Privacy Policy

Protecting your privacy

Clann is committed to respecting and protecting your privacy. We will always take great care to fulfil our responsibilities under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. At Clann we may collect personal information about you in different situations, including when you access Clann’s services, sign a tenancy agreement or visit our website www.clannhousing.ie This statement sets out the basis on which any personal data we collect, use, and store or obtain from or about you will be processed by us.

Who are we?

When we talk about “Clann” or “us” or “we” in this statement, we are talking about Clúid Housing (operating as Clann) of 159-161 Sheriff Street Upper, Dublin D01 R8N0 and we are the data controller for the purposes of the General Data Protection Regulation and Data Protection Act 2018.

Clúid is a registered charity whose principal activities are in the provision of social housing across a wide spectrum of housing needs. Clúid is an approved housing body, regulated by the Approved Housing Bodies Regulatory Authority (AHBRA) and the Charities Regulator.

What information do we collect about you?

The information we hold on our records concerns our relationship with you. For example, we could hold the following types of data about you:

Identity and contact data: Includes first name, last name, title, date of birth, gender, PPSN and identity documents (e.g., drivers license, passport, PSC), address, Eircode, phone numbers, email addresses and next of kin details.

Behavior data: Includes a record of your tenancy compliance.

Financial data: Detailed financial information including contact details, income details, date of birth, gender, residential status, employment details, social welfare details, linked relationships, bank details and payment methods, the amount of money you have paid us, any amounts outstanding and associated recovery action.

Profile data: Includes who lives in our houses, feedback, and survey responses.

Technical data: Includes internet protocol (IP) address, your login data, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and other technology on the devices used to access this website www.clannhousing.ie

Transaction data: Includes details about payments made from you, and to you.

Usage data: Includes information about how you use our website.

Other data: Includes CCTV images, telephone recordings, webchat recordings, and criminal conviction data.

We may collect Special Categories of Personal Data about you (e.g., health/medical information). You may have provided this information.

We will only ask for personal information that is appropriate to enable us to deliver our services. If you do not provide this information, we may not be able to process your request.
We may occasionally receive unsolicited correspondence from members of the public which contains personal data relating to third parties (“Third Party Data”). We may process this data for the purposes of replying to correspondence, dealing with queries or complaints, and complying with our legal and regulatory obligations. The legal basis on which we process Third Party Data is that this is necessary for our legitimate interests in conducting our business and ensuring proper management and functioning of Clann.

How we use your information?

The personal data that you provide to us will enable us to fulfill our obligations to you and provide you with the appropriate services and support that you may require. Clann must have a legal basis to process your personal data. Usually this falls within our contractual obligations to fulfil your tenancy agreement, however it could be with your consent or may be necessary for the legitimate interests of Clann.

To enable Clann to provide you with the best service possible, we may use your personal data:

• for market research purposes and to get your views and feedback to help us improve the services you receive.

We may contact you about our services and products and ask you if you would like to get involved in the activities or groups which we hold e.g., National Residency Advisory Group (NRAG) and Clann Residency Advisory Group (CRAG).

Our legal basis for processing your information

Contract: this processing is necessary for a contract we have entered with you, or because you have asked us to take specific steps before entering a contract. Failure to provide such personal data would mean that we are unable to provide our service to you.

Consent: You have given clear consent to us to process your personal data for a specific purpose. Where consent is the lawful basis for processing, you have the right to withdraw your consent at any time.

Legal obligation: The processing is necessary for us to comply with the law.

Legitimate interests: The processing is necessary for our legitimate interests, or the legitimate interests of a third party, unless there is as good reason to protect your personal data and rights and freedoms which would override those legitimate interests.

Vital interests: The processing is necessary to protect someone’s life.

Who we share your information with?

On occasion it will be necessary to share your personal data with third party service providers that perform services or functions on our behalf for example:

• Accountants, Solicitors, Consultants, Business Advisors
• IT service providers
• Security companies
• Local Authorities
• Contractors
• Government Departments, including Revenue and Social Protection
• Residential Tenancies Board (RTB)
• An Garda Síochána
• The Criminal Assets Bureau (CAB)
• Tusla
• HSE
• Funders.

We will only share relevant and necessary information with them.

Where your personal data is shared, we ensure appropriate technical and organisational safeguards are used to protect your personal data.

Clann does not share your information with any organisation outside of the European Economic Area (“EEA”).

How we keep your information safe?

We are committed to holding your personal information securely. Our security measures comply with the law and international standards, access is given only to those that need it and our computers, files and buildings are secure. We limit access to your personal data to those employees, contractors and third parties who have a business need to know. They will only use your personal data on our instruction, and they are subject to a duty of confidentiality.

Clann has procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of any breach where we are legally required to do so.

How long we keep your information for?

We will hold your personal information for no longer than is necessary. We retain your personal information for as long as we need it for the purposes described in this statement, or to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise between you and us.

Your rights

You have a range of rights under data protection law in relation to the way we process your personal information, including:

• right to request access to a copy of your personal data;
• right to have personal data rectified if it is inaccurate or incomplete;
• right to erasure (‘right to be forgotten’) in certain scenarios;
• right to restriction of processing, in certain scenarios;
• right to data portability, only applies to data you have provided to us;
• right to object to processing, including automated decision making.
• Clann does not make decisions about you automatically or conduct profiling.

If you would like to exercise your data protection rights, please do not hesitate to contact us. You may contact our Data Protection Coordinator at dataprotection@cluid.ie or in writing to Data Protection Coordinator, Clúid Housing, 159-161 Sheriff Street Upper, Dublin D01 R8N0.

Cookies

Our website www.clannhousing.ie uses cookies to help provide you with the best experience we can. Cookies are small text files that are placed on your devices when you browse websites. No information is collected that could be used by us to identify you. Please see our Cookie Policy for further information.

Privacy policies of other websites

Our website may include links to other third-party websites, plugins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not have control over third-party websites and are not responsible for their privacy policies. If you click on a link to another website, you should read their privacy policy.

Changes to our privacy statement

Clann keeps this privacy statement under regular review and places any updates on this web page. This privacy statement was last updated in July 2023.

How to contact us

If you have any questions about this privacy statement, the data we hold, or you would like to exercise your data protection rights, please do not hesitate to contact us.

You may contact our Data Protection Coordinator at dataprotection@cluid.ie or in writing to Data Protection Coordinator, Clúid Housing, 159-161 Sheriff Street Upper, Dublin D01 R8N0.

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that Clann has not addressed your concern in a satisfactory manner, you may contact the Data Protection Commission through their website https://www.dataprotection.ie/en/contact/how-contact-us