Supplier Privacy Notice
This is the Supplier Privacy Notice of West Highland Housing Association Limited, Crannog Lane, Oban, PA34 4HB.
West Highland Housing Association [“WHHA”] defines a supplier as a person or organisation that provides something that the company needs, such as a product or service. On entering into a contract with us, you trust us with your personal information. This Privacy Notice is meant to help you understand what data we collect, why we collect it, what we do with it, how we keep your personal data safe, and your individual rights over your personal data.
We are strongly committed towards the privacy of sensitive information, acting transparently and meeting our obligations in respect of data protection. Whenever you provide personal information, we will treat that information in accordance with this Privacy Notice, relevant legislation and best practice.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
- What information do we need
WHHA collects and processes the following information about its suppliers:
- full name of the relevant contact;
- company address;
- contact details, including email address and mobile and landline telephone numbers;
- details of services/products provided;
- the terms and conditions of your contract;
- copies of email correspondence and hardcopy correspondence; and
- bank account details.
WHHA collects and processes the following information about its potential suppliers:
- full name of the relevant contact;
- company address;
- contact details, including email address and mobile and landline telephone numbers; and
- details of services/products provided, including email correspondence and supplier marketing material.
WHHA collects this information in a variety of ways. For example, data is collected through enquiry telephone calls, emails, meetings, and from correspondence with you throughout the order and delivery process.
- Why we need this information
WHHA 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, WHHA needs to process supplier data for banking purposes, and to contact suppliers about orders, deliveries, returns and/or give feedback.
In some cases, WHHA 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, WHHA has a legitimate interest in processing supplier data before, during and after the end of the contracting relationship.
Processing supplier data allows WHHA 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.
WHHA 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.
- Do I have to provide personal data
You have some obligations under your contract agreement to provide WHHA with relevant data in order for us to enter into a contract with you. In particular, you are required to provide relevant and accurate contact details and invoicing details, and it is in your best interests to provide all relevant information pertaining to your services. Failing to provide this data may mean that we are unable to fulfil our contractual obligations to you.
- Who can access personal data
We disclose supplier data for the purposes of operational use with WHHA employees.
If necessary, WHHA will share your data with third parties such as solicitors and Courts in relation to disputes, or with third parties that process data on our behalf, such as for the purposes of end of year accounting.
We will never sell your details to a third party or transfer your data to countries outside the European Economic Area.
- How do we protect personal data
WHHA takes the security of your data very seriously. WHHA has internal policies and controls in place to ensure as is reasonably practicable that your data is not lost, accidentally destroyed, misused or disclosed to irrelevant third parties, and that your data is only accessed and used by WHHA employees in the performance of their duties. Electronic supplier data is stored securely via a secure server and password protected systems. Financial information is also stored within WHHA’s chosen online banking systems. Hardcopy information is locked away when not in operational use. Data is subject to restricted access as appropriate.
Where WHHA engages third parties to process personal data on its behalf in the course of its business operations, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate measures to ensure the security of data held.
- How long do we keep personal data
WHHA will hold your data for the duration of the contract between us. The periods for which your data is held after the end of the contract is dependent upon the service requirements. If we use a supplier service once a year we will maintain your details on our list of approved suppliers. Any service used less than once a year will be removed from the list from one year after the last action of the contract.
Any supplier details or marketing literature deemed irrelevant during the review process will be destroyed via shredding or deletion from the system/supplier list.
- The right to be informed how your personal data is processed
This guide informs you how your data will be processed and sets out our 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 Housing Association holds about you. You can do this by writing to:
Data Protection Officer
2c New Mart Road
Or e-mailing: email@example.com
West Highland Housing Association 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 Housing Association 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
If you wish to move to another landlord, you can ask us to pass on the personal data we hold about you to the new landlord, where you have provided that personal data to us and we have been processing it to perform a contract with you.
- The right to object
You have the right to object to our processing of your personal data. However, if West Highland Housing Association 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 us to have the decision investigated by a member of staff.
- How to action your rights under the 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 Strategy and Business Support Team by e-mailing firstname.lastname@example.org.
- The right to complain to the ICO
If you have a concern about the way West Highland Housing Association is processing your personal data, you may raise a complaint with the Information Commissioner’s Office.
Information Commissioner's Office
0303 123 1113
This privacy notice was last reviewed on 17 September 2021.