Privacy Policy
1.0 Introduction
1.1 Welcome to R3 Repairs Limited’s privacy policy. “We” or “we” or “us” or “our” means R3 Repairs Limited, a company incorporated in Scotland under the Companies Acts (Company Number SC361210) and having its registered office at 18-20 Market Street, Haddington, East Lothian EH41 3JL and being a subsidiary of East Lothian Housing Association Limited, a Scottish charity and registered social landlord under the Housing (Scotland) Act 2001 (Scottish Charity No. SC028900) and registered under the Co-operative and Community Benefit Societies Act 2014 with registered number 2266R(S), whose registered office is at 18-20 Market Street, Haddington, East Lothian EH41 3JL
1.2 We respect your privacy and are committed to ensuring the secure and safe management of data we hold on you. We have a responsibility to comply with the terms of this policy, and to manage your data in accordance with this policy and any documentation referred to.
1.3 We gather and use certain information about you as well as managing some data, from a variety of other sources.
1.4 This Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
2.0 Legislation
2.1 It is our legal requirement that we process your data correctly and that we collect, handle and store personal information in accordance with the relevant legislation.
2.2 The relevant legislation in relation to the processing of data is:
(a) The retained EU law version of the General Data Protection Regulation (EU) 2016/679 (“the GDPR”) as defined in the Data Protection Act 2018.
(b) the Data Protection Act 2018 (and regulations made thereunder).
(c) The Privacy and Electronic Communications Regulations 2003 (as may be amended).
(d) all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of Personal Data.
3.0 Controller
3.1 We are registered as a Data Controller with the Information Commissioner’s Office with registration number Z3279921 and we are the data controller of any personal data that you provide to us.
3.2 Our Data Protection Officer is Caroline Wilson, Corporate Services Manager, East Lothian Housing Association.
3.3 If you have any concerns or questions about how we look after your personal information, please contact our Data Protection Officer on 03000 999 247 or e-mail here (mailbox@R3repairs.co.uk).
3.4 You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
4. Data we collect about you
4.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
4.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data: first name, maiden name, last name, and title.
• Contact Data: billing address, delivery address, email address and telephone numbers.
• Financial Data: no financial data is collected. All financial data is processed out with the website by Opayo by Elavon (SagePay).
• Transaction Data: details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data: the website does not collect username, interests or preferences.
• Usage Data includes: information about how you use our website, products and services.
• Marketing and Communications Data includes: We do not share your personal data with any third party for marketing purposes.
For scientific research and statistical purposes – to train and deploy Artificial Intelligence speech recognition systems to help us develop and use technology to automate some of our systems, to help improve our efficiency and our tenants’ experience.
4.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
4.4 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
4.5 If you fail to provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
5 How is your Personal Data collected?
5.1 We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• Become a member of R3 Direct;
• Create an account on our website;
• Use our services;
• Make payment to us;
• Request marketing to be sent to you; or
• Give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources We do not collect data from third parties or publicly available information.
6. How we use your Personal Data
6.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
6.2 See the Glossary at the end of this page to find out more about the types of lawful basis that we will rely on to process your Personal Data.
6.3 Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
7. Purposes for which we will use your Personal Data
7.1 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
7.2 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of Data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer |
(a) Identity (b) Contact |
Performance of a contract with you |
| To undertake and perform our obligations and duties to you in accordance with the terms of our contract/agreement with you |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us) |
| To enable you to partake in a prize draw, competition or complete a survey |
a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
8. Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
9. Promotional offers from us
9.1 We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
9.2 You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
10. Third-party marketing
We do not share your personal data with any third party for marketing purposes.
11. Opting out
11.1 You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
11.2 Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service purchase or other transactions.
12. Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see: page/cookie-policy
13. Change of purpose
13.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
13.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
13.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
14. Disclosure of your Personal Data
14.1 We may share your personal data with the parties set out below for the purposes set out in the table above.
- East Lothian Housing Association acting as processors who provide system administration services.
- Service providers acting as processors who provide IT and system administration services.
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- Suppliers acting as (i) joint controllers who deliver supplies or perform services for us in accordance with our performance of a contract with you, or (ii) processors who provide services for us.
14.3 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
15. Transfers outside the UK and Europe
15.1 The majority of Personal Data is stored on systems in the UK. However, our third party contractor who we use for our members newsletters may transfer your e-mail address outside the UK and/or EEA to enable these newsletters to be distributed to all members on our behalf.
15.2 Where information is transferred outside the UK or EEA we ensure that there are adequate safeguards in place to protect your information by ensuring that we have a robust contract/agreement in place with the third party.
16. Data Storage, Retention and Security
16.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
16.2 Data Retention
16.2.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
16.2.2 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, regulatory, tax, accounting or other requirements
16.2.3 We will keep your information for the duration of providing a service to you and/or as long as you are an R3 Direct Member. When the service we have provided comes to and end or if you end your R3 Direct membership we will keep your personal data for a set time for auditing and reporting purposes and for legitimate interest purposes. After that time we will either anonymise or destroy your information.
16.2.4 Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us by e-mail to mailbox@r3repairs.co.uk
16.3 Paper Storage
16.3.1 If your Personal Data is stored on paper we will keep it in a secure place where unauthorised personnel cannot access it. When your Personal Data is no longer required it will be disposed of.
16.4 Electronic Storage
16.4.1 Your Personal Data stored electronically will be protected from unauthorised use and access. Examples of our security include:
- Password protection of documents if appropriate.
- Controlling access to systems and networks allows us to stop people who are not allowed to view your personal information from getting access to it.
- Training our staff to allow us to make them aware of how to handle information and how and when to report when something goes wrong.
- Regular testing of our technology and ways of working including keeping up to date on the latest security updates (commonly called patches).
16.5 Data breaches
16.5.1 A data breach can occur at any point when handling your Personal Data. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so
16.5.2 If you suspect your personal information or that of others may have been at risk of a data protection breach please tell us by emailing us at mailbox@r3repairs.co.uk.
16.6 Internal reporting of data breaches
16.6.1 We take the security of your data very seriously and in the unlikely event of a breach will take the following steps:
- As soon as the breach or potential breach has occurred, and in any event on the same working day that it has occurred, the Data Protection Officer (DPO) will be notified of:
- the breach;
- how the breach occurred; and
- what the likely impact of that breach is on any data subject(s).
16.6.2 We will seek to contain the breach by whatever means available
16.6.3 Our DPO will consider whether the breach is one which requires to be reported to the Information Commissioners Office (ICO) and all data subjects affected. If a breach poses a risk to the rights and freedoms of a data subject then our DPO will report any such breaches to the ICO within 72 hours of the breach occurring.
16.6.4 We will notify third parties in accordance with the terms of any applicable Data Sharing Agreements.
17. Your Legal Rights
17.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data.
17.2 You have the right to:
17.2.1 Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
17.2.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
17.2.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
17.2.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
17.2.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
17.2.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
17.2.7 Withdraw consent at any time where we are relying on consent to process your personal data. 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. We will advise you if this is the case at the time you withdraw your consent.
17.3 If you wish to exercise any of the rights set out above, please contact us by sending an email to mailbox@R3repairs.co.uk or sending a letter to our registered office address of R3 Direct, 18-20 Market Street, Haddington, East Lothian EH41 3JL.
17.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
17.5 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
17.6 We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
18. Policy Review
18.1 We will review our Privacy policy every five years, unless changes in law or practice require an earlier review. Any changes to the policy will be approved by the R3 Board.
19. Glossary
Lawful basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to
