How We Use Your Personal Information
R3 Commercial
GDPR Fair Processing Notice
1.0 Introduction
This notice explains what information we collect, when we collect it and how we use this. During the course of our activities we will process personal data (which may be held on paper, electronically, or otherwise) about you and we recognise the need to treat it in an appropriate and lawful manner. The purpose of this notice is to make you aware of how we will handle your information.
In some cases, you may also add information about third parties that you have a contractual relationship with into our systems. When you supply us with this information, we will also process this information in the same way.
2.0 Who we are
R3 Commercial is a trading name of R3 Repairs Limited, registered in terms of the Companies Acts with registered number SC361210 and having its Registered office/main office at 18-20 Market Street, Haddington, EH41 3JL. (“We” or “us”) take the issue of security and data protection very seriously and strictly adhere to guidelines published in the General Data Protection Regulation (EU) 2016/679 which is applicable from the 25th May 2018, together with any domestic laws subsequently enacted.
(a) We are notified as a Data Controller with the Office of the Information Commissioner under registration number Z3279921 and we are the data controller of any personal data that you provide to us.
(b) Our Data Protection Officer is Caroline Wilson, Corporate Services Manager, East Lothian Housing Association.
(c) Any questions relating to this notice and our privacy practices should be sent to the Compliance Group.
3.0 How we collect information from you and what information we collect
We collect information about you:
When you become a customer of R3 Commercial
When you use our services via the R3 Commercial website or by speaking to our staff
From your arrangements to make payment to us (such as bank details, payment card numbers )
We collect the following information about you:
Your name.
Your company/employer’s name.
Your email address.
Your telephone number, which may include direct dial or mobile numbers.
Your business/work address.
Your IP address (if you visit our websites).
Website cookies (if you visit our websites).
Information from credit reference / credit scoring agencies
References supplied by other third parties
In addition, we will store and process the same information about any third parties you add to your account.
We receive the following information from third parties (not supplied by you):
Payments made by you to us
We also sometimes hold Personal data that is sensitive in nature (i.e. relates to or reveals your racial or ethnic origin, religious beliefs, political opinions, relates to health or sexual orientation) about you or any person residing at your address. For example, you may share this with us when calling our Service Desk and informing us about any particular needs or requirements you may have. This is “Special Category Personal Data” or “Sensitive Personal Data”.
4.0 Why we need this information about you and how it will be used
We need your information and will use your information:
To undertake and perform our obligations and duties to you in accordance with the terms of our contract/agreement with you
To enable us to supply you with the services and information which you have requested
To enable us to respond to your service request and any complaints made
To enable you to manage your account, and any third parties you give similar access to your account
To analyse the information we collect so that we can administer, support and improve and develop our business and the services we offer
For all other purposes consistent with the proper performance of our operations and business
To contact you for your views on our products and services.
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.
5.0 Sharing of Your Information
The information you provide to us will be treated by us as confidential. We may disclose your information to other third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:
If we enter into a joint venture with or merged with another business entity, your information may be disclosed to our new business partners or owners
If we instruct repair or maintenance works, your information may be disclosed to any sub-contractor
If we are conducting a survey of our products and / or service, sending you information about our products and services, or you are using our online help service, your information may be disclosed to third parties assisting in the compilation and analysis of survey results, managing e-mail preferences or storing online chat records.
If we need to collect money owed to us (such as when we engage debt collectors to recover a debt)
Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.
With Wyser Limited, who provide a software system to us that uses speech recognition help us transcribe telephone calls to our service desk and Artificial Intelligence to help us automate some of our systems, to help improve our efficiency and our tenants’ experience.
6.0 Transfers outside the UK and Europe
The majority of personal information 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 EE to enable these newsletters to be distributed to all members on our behalf.
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.
7.0 Security
When you give us information we take steps to make sure that your personal information is kept secure and safe. Further information can be found in our Privacy Policy which is available here
8.0 How long we will keep your information
We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you.
We will generally keep your information for the minimum periods.
Our full retention schedule can be obtained on request from our offices at 18-20 Market Street, Haddington, EH41 3JL or by calling 03000 999 247
9.0 Your responsibilities as a trade customer
As a trade customer, it’s your responsibility to ensure GDPR compliance for the client data you hold on file. When passing us that data for an order or to add a client to your account, you should ensure that your clients have been informed about the transfer of data and that you have designated us as a “Data Processor” for this purpose.
10.0 Your Rights
You have the right at any time to:
Ask for a copy of the information about you held by us in our records
Enquire us to correct any inaccuracies in your information
Make a request to us to delete what personal data of yours we hold
Object to receiving any marketing communications from us
If you would like to exercise any of your rights above please contact us at 18-20 Market Street, Haddington, EH41 3JL
You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information. The Information Commissioner’s contact details are noted below:
The Information Commissioner’s Office – Scotland
45 Melville Street, Edinburgh, EH3 7HL
Telephone: 0131 244 9001
Email: Scotland@ico.org.uk
The accuracy of your information is important to us - please help us keep our records updated by informing us of any changes to your email address and other contact details.