Equalities Data Collection in My Home - Webinar

For Housing Online’s very first webinar, the representatives of eleven Scottish Housing Associations came together for an hour to discuss data protection law and the collection of Equalities Data within Housing Online’s My Home portal.

Guest speaker Daradjeet Jagpal, Director and Legal Consultant at Information Law Solutions, kicked off proceedings with a run through UK Data Protection law and the Scottish Housing Regulator’s framework for equalities data collection to ensure that Registered Social Landlords (RSL) “pay due regard to the need to eliminate discrimination, advance equality and human rights, and foster good relations across the range of protected characteristics in all areas of its work, including its governance arrangements”.

Social Landlords have an obligation to gather data to demonstrate their commitment to, and their progress towards eliminating discrimination. They are also bound to handle that data lawfully, fairly and transparently; to specify how that data is to be used, how it will be used and how long it will be stored.

"The My Home Equalities module provides My Home customers with a very elegant solution to the potentially thorny problem of gathering data from tenants to demonstrate a commitment to eliminating discrimination in a way that is lawful, fair and transparent."

If the data is collected in a named format, where information linked to tenants is accessible to staff, then you need to carry out a data protection impact assessment, develop an appropriate policy, update privacy notices, implement a collection procedure and prepare internal systems and ensure restricted staff access.

The data can also be collected anonymously which, whilst it solves a lot of the privacy headaches, does make the data difficult to be useful. Anonymous data cannot be filtered, will contain current and former tenants and may contain duplicates if tenants are able to re-submit their data at any time.

However, there is a third option, pseudonymous, where the data is not linked directly back to individuals, but it will only contain the latest submissions by current tenants and can thus be filtered for specific uses. For example, you could extract the data only for new tenants in the past year or for a particular area.

This is where the My Home Equalities Data Collection module comes in.

As demonstrated during the session by Phil Sorrell, Housing Online’s Development and Customer Relations Director, this module enables the simple, pseudonymous collection of equalities data from tenants. The module also supports anonymous and named collection methods.

As well as asking tenants who log onto their My Home accounts to provide their details, My Home enables staff to access anonymised, aggregated data for reporting and to prompt (via branded emails or letters) any tenants who have not yet submitted their information or who need to complete the annual refresh of their submissions. Any amendments to the data will automatically overwrite the old data, which is then securely deleted and will not be included in any future reporting.

From a GDPR perspective, there is no legal requirement for a privacy notice for data collected in this way. However, the My Home Equalities module does provide as standard a customisable “comfort statement” highlighting why the data is being collected, what it is used for and how it is stored.

The Equalities module thus provides My Home customers with a very elegant solution to a potentially thorny problem.

Housing Online are planning to host regular My Home webinars on topics like these. If you would like to attend a future session or to suggest a topic you would like to see covered, please drop us a line at info@housing-online.com

For any queries on My Home in general, or the Equalities Module in particular, please contact Housing Online at info@housing-online.com

For further consultation and guidance on the laws relating to Data Protection, Daradjeet can be contacted at: