Data Protection and Privacy Policy

Introduction

This Privacy Notice is designed to help you understand what personal information Threshold Ltd. (referred to as “Threshold”) take from you. We also want you to understand why we take this information and how we use it.


Threshold values the relationships with all service users (Data Subjects) and this notice explains how Threshold collects, processes and manages your personal data. Threshold will process all personal data in compliance with the General Data Protection Regulation (GDPR) and any applicable local privacy law for providing you with the service you have requested and to meet our statutory obligations.
In this privacy statement “we”, “our”, “us” refers to Threshold.


Please read this Notice carefully. This Notice supplements any other privacy related notices and policies we may provide to you from time to time, and is not intended to override them. If you do not agree with this Privacy Notice in general or any part of it, please do not use our Services or otherwise provide your personal data to us. We may make changes to this Notice from time to time and will update the last revised date and take any other steps necessary to comply with applicable law

Who are we?

Threshold provides independent advice and advocacy to people experiencing housing problems. Our mission is to secure a right to housing for private renters experiencing poverty and exclusion, we achieve this by influencing housing policy.


For the purposes of data protection legislation, the Data Controller of your personal data is:
Threshold Ltd.


First Floor

25-28 Strand Street Great,

Dublin 1,

D01 XP04
E-mail: dpo@threshold.ie
Telephone: 01 6353601


This notice applies to all personal data collected by Threshold in connection with the performance of its functions as outlined below. Threshold can receive the personal information directly from individuals or indirectly from other sources.

Data Protection Principles

We strive to comply with Data Protection law. This means any information we hold about you must be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used for any other reason.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only for as long as necessary for the purposes we have told you about.
  • Kept securely.
  • Be able to demonstrate our compliance.

Why we collect your data

We collect personal data for many reasons, including to provide you with services, communicate with you and send you information you have requested, and administer donations. Depending on how you interact with us, we may process data for the following purposes:

  • To provide you with advice or advocacy services that you have requested or been referred to.
  • To administer services Threshold is providing to you.
  • To communicate with you regarding Threshold’s work and fundraising activities
  • To process donations and administer information for any donation you make to us.
  • To administer and send you information about our legacy programme.
  • For our own internal administrative purposes, and to keep a record of your relationship with us.
  • To manage your communication preferences.
  • To process job applications or volunteer placements.
  • To conduct surveys, research and gather feedback.
  • To obtain information to improve our services and client experience.
  • To comply with applicable laws and regulations, and requests from statutory agencies.

Lawful Basis for Processing

Any processing of personal data is only lawful where it has a ‘legal basis’. We may only collect, process and share Personal Data fairly and lawfully and for specified purposes. We will ensure all processing of personal data is based on one or more of the following:

Consent:

In case where you have given a clear consent for us to process your personal data for a specific purpose. For example, once you have you signed our Consent to Act form we may then make representations and/or share agreed data on your behalf to relevant third parties, such as your landlord or a Local Authority.

Once you sign a Service User Information Form or Consent to Act Form, you agree to the storing of all your information on files, databases and the Pathway Accommodation and Support System (PASS) system. You also agree to communicate with relevant people and services as agreed on the form.


You have the right to withdraw consent at any time by contacting us. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.

Contract:

Where the processing of your personal information is necessary in order to fulfil the terms of a contract. For example: if you have ordered a rent book from our website or if you submit information for example bank statements, payslips for Housing Assistance Payment Applications or Supplementary Welfare Allowance Applications; we store all information in secure locations. Data is stored for a specific timeframe depending on legislative and organisational requirements.

Legal Obligation:

Where the processing of your personal information is necessary to comply with any legislation. For example. For example, we are required by law to keep records of donations that we receive for 7 years in line with Revenue requirements.

Vital Interests:

In certain conditions when your consent it is not possible to be obtained, it may be necessary for us to process your Personal Data, including Sensitive Personal Data you provided through our Services, where it is in your vital interest or in the interest of others. Vital interest could be an event of a medical emergency, in which we may disclose your data, for example, to a hospital.

For example:

  • In circumstances where a medical emergency arises, we reserve the right to contact any medical staff who we identify as necessary to ensure your physical and mental health needs are met.
  • If a client contacts our services and states that they are suicidal, we arrange to meet the client or visit the client if it is safe to do so. In circumstances where a client has left their property, the Gardai may need to be contacted and a description of the person, situation and their whereabouts may need to be disclosed. We may also contact the client’s GP for further information to assist with the situation. We may also contact the client’s GP to visit the client in certain circumstances for an assessment to be carried out or they may need to present to hospital for an assessment by a Psychiatrist. If an Involuntary Admission needs to take place, their GP may be contacted, staff would complete Form 4, take this to the GP, the form would be sent to the Psychiatrist for assessment. An Involuntary Admission would take place if the Psychiatrist agreed to do so, and the client’s details and address would be given. Staff to be present if this was to take place during working hours.
  • Where Threshold identifies Child Protection concerns, we are obliged to report any concerns to TUSLA/GARDAI with immediate effect to safeguard all children. Concerns would include neglect, physical/emotional/sexual abuse, concerns re harm to a child.
  • If a parent was engaging in active addiction, anti-social behaviour was taking place in the property and there were concerns for the parent’s ability to care for her children. If signs emerged of the children not going to school, not receiving regular meals and witnessing inappropriate behaviour. Condition of the property, children’s appearance or any disclosure of concern from the children. Any reports from neighbours of disturbances at the property which would be concerning for child welfare. Any unexplained injuries to a child would be a huge concern.
Public Task:

Where the processing of your personal information is necessary to carry out a task in the public interest or for official functions.

For example:

  • If submitting a court report where Child Protection concerns arise; names, dates of birth and personal data of events would be discussed in a court room setting. Same would apply for a Case Conference hearing.
  • If submitting a report in relation to a domestic violence case and being to give evidence if supporting the client.
Legitimate Interest:

Where the processing of your personal information is necessary for legitimate interest or the legitimate interest of a third party unless there is a good reason to protect your personal data which override those legitimate interests. For example it is in our legitimate interest to use your personal data to create a file where all your data are stored so that we can keep track of the progress we make while helping you.


We must always determine our legal basis before beginning to process your personal information.

How we collect your Personal Data

The term personal data means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is a living person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Personal Data we collect directly from you

While we work with you, we may collect the following types of personal data from you. This can include data collected in our interactions with you in order to provide you with our services i.e. via phone, email and in person interactions. These include:

  • Your name
  • Your date of birth
  • Your PPS number
  • Your address (or address of family member or someone else you may have lived with before)
  • Your telephone number and email address
  • Main source of income
  • Household composition and type
  • Next of kin
  • Gender
  • Copies of documents related to your service needs, e.g. Notice of Termination.
  • Copies of Welfare Forms/Housing Assistance Payment Forms/Letters of advocacy by other professionals
  • References – landlord/work/character

Personal Data can also be collected via the web forms available on our website. These web forms include:

  • Donation form
  • Job application form
  • Leaving a gift in will form
  • Online query form
  • Book video call form
  • Join mailing list form
Other information about you

Certain types of sensitive personal data are subject to additional protection under the GDPR. These are listed under Article 9 of the GDPR as “special categories” of personal data. The level of information we collect typically relate to the level of complexity and duration of your service issue.

This information can include:

  • Information about your racial or ethnic origin, religious beliefs and your sexual orientation.
  • Information about any health conditions or disabilities you may have. For example if you have problems with addiction to alcohol or drugs or if you struggle with your mental health or if you are currently taking any medication.
  • Information about other safety concerns relating to you. For example, if you have had any prior convictions or have spent time in prison.
  • Information about your children (if you have any). If your children need support and help too we will collect information about them to give them the support they need.
  • Information about your needs and wishes. In certain instances we will make a case management plan with you. This plan will list what support you need and who we will work with to get you that support. It will also list your own goals and what you want to achieve while working with us too.
  • Citizenship – Stamp4/Habitual Residence
  • Family & Relationships
  • Financial Issues
  • Social Supports
  • Education/Training /Employment
  • Residential History
  • Independent Living Skills Needed
Person data we collect from other sources

In some cases, Threshold may collect data from publicly available sources to assist in the provision of our services. This personal data is collected through websites such as but not limited to www.landdirect.com and www.solocheck.ie.

The personal data collected from these sources can include:

  • Address
  • Housing sale history
  • Housing portfolios

Who do we share your information with

While we work with you, we may ask other organisations and agencies to help you to get the support you need. So we may share your personal data that we collect, or you provide to us with these organisations:

  • Local Authority Services for example, Dublin City Council or the Dublin Regional Homeless Executive, Cork City Council, Cork County Council
  • Medical services like GPs or public health nurses or others working with primary care teams. Psychiatrists, Occupational Therapists
  • Residential Tenancy Board
  • Government Departments for example, the Department of Housing or the Department of Employment Affairs and Social Protection
  • Social Workers
  • Mental Health Services
  • Addiction Services
  • Community & Voluntary Groups
  • Schools
  • Gardaí

We also share your personal data internally within Thresholds departments for management purposes, administrative purposes and to manage our relationship with you.

How we use your personal data

We use your personal data to:

  • Make a file about you and keep a record of all the work we have done with you during your time with us.
  • To fully understand your needs. We use your information to make sure we can best advice you and advocate on your behalf.
  • Communicate and work with organisations and agencies that offer support to you too.
  • Compiling a Risk Assessment for Home Visits.
  • To better understand our organisation and service needs, to inform service improvements
  • For statistical reporting and compliance requirements.
  • To inform our advocacy, policy and campaigning work.
  • To determine your suitability for a job role that you have applied for.

CCTV

Threshold has installed CCTV systems at our premises for the purposes of public and staff safety, crime prevention and detection as well as to comply with standard business protocols. CCTV cameras are located at access points, general reception areas, car parks, shared areas and the exterior perimeter.

Signage advises of areas covered by CCTV equipment. Threshold will only disclose CCTV images to others who intend to use the images for the purposes stated above.

Images captured by CCTV will generally be retained for a maximum period of 30 days. However, on occasion, there may be a need to keep images for longer, for example for the purposes of investigating a crime.

How long we keep your Personal Data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying 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, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data. In other circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Where We Store and Process Personal Data

The personal data and other information that we collect from you will be stored, and processed in Ireland where our servers are located and our central database is operated.

What are your Rights?

If your personal data is processed by us, you have certain rights in relation to that data, which are outlined in summary form below. Threshold may require further information from you before we can respond to your request. The scope of certain rights may be subject to restrictions or exceptions provided for under data protection legislation.

All requests to exercise your rights will be duly considered. Should you believe that any personal data we hold on you is incorrect or incomplete, you have the ability to request to see this information, rectify it or have it deleted. Please contact us through our DPO Office via email at dpo@threshold.ie so we provide you with the necessary information. We will respond to requests to exercise these rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances, and should such an extension be necessary, we will notify you in advance).

Under Data Protection Law you have the following rights which you can exercise to make sure your personal data is protected properly:

  • Right to Access
    You have the right to receive a copy of the personal data Threshold holds about you as well as information about how it is used. We shall respond as soon as reasonably possible and at the latest within one month from the date of your request.
    Applicability
    This right is applicable at all times when Threshold holds your personal data.
  • Right to Rectification
    You have the right to ask Threshold to correct personal data we hold about you where it is incorrect or incomplete.
    Applicability
    This right is applicable at all times when Threshold holds your personal data.
  • Right to Erasure
    This right entitles you to require the erasure of your personal data from Threshold’s systems and records. However, this right applies only in certain circumstances (e.g. where Threshold no longer needs the personal data for the purpose for which we collected it or where you withdraw consent to our use of your personal data and where there is no other legal basis for continuing to use it).
    Applicability
    This right does not apply where personal data is required for the purpose of compliance with a legal obligation or for the performance of a task carried out in the public interest or in the exercise of official authority.
  • Right to Restrict Processing
    This right entitles you to restrict the processing of your personal data by Threshold where for example, the data we hold is inaccurate, the processing unlawful or where we no longer need to hold that data for the original purpose. Where this right is exercised, Threshold is still permitted to store your personal data but other use of the data is prohibited, save in certainlimited circumstances. Where we have legitimate grounds not to restrict the processing of your data we will inform you of our decision before any action is taken.
    Applicability
    You can exercise this right if one of the following applies:
    -You contest the accuracy of the personal data held about you and the Threshold is verifying the accuracy of the data.
    -The personal data has been processed unlawfully and you oppose erasure and request restriction instead.
    -Threshold no longer needs the personal data but you need the data in connection with a legal claim.
    -You have objected to processing and Threshold is considering whether its legitimate grounds override your rights and interests.
  • Right to Object Processing
    You have the right to object to Threshold’s use of your personal data in certain circumstances. However, Threshold may continue to use your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to use your personal data in connection with any legal claims.
    Applicability
    This right applies where Threshold processes your personal data for the performance of the task carried out in the public interest or in the exercise of official authority or in pursuance of its legitimate interests.
  • Right to Data Portability
    This right allows you to obtain your personal data in a format that enables you to transfer that personal data to another organisation where the organisation is processing your personal data on the basis of consent or on the fulfilment of a contract and if processing is carried out by automated means. You may have the right to have your personal data transferred by us directly to the other organisation, if this is technically feasible.
    Applicability
    This right does not apply where personal data is required for the purpose of compliance with a legal obligation or for the performance of a task carried out in the public interest or in the exercise of official authority.
  • Right to Withdraw Consent
    You have the right to withdraw your consent to the processing of your personal data by Threshold at any time. This will not affect the lawfulness of our processing before the withdrawal.
    Applicability
    This right only applies where the sole legal basis for processing your personal data is your consent.
  • Right Relating to Automated Decision Making and Profiling
    You have the right not to be subject to a decision based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you.
    Applicability
    As Threshold currently does not make any automated decisions, this right is not applicable.
  • Right to Complain to Data Protection Commission
    You have the right to lodge a complaint with the Data Protection Commission (DPC) via their website www.dataprotection.ie if you think that Threshold has not processed your personal data in accordance with data protection legislation.
    Applicability
    This right applies at any time.

Failure to provide Personal Data

If you fail to provide certain information when requested, we will not be able to fulfil our legal obligations or deliver the service you have requested.

Security of Personal Data

Threshold will take all appropriate measures (including appropriate technical and organisational measures) to prevent against unauthorised access to, alteration of, disclosure of or destruction of your personal information.

Cross-Border Data Transfers

Threshold does not transfer data outside the European Economic Area (“EEA”). If this changes in the future we will notify users of this.

Modifications of this Policy

We may revise this policy occasionally and will inform you of significant changes to this by publishing a new version on our website, through email, through a private messaging or by handing you the hard copy of same.

Data Protection Queries and Complaints Procedure

Any queries or complaints regarding our use of your personal data and / or the exercise of individual rights should be addressed in the first instance to us via email at dpo@threshold.ie or via post at the Threshold Office address shown below:

Data Protection Officer
Threshold

First Floor

25-28 Strand Street Great,

Dublin 1, D01 XP04

You also have the right to contact the Data Protection Commission here.

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