In the day to day running of our business it may sometimes be necessary for us to collect, process and share your personal data with other organisations. As we make decisions about why and how your data is processed under data protection law, we are a “Data Controller” and are registered & regulated accordingly with the Information Commissioners Office (ICO). Our registration number is ZA048449.
This privacy notice applies to all Capsel Ltd customers including customers who purchase one of our new homes and explains:
We have updated this notice to reflect changes in data protection law, which took effect from 25 May 2018; this document was last updated in February 2023. Any future changes we make to this notice will always be posted here on our website. A paper copy is available on request.
Capsel Ltd is a wholly owned subsidiary of Monmouthshire Housing Association Ltd (MHA) and forms part of the Monmouthshire Housing Group. MHA is a registered social landlord providing homes and services for around 3,600 tenants and their families in Monmouthshire. Capsel Ltd) (us, we) are a trusted, professional company providing a range of home related services which includes:
As a Data Controller we are committed to:
Capsel collects personal information about our clients in a variety of ways, including:
The information we collect may include the following dependent on the services provided. Details about you including:
Under Data Protection legislation, certain personal information is also classed as “Special Category Personal Data”. This is any information relating to:
Capsel Ltd does not collect any of your Special Category Data.
We use your information for a variety of different purposes, these are listed below:
This list is not exhaustive, and we may request other information on occasion. This will however only be to enable us to provide services to you
To conduct business with you or your behalf we will collect data for a number of different reasons and rely on a number of legal basis. These are outlined below.
(i) Performance of a contract – this is where the collection and processing of your data is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract
(ii) Legal obligation – this is where the collection and processing of your data is necessary for compliance with a legal obligation, for example, verification of identity and fraud prevention as well as anti-money laundering regulations or our legal obligations under relevant Housing Legislation
(iii) Consent – where we process information under consent we will seek your clear and unambiguous consent before processing your data, for example if you wish to use our recommended financial advisory service or solicitor
(iv) Legitimate interests – some information is processed by us in our legitimate interests which include, network and information security, web analytics, and improving core services provided. Please note that this is not an exhaustive list and on occasions another legal basis may apply. Should this be the case will advise you accordingly.
You may register your interest in a property via our website. We will use that data to keep you updated and to occasionally inform you of our future offers and similar homes and developments.
From time to time, we may use your information to contact you for internal market research purposes. We may contact you by email, phone or mail, and may use the information to improve the products and services we provide. You may opt out at any time via email or by contacting us direct.
The Privacy & Electronic Communications Regulations sit alongside the Data Protection Act & GDPR and outline privacy rights in respect of electronic communications. To find out more about these regulations, please visit https://ico.org.uk/media/for-organisations/guide-to-pecr-2-4.pdf
Please note we will never share your information with third parties for marketing purposes.
Capsel records all telephone conversations made to and from our main telephone number. The recordings are then used for training and monitoring and are also used to investigate complaints made by customers or staff.
We do not record your card details when you supply them over the phone for us to take payments, these are taken via a secure payment line – keep this for reservations and upgrades. Our legal basis for recording calls is:
If you apply for a position with us, you can find full details of how we use your data in the separate Recruitment Privacy Notice on The MHA website:
https://www.monmouthshirehousing.co.uk/wp-content/uploads/2021/05/Employment-privacy.pdf. Part of our recruitment process relies on automated processing. If your application does not meet the minimum standards required for the post it will not be processed any further by the system.
You can contact our HR team by calling 0345 677 2277 at any point in the recruitment process for further information or to discuss.
Our company operates in accordance with the Disability Discrimination Act 1995 and the Equality Act 2010 and, as such we encourage all prospective clients to talk to us about any special accommodation requirements they may have.
We will when required, share information with contractors, third parties and other agencies we work with. We will only share information within the bounds of current data protection legislation and will ensure there is a lawful basis to do so. In particular please note as follows:
Organisations that we share information with will need to process personal data in line with the law and where applicable agree to our specific requirements to process the data.
Capsel Ltd does not transfer data internationally. Where we are aware that third party organisations that we may use do transfer data outside of the European Economic Area, we will ensure adequate safeguards are in place to keep your data protected.
MHA Group has an Information Security Policy & also a Data Protection Policy. These are available upon request.
Information held electronically or on paper is stored securely with appropriate controls and higher levels of security around sensitive personal data where applicable. The controls will be appropriate to the nature of the personal data and the level of associated risk.
Controls include:
Periodic checks are carried out to test the effectiveness of the security controls.
We keep your information for no longer than is necessary for the purposes it was collected for. The length of time we retain your personal information is determined by operational and legal considerations including Anti-Money Laundering Regulations.
Under data protection legislation you have a number of rights in relation to your personal information:
(a) The right to access the personal information we hold on you You have a right to ask us what personal information we hold about you, and to request a copy of your information, free of charge. This is known as a subject access request. We have one calendar month within which to provide you with the information you’ve asked for or tell you why if we cannot provide the information.
(b) The right to ask for your personal information to be corrected if you think it is wrong. You have the right to ask us to correct your personal information if you believe it is wrong. We have one calendar month to deal with your request or let you know why if we can’t.
(c) The right to erasure (right to be forgotten). You may have the right, in certain situations, to ask us to delete your data. If we are unable to do this for you we will always let you know why.
(d) The right to restrict us processing your personal information In some cases, you may be able to ask us to restrict our processing of your data. When processing is restricted, we are allowed to store the information, but not do anything with it.
(e) The right to object to processing. You have the right to object to processing where we say it is in our legitimate business interests. We must stop using the information unless we can show there is a compelling legitimate reason for the processing, which override your interests and rights or the processing is necessary for us or someone else to bring or defend legal claims.
(f) The right to withdraw consent. Whenever you have given us your consent to use your personal information, you have the right to change your mind at any time and withdraw that consent. If the basis on which we are using your personal information is your consent, then we must stop using the information.
(g) The right to data portability. The right to data portability allows you to obtain and reuse your personal information for your own purposes across different services. It allows you to move, copy or transfer personal information easily from one IT environment to another in a safe and secure way. The right only applies to personal information you have provided to us where the reason we are relying on to use the information is either your consent or for the performance of a contract. It also only applies when processing is carried out by us using automated means which does not apply in our case.
(h) The right to object to automated decision making. You have the right to object to us making a decision about you which is made by automated means only.
As outlined above, automated decision making does form a part of our recruitment process.
Please note that additional exceptions apply to a number of these rights and not all will be applicable in all circumstances.
Further detail regarding your rights can be found at: https://ico.org.uk/.
If you would like to exercise any of the above rights, please contact us at: dpo@monmouthshirehousing.co.uk .
You can also write to our Risk & Business Assurance Manager, at our HQ address below. Please provide as much detail as you can about your request and specifically what personal information you want to access. We will endeavour to respond fully to the request within one month of receipt.
If we are unable to do so for any reason we will contact you with reasons for the delay. If we are not able to fully complete your request (due to conditions set out by the UK General Data Protection Regulations and Data Protection Act 2018) we will explain why.
If you have any queries or concerns connected to our use of your personal data or any other data protection questions not already covered in this notice, please contact us on: dpo@monmouthshirehousing.co.uk
You can also write to us at our HQ:
Risk & Business Assurance Manager
Nant Y Pia House
Mamhilad Technology Park
Mamhilad
Monmouthshire
NP4 0JJ
Our Data Protection Officer is:
GDPR Sentry Ltd
Unit 434 Birch Park
Thorp Arch Estate
Wetherby
West Yorkshire
LS23 7FG
Tel: 0113 804 2035
email: info@gdprsentry.com
If you feel that your personal information has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal information, you have the right to make a complaint to the Information Commissioner’s Office. You can contact them by:
Calling 0303 123 1113 Or by writing to:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Online: www.ico.org.uk/concerns
