Data Protection Notice For Tenants
1 About this Data Protection Notice
This notice tells you how Focus Housing Association uses your personal data as a tenant. It explains what information we collect, why we collect it, how we use it and who we might share it with. It’s a way for us to be transparent about how we respect and protect your data and privacy.
2 Who we are
Focus Housing Association CLG is an Approved Housing Body (AHB). We work with tenants to provide secure accommodation, protect their rights and support their needs. Focus Housing Association is also a registered charity.
Our sister charity, Focus Ireland, works with people who are homeless or at risk of losing their home across Ireland. Focus Ireland believes that everyone has a right to a place they can call home. We are driven by the fundamental belief that homelessness is wrong.
You can find out more information on who Focus Ireland is and what we do on our website – www.focusireland.ie .
3 Our contact details
If you have any queries or concerns in relation to our processing of personal data or the contents of this Data Protection Notice, we would be happy to help. You can contact us by writing to, emailing, or phoning our head office:
Focus Ireland
9-12 High Street info@focusireland.ie
Christchurch
Dublin 8 +353 (0) 1 881 5900
D08 E1W0
Contact details for Data Protection Officer (DPO):
You can also contact our Data Protection Officer (DPO) directly using the contact details below:
Data Protection Officer (DPO) dpo@focusireland.ie
9-12 High Street
Christchurch
Dublin 8 +353 (0) 1 881 5900
D08 E1W0
4 What data we process and why
Personal data is any information which identifies you or could identify you.
The below table summarises the type of data we process for different activities we do.
| Business Activity | What data we collect | Lawful Basis |
| Managing Tenancies | · Name
· Address (including previous address) · Contact details · Email address · Date of Birth · Photo ID · PPSN · Next of kin · Communications · Information shared on referral forms · Information relating to maintenance and repairs · Information relating to breaches of tenancy which may include evidence · Information relating to health and safety and checks carried out · Estate management checks
|
Performance of a contract: We use your personal information to check if you’re a good fit for renting a place from us or to help manage your rental agreement with us. |
| Rent – processing rent, rent reviews and managing rent arrears | · Completion of Household budget deduction form which will include your PPSN.
· Information relating to incomings and outgoings if required for assessing rent. · Evidence of income such as bank statements · Information relating to reasons for rent arrears and plans to address · Bank Details if you request a refund · Bank Statement as evidence of income if required
|
Performance of a contract: We process this personal data about you to manage your rent agreed under your tenancy contract. |
| Complaint Handling and Appeals | · Details of the complaint
· Any relevant evidence to substantiate a complaint such as CCTV footage, witness statements · Correspondence sent and received relating to the complaint such as text messages, records of phone calls, letters and emails.
|
Performance of a contract: We process this personal data about you if you or Focus Housing are not agreeing to the terms and conditions of your tenancy agreement. |
| CCTV | We have CCTV in operation at our offices and properties. If you visit our premises or live in one of our properties, your image may be captured on our CCTV cameras.
Where CCTV recording is in place, you will be notified by signs displayed in the areas where the CCTV covers.
CCTV is in operation for the purpose of Health, Safety and Welfare and Crime Prevention and Detection. |
Legitimate Interests: We use CCTV for our legitimate interests relating to health, safety and welfare and crime prevention and detection. |
| Administration & Operational Management | We might use your information for office work or running our operations. This could involve making reports for staff who are covering for others on leave, creating reports to figure out what we need to provide our services, making reports to measure risks and how well we’re doing, making reports about the kinds of tenants we have (like their gender, age, family situation, and address), making reports to push for changes in policies, and making reports to make our services better and find out if we’re falling short. | Legitimate Interest: Focus Ireland needs to process this data to ensure the efficient and smooth operation of the business. |
| Next of Kin / Emergency Contact details | We might handle information about your emergency contact or closest family member. We’ll only use this information in an emergency, like if we’re worried about your safety or well-being. | Vital Interest: We may share limited data with your next of kin only in a situation where we cannot reach you and have genuine and reasonable concerns for your safety and welfare. |
| Health & Safety | We use incident and accident reports to write down what happened and the result of any incidents or accidents that happen at Focus Ireland/Focus Housing places or where these companies are in charge of health and safety. We write down details of the accident or incident to meet the companies’ responsibilities. | Legal Obligation: Focus Ireland and Focus Housing have certain obligations under Health, Safety and Welfare legislation.
Insurance Purposes: We may also use this information for insurance purposes and claims. |
4.1 Processing Special Categories of Personal Data
Certain data is considered “special” under the GDPR. Special category data requires further protection than other data, this is because its misuse may have worse affects than other personal data. Special Category Data includes:
- Health Data may be processed where necessary for example:
- For the purpose of complying with health and safety legislation and insurance claims or potential claims such as personal injury claims.
We are not permitted to process special categories of data unless one of the exemptions under Article 9 of the GDPR apply. In this case, the Article 9 exemptions relied on include:
- Processing is carried out in the course of its legitimate activities with appropriate safeguards by a not-for-profit body
- You have given us explicit consent
- processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;
- Processing is necessary for and proportionate for a policy of insurance
4.1.1 Data relating to criminal convictions and offences
We might use some information about any criminal convictions or offences you may have. This is to check if the accommodation is suitable for you and to make sure all tenants are safe and well. According to section 55(1) of the Data Protection Act 2018, we use this information when: • It’s needed and fair for your tenancy contract or to take action at your request before making a contract, • It’s needed to give or get legal advice or legal defence, • It’s needed to stop injury or other harm to you or someone else, or loss or damage to property, or to protect your or someone else’s vital interests.
5 Profiling and Automated Decision Making
You have the right not to be subject to a decision based solely on automated processing of data, including profiling, which would produce legal effects concerning you or significantly affect you.
Focus Housing Association does not use profiling or automated decision making.
6 Information provided to us by you about others or others about you
Sometimes, you might give us someone else’s personal information, or they might give us yours. When this happens, it’s important that you ask them first if it’s okay to share their information and they should do the same with you. If you give us someone else’s personal information, it’s important that you tell them about this Data Protection Notice. By giving the information to Focus Ireland, you’re saying that they’ve read this notice and agreed to let us use their personal information according to this notice and its rules.
7 Data Sharing
We may share your information with organisations that are not Focus Ireland or Focus Housing Association to help us operate, provide, improve, understand, customise and support our services and business.
7.1 Data Processors
We use services and systems from other companies to help us with our business needs. We often have to share your personal information with these companies. All these companies are required to protect your personal information properly, following the GDPR rules. We don’t let these companies use your personal information for their own needs unless they are also in charge of controlling the data. We only let them use your personal information for specific reasons and they have to follow our instructions. Anyone who gets the information also has to keep it confidential.
We have data processors acting on our behalf for the following business processes:
- IT Support
- Property Database for managing tenancies
- Confidential Waste Management
- Security Companies
- Consultants
7.2 Focus Ireland
Focus Housing Association is the property arm of Focus Ireland. The two companies work closely together and information will be shared between the companies on a need to know basis and where operationally required.
7.3 Other Data Sharing
For many of our processing activities, we are required to disclose data to third parties who are not data processors acting on our behalf or data controllers on whose behalf we are working. Categories of recipients include:
7.3.1 Residential Tenancy Board (RTB)
The RTB are an independent public body. Focus Housing Association has to let the RTB know about all its rental agreements, which means they’ll have to give them some information about you as the renter. The RTB also runs a service to help solve disagreements. If you’re part of this, then some information might be given to the RTB to help sort things out. This could include things like statements from witnesses, complaints that have been made, or proof of broken rental agreements.
7.3.2 Local Authorities
When there is a vacancy within Focus Housing Associations stock, the local authority (from their list of people on the waiting list) provide us with a nomination for the property. If you are nominated for a property, then your information will be passed from the local authority to Focus Housing Association.
7.3.3 Tusla – The Child and Family Agency
We’re required by law to tell Tusla, the Child and Family agency, if we’re worried about a child’s safety. In most situations, we’ll let you know if we’re sending a report to Tusla.
7.3.4 Maintenance
If the place you’re renting needs to be fixed or looked after, your name, address, and contract number will be given out. This is so the person doing the repairs can get in touch with you to find a good time to do the work.
7.3.5 Other data sharing
We may also share data with the following:
- Tax authorities (e.g. Irish Revenue Commissioners)
- Law enforcement (where required for the investigation, detection, or prosecution of criminal offences)
- Standards bodies
- Statutory bodies
- Accountants, Solicitors, Consultants, Business Advisors
- Government Departments including Social Protection
- Financial Institutions
8 Data transfers outside of the EEA
Sometimes, the companies we work with might handle your data outside of the European Union (EU) or the European Economic Area (EEA). Some countries outside of the EU/EEA might not have strong rules to protect your data like the General Data Protection Regulation (GDPR). But don’t worry, we’ll make sure your data is safe.
An “adequacy decision” is a formal decision by the EU Commission. It means that another country has similar protections for personal data as the EU. You can find a list of countries that have this decision on the European Commission’s website.
We use an adequacy decision from the European Commission to send data to the United Kingdom (UK). So, your data might be sent to the UK based on this decision. For example, if you’re a tenant of Focus Housing, your data will be handled on our property database, which is in the UK.
9 How long we keep your data for
We will only keep your data for as long as we need it or where we have to keep it to comply with the law. Some of our retention periods relating to data that will be processed during your tenancy is set out in the table below:
| Data | Retention |
| Information relating to your tenancy | 7 years after your last tenancy with us ends |
| Unsuccessful tenancy applications | 1 year from the data the application is refused |
| CCTV Recordings | 30 days from the date the footage was recorded |
| Text Messages | May be deleted 90 days from the date the message was sent or received |
| Emails | No longer than 7 years from the date the message was sent or recieved |
10 Your rights
You have the following rights in relation to your data. You can send us a request about any of the rights outlined below. We will do our best to handle your request as soon as possible and within one month. However, restrictions may apply in certain situations
Under the General Data Protection Regulation (GDPR), you have several rights:
- Access: You can ask to see the personal data a company has about you.
- Correction: If the personal data a company has about you is incorrect, inaccurate or incomplete, you can ask for it to be corrected.
- Restriction: You can limit how a company uses your personal data.
- Deletion: You can ask a company to delete your personal data when it’s no longer needed or if processing it is unlawful.
- Data Portability: This means you can copy, move, and transfer your personal data easily from one IT environment to another in a safe and secure way, without affecting its usability.
- Objection: This means that you can say no to certain types of uses of your personal data.
- Automated Processing: You have the right to avoid decisions made about you based solely on automated processing, including profiling, which have significant effects on you
If you want to use any of the rights we just talked about, tell your housing officer. Or, you can get in touch with our Data Protection Officer. You can find their contact info in the first section of this notice.
10.1 Withdrawing Consent
If we’re using your personal information because you consented to us using it, remember you can change your mind at any time. If you want to do this, just get in touch with your housing officer or our Data Protection Officer.
10.2 Right to Complain to the Data Protection Commissioner (DPC)
The Data Protection Commissioner (DPC) is like a watchdog for personal data safety in Ireland. If you think your personal data isn’t being handled right, or if you’re unhappy with how we’re using your data, you can complain to the DPC. Before you do that, though, it’s a good idea to first talk to our Data Protection Officer if you’re worried about how your data is being used. If you decide you want to complain to the DPC, you can find out how to reach them on the Data Protection Commission’s homepage Homepage | Data Protection Commission.
11 Security of your Data
Focus Ireland really cares about keeping your personal data safe. We do everything we can to protect any personal data you give us. If we have any paper records of your data, we keep them safe in locked cabinets or rooms. We also have security cameras and alarms at our buildings. We also protect any digital data on our computers and devices. For example, our laptops and PCs have encryption. We use Multi-Factor Authentication (MFA), which is an extra layer of security. Our mobile devices are protected with passwords or FaceID/TouchID. We control who can access data and only allow it if they really need to know. We also use firewalls, antivirus protection, endpoint protection, and backups to keep data safe. All our employees get regular training on how to protect data and keep our IT systems secure. We even teach this to new employees when they first join us.
12 Updates to this Notice
Any changes to this notice will be updated here. This notice was last updated June 2024.