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25/10/2021
Success Story

Data protection solution for housing cooperatives – NEUE LÜBECKER proudly boasts a tailored solution

Housing cooperatives work with the aim of providing their members with affordable and modern long-term housing. In contrast to other private housing and real estate companies, their tenants always also maintain a membership with the cooperative. The membership can already exist before the start and even after the end of the rental relationship. Is the GDPR obligation to delete personal data irrelevant in this case? Not at all! We show what needs to be considered both technically and content-wise and present the implemented solution at the NEUE LÜBECKER housing cooperative.
Datenschutzlösung für Wohnungsbaugenossenschaften am Beispiel der NEUE LÜBECKER

© Dirk Silz Fotografie

Nature and characteristics of the housing cooperative


When establishing a lease with a cooperative, prospective tenants must also acquire membership in the cooperative. This entails the acquisition of compulsory shares and, if necessary, other voluntary cooperative shares, which are subject to an annual dividend. This subscription of shares is directly linked to the leasing of an apartment. Only individuals who rent an apartment can become members and thus co-owners of the housing cooperative. Cooperative members also receive a provision entitlement for housing, which they can exercise at any time depending on availability. Even after the termination of this so-called permanent residential right to an apartment, the membership can continue if desired. In addition, the employees of NEUE LÜBECKER are members of the cooperative even if they don’t have a rental relationship with the company. These special characteristics must be mapped separately in the cooperative’s ERP system. Third-party providers have developed a membership module for SAP® systems that can be used to manage members. NEUE LÜBECKER also uses a module like this.


NEUE LÜBECKER – a future-oriented company


With almost 16,000 apartments and over 18,000 members in 2020, NEUE LÜBECKER is one of the largest housing cooperatives in northern Germany. For over 70 years, the company has been successfully meeting the challenges of the times and acting with a balance of economic, ecological and social responsibility. With construction investments in maintenance, modernisation and new builds reaching a total of around €70 million in 2020, NEUE LÜBECKER is fulfilling its mission to provide modern and affordable long-term housing. The recently implemented technical solution for handling personal data in accordance with the GDPR once again proves the Lübeck cooperative has the future in sight.

Informationstechnologie und Immobilien (IT&I) Ausgabe Nr. 31 / April 2021

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Specialised solution for the individual needs of housing cooperatives


The common assumption that cooperatives are not affected by the obligation to delete personal data due to their memberships often existing beyond the rental period is a fatal misconception. Here, too, the imperative is to retain only as much data as is actually necessary. Ulf Linkner, head of IT at NEUE LÜBECKER, and Petra Spranger, project manager in accounting/controlling, describe the challenge of mandatory data deletion for cooperatives: “We map our members in SAP® in parallel via the business partner management and via a member module. The two modules are coupled together. However, the termination of a business partner relationship in the technical sense must not simultaneously cause the deletion of the person and their data from the member module.” One of the first tasks for PROMOS was to closely examine the interaction between the business partner management and the member module in order to avoid unwanted deletions when introducing the PROMOS anonymisation solution.


It was quickly evident that the member module tables were synchronised with the contents of the business partner tables. This meant that a business partner’s deletion would normally automatically result in their removal from the member module. This was to be avoided during introduction of the new solution. Additional special cases that had not been relevant for other housing and real estate companies also had to be considered. For example, some business partners are members of the cooperative but do not have a rental agreement. Furthermore, a member’s shares may be transferred to an heir after the member dies. There is also no rental agreement in this case, but the person must not be anonymised. The standard solution from PROMOS has been adapted for NEUE LÜBECKER in the project based on the cooperative’s needs. The PROMOS anonymisation solution went live smoothly within only six months of being commissioned.

Anonymisierung personenbezogener Daten im Mitgliedermodul von NEUE LÜBECKER gemäß DSGVO

Figure 1: It is clear on the “Partner Data” tab of the member module that the personal data no longer required has been anonymised.

Legal background


The regulations of the EU GDPR apply wherever personal data is processed. The mere fact that a member is still a business partner after the termination of the lease is not a sufficient reason to retain all personal data. Rental contract-related data such as bank information must be removed from the system within the specified time limit. For this purpose, PROMOS uses an approach based on data anonymisation in which the information to be deleted is automatically overwritten using a special report. In addition, the PROMOS data protection package includes a report that can be used to provide an overview of all the personal data processed by the company on a specific business partner. This enables companies to easily and automatically comply with requirements arising from the EU GDPR.


Summary


With NEUE LÜBECKER eG, PROMOS now counts the first housing cooperative among its customer base. At the same time, the data protection solution tailored to the needs of cooperatives is also being introduced at another housing cooperative in parallel. The project with NEUE LÜBECKER eG went exactly as planned, both in terms of time and budget. With warm words, Linkner drew a very positive conclusion from the successfully completed project: “A big thank you goes to Mr Mätsch and his team from PROMOS for the seamless cooperation, consistent availability for enquiries, good technical input and fast processing of all concerns and questions!” The company also has a very positive outlook regarding future joint projects with PROMOS. NEUE LÜBECKER is convinced that PROMOS is able to recognise the specific needs of cooperatives and to take them into account when developing and implementing solutions.

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