Customer Privacy notice

This privacy notice will illustrate how your personal data and, if applicable, special categories of personal data will be used by West Highland.

This notice was reviewed and updated on 1 August 2023.

What data we need

To allow us to provide the service you would expect from us, we process the personal information you provide us with, which includes:

  • your name (and any previous names);
  • address (and previous address information);
  • telephone number(s);
  • e-mail address;
  • national insurance number;
  • date of birth;
  • details of your next of kin;
  • names and dates of birth of those living in the property with you;
  • notes from conversations we have with you in relation to arrears or complaints;
  • details of when you have contacted us to request a service, for example to request a repair or for a housing officer to call/visit you.
  • next of Kin/Power of Attorney/Guardianship
  • details of Relevant Medical Conditions, support needs and mobility issues
  • if you are a registered offender
  • bank details

Why we need it

Larkfield needs to process supplier data to consider whether to enter into a contract with a supplier/s or following the placement of a contract with a supplier/s and to meet its obligations under this contract. For example, Larkfield needs to process supplier data for banking purposes, and to contact suppliers about orders, deliveries, returns and/or give feedback.

In some cases, Larkfield needs to process data to ensure that it is complying with its legal obligations. For example, to comply with health and safety laws such as cleaning service COSHH assessments. In other cases, Larkfield has a legitimate interest in processing supplier data before, during and after the end of the contracting relationship.

Processing supplier data allows Larkfield to:

  • maintain accurate and up-to-date supplier records and contact details;
  • pay suppliers in accordance with their payment terms;
  • operate and keep a record of supplier spending to inform current and future budgets;
  • ensure effective general business administration;
  • ensure compliance with Health and Safety legislation; and
  • respond to and defend against legal claims.

Where the organisation relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of suppliers and has concluded that they are not.

Larkfield does not collect or process special categories of personal data i.e. particularly sensitive information about its suppliers at any point, such as ethnic origin, sexual orientation or religious and/or political beliefs.

Where we store your data

We store your information in what is called a ‘Housing Management System’ – this is basically a large database, an electronic information storage system.  We also keep some information on paper based forms; these are stored in our office. It’s also possible, if you have contacted us by email, that some information will be held in the email system. 

 We also have an electronic filing system or document management system, where any forms or correspondence are scanned and stored.

 Your Housing Application information may also be held on Argyll and Bute Council’s Home Argyll online Application system to which we have access.

How long we will keep your information

We continually look at how long we hold onto information you have provided to us and how long it should be kept for.  Generally, once it has served its purpose it will be destroyed, however there are some instances when we will need to keep some of the information you have supplied.  For example,  once your tenancy has ended we will only keep any information received during that tenancy for 5 years, unless you left owing money for rent or repairs.  If money is due, we will hold on to the relevant information required to help us to pursue that debt.

We will generally keep your information for the following minimum periods after which this will be destroyed if it is no longer required for the reasons it was obtained.


Document Type

Retention Period

Tenancy agreement

5 Years after the tenancy has ended unless there is money owed for rent

Tenancy forms

5 Years after the tenancy has ended


5 Years after the tenancy has ended

Stage 2 complaint investigation and correspondence

5 Years after the tenancy has ended if appropriate to allow for escalation to Scottish Public Services Ombudsman

Membership Record

5 Years following last contact

Housing Application

5 Years following last contact

Housing Benefit Notifications

Duration of Tenancy

Anti-Social Behaviour Case File

5 Years after the tenancy has ended or end of legal action

Tenant Eviction Case File

7 Years

Tenant Abandonment Information 

5 Years

 Our full retention schedule is available here

What is the legal justification

The tenancy agreement between West Highland Housing Association and you, as a tenant, is a legally binding contract. We rely on the contractual legal basis for processing to ensure that are able to meet the requirements of the contract. 

There are a number of pieces of legislation that require us to collect the information from you


Data Type

Condition of Processing

Personal Data

The Housing (Scotland) Act 1987 (as amended)

The Housing (Scotland) Act 2001

The Housing (Scotland) Act 2006

The Housing (Scotland) Act 2014 (once enacted)

Special Category Data

The Housing (Scotland) Act 2001, section 105

The Scotland Act 1998, Schedule 5, section L2

The Equality Act 2010

Sharing your information

The information you provide to us will be treated by us as confidential.

We will disclose your information to third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:

  • repair contractors; to carry out repairs to your property or home improvements
  • any company we engage to carry out surveys; for example where we are proposing a change to a policy and are legally required to consult with our tenants or where we need to how well we are carrying out repairs and maintenance
  • local authorities; this will include notifying council tax departments of when you leave a property or start a tenancy
  • police (if necessary for the prevention or detection of crime);
  • Department of Work and Pensions; where we are assisting you in making a benefit claim or trying to resolve an issue of unpaid rent due to a benefit claim
  • utility companies (where you have left the property)

Receiving data about you

We will also, where appropriate, receive the following information from third parties:

  • benefits information, including awards of Housing Benefit/Universal Credit;
  • payments made by you to us via your bank, allpay or post office
  • complaints or other communications regarding behaviour or other alleged breaches of the terms of your contract with us, including information obtained from Police Scotland;
  • reports about your conduct or condition of your tenancy, including references from previous tenancies, and complaints of anti-social behaviour.

Updating your information

If your details change, please contact 0300 323 11 70 to inform us to ensure that all of the information we hold about you is up to date.

Your rights

You have a number of rights under the Data Protection Legislation which are outlined and explained below.

The right to be informed how your data is processed

This guide informs you how your data will be processed and sets out clearly West Highland's lawful basis for processing.

The right to access your personal data

You can submit a Subject Access Request to access the personal data that West Highland holds about you. You can do this by writing to:

Managing Director or Company Secretary

West Highland Housing Association

Crannog Lane


PA34 4HB

West Highland will then have 30 days to respond to your request. As part of the subject access request process we will ask for two forms of identification to be submitted before any information is released.

The right to rectification

If any of the personal data we hold about you is wrong, you have the right to ask us to correct it.

The right to erasure

You may request that West Highland erase any of your personal data that is processed by us. This is also known as the ‘right to be forgotten’. Please note that this is subject to a number of exemptions and so is not an absolute right.

The right to restrict processing

If you believe that we are processing personal data unlawfully, where it is no longer needed or think that the personal data held is inaccurate you can ask us not to process that personal data.

The right to data portability

You can ask us to pass on the personal data we hold about you to a third party, where you have provided that personal data to us and we have been processing it to deliver a service to you.

The right to object

You have the right to object to our processing of your personal data. However, if West Highland can demonstrate that there is an appropriate ‘condition of processing’ in place then we may refuse to stop processing your personal data.

Rights in relation to automated decision-making and profiling

You have the right not to be subject to a decision solely based on automated processing. If a decision is made by an automated process you may ask West Highland to have the decision investigated by a member of staff.

How to action your rights under data protection legislation

If you wish to object to the use of your personal data, would like to restrict processing or have data rectified, please contact

The right to complain to the ICO

If you have a concern about the way West Highland is processing your personal data, you may raise a complaint with the Information Commissioner’s Office.

Information Commissioner's Office
Wycliffe House
Water Lane

0303 123 1113


We will never share or sell your personal data to a third party for marketing purposes.


Electronic information that contains personal information is kept in secure systems. Laptop computers and other devices which may be taken out of the office are encrypted and password protected. Any paper files containing personal information are stored in locked filing cabinets. 

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