deletion or removal of personal data where there is no compelling reason which allows us to continue using it. Individuals can make a request for erasure verbally or in writing and we have one month to respond to a request.
The right is not absolute and only applies in certain circumstances. The specific circumstances under which you can request the deletion of your data are listed on the ICO website.
In certain limited circumstances you have the right to request the restriction or suppression of your personal data. You can make a request for restriction verbally or in writing. While the processing is restricted, we are permitted to store your personal data, but not to use it.
This is not an absolute right and only applies in certain circumstances. The circumstances under which we would be required to cease processing are listed on the ICO website.
Where we are processing your personal data with your consent or for a contract, you have the right to obtain and reuse your personal data for your own purposes across different services. This means that, where requested, and where applicable, we must provide you with your personal data in a ‘machine readable’ way which enables you and other organisations to use the personal data you provided to us for that purpose.
The circumstances under which the right to data portability applies are listed on the ICO website. This is free of charge and we must respond to requests within one month (extendable by two months where the request is complex)
You have the right to object to:
The circumstances under which we must cease processing when an objection is made are listed on the ICO website. Where an objection is made to direct marketing, we must cease processing as soon as we receive the objection.
Where we are processing your personal data with your consent, you have the right to withdraw your consent for processing your personal data at any time. Where there is no other lawful basis which permits us to continue using your personal data, then your personal data will be removed from our records and systems.
Please note that some of the personal data that we process about you will be necessary to perform a contract with you or may be necessary to comply with a legal obligation. In these circumstances we may not be able to cease the processing, for example, if you wish us to assess your housing application then we will require certain information from you, or to provide you with a tenancy and associated services such as repairs.
You may still notify us of your wish to withdraw your consent and we will consider each request on a case by case basis.
In all instances please write to: Cheltenham Borough Homes Ltd, Business Support team, Cheltenham House, Clarence Street, Cheltenham GL50 3JR or email at firstname.lastname@example.org
This right provides you with safeguards against:
CBH/Vivid Lliving does not currently carry out automated decision making without human intervention. Further details about this type of activity can be found on the ICO website.
If you have a concern about the way in which we are handling your personal data then please contact us. In the first instance please write to: Cheltenham Borough Homes Ltd, Business Support team, Cheltenham House, Clarence Street, Cheltenham GL50 3JR or email email@example.com
We will take your concern seriously and work with you to try to resolve it.
If you are not satisfied with our response you can raise the matter with the Information Commissioner’s Office (ICO) via their website or call their helpline on 0303 123 1113.
This privacy notice will be updated to reflect changes either to the way in which we operate or changes to the data protection legislation. To make sure that you keep up to date, we suggest that you revisit this notice from time to time.
© Vivid Living/Cheltenham Borough Homes 2022