This short article focuses on how electronic statements can be delivered to tenants in the Social Housing sector under GDPR.
Traditionally, tenants would receive their rent statements by post. However, as email became more prevalent many organisations switched to sending statements electronically to save money and to meet digital expectations. Many housing management systems have made this process convenient for registered providers (RP’s) with batch processing or automated email generation.
From the 25th May 2018, RP’s should no longer send electronic statements to tenants via an unsecure email system. One of the aims of GDPR is to protect against any potential personal data breaches, accidental or deliberate, leading to disclosure to unrelated third parties.
The most likely cause is sending an unencrypted email to an incorrect address, enabling the recipient to access the personal data.
In the event of a personal data breach, you will need to establish if there was a risk to the individuals rights and freedom. Depending on this assessment you may even need to report the breach to the ICO. More information on this can be found on the ICO website, including the penalties for breaches. These can be as much as 4% of annual turnover, or 20 million euros.
The most obvious solution would be to revert back to using standard postal services. However, this approach does also bring back the old challenge of the tenant actually opening and reading the document.
Sending a quarterly statement by post also costs in the region of £4 per tenant per year. This is without taking into account the labour costs associated with generating the statements.
An online portal provides a solution and enables a tenant to securely log-in using their credentials, to view or download their rent statements. This kind of solution means that the tenant will have to verify their identity each time they wish to view their statements, making it GDPR compliant.
With a traditional Pyramid Housing Management System implemented on our customers infrastructure, OmniLedger are strongly recommending that the Rent Ledger Email Statement feature be removed. For any customer who consents to this, our support team will remove this on their behalf.
With the hosted Pyramid Housing Management System, the Rent Ledger Email Statement feature will automatically be removed and all affected customers will be notified.
In place of the Rent Ledger Email Statement, OmniLedger have developed a tenant document portal where newly generated statements are automatically uploaded via the standard statement production software. An email or text message will then be sent to the tenant to notify them that their new statement has been uploaded and can be viewed online by logging in.
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