Our privacy notice

We will only collect, use and store personal information about you and other household members so that we can provide the services and support you need or where we have a legal obligation to do so. This includes housing management, support and advice, repairs and maintenance, rents, transfers, membership and any other services we provide.

By doing this we can also:

• Make sure the information we hold about you is correct and up to date.
• Provide services that are fair, equitable and in line with the Equality Act 2010.
• Support the health, safety and safeguarding of our customers and employees.
• Improve the services we provide to you.
• Provide you with information about us and the work we are doing that may be of interest to you.

We will only collect personal information when we need this. The information we hold about you is usually information you have given us or information related to your customer history with us. This is likely to include:

• Names and dates of birth of people in your household to keep our records up to date and help prevent tenancy fraud and illegal subletting.
• Contact details, such as telephone numbers and email addresses, so that we can communicate with you and keep you informed about other services which may be useful to you.
• Transaction history, such as payments of your rent or invoices, and your bank account details.
• Information related to your health or support services. If you ask us for care and support requirements we will hold detailed information about your needs and your family’s needs. This may also be to provide you with information relating to products or services from us or from organisations we work with to provide, for example, training or employment opportunities.
• Financial assessments on your household income and expenditure to help you to maintain your tenancy and manage your financial circumstances
• Recordings of your telephone calls to us, as some of our calls are recorded for training and monitoring purposes so that we make sure we are providing you with a high quality customer service.
• We may capture your image on CCTV systems if you visit one of our estates or offices. We use CCTV systems for safeguarding purposes and to prevent and detect crime.
• We may hold information provided by third parties where it is relevant to your circumstances, for example, information from social workers or health professionals or where you have applied for a property through Homeseeker.

When you provide information about household members we assume that you do so with their full knowledge and consent. Where enquiries relate to household members, it is in our legitimate interests to know who will be living in our premises to check that accommodation offered is adequate for current and near future needs of the household and to check that household members’ needs are being met.

We have a legal or contractual obligation to process this information. Without this information, we may be unable to provide the services we are responsible for. For example, we would not be able to consult with you about changes to your service if we do not hold your contact details. It is also in our legitimate interests to make sure that service delivery meets the needs of our service user and their household. Please speak to us with any concerns.

The information we have about you is kept securely in accordance with Data Protection legislation. Your data is seen only by those officers who need to see it to carry out their duties and will only be kept for as long as it is needed to fulfil the reason for collecting it in the first place.

Once your personal information is no longer needed it will be removed from our systems or anonymised so that you cannot be identified from any data we might keep for statistical or analytical purposes. There are national guidelines that apply to Housing Associations and we comply with those as well as with the law.

Sometimes we need to share personal information we hold about you with other organisations that we work with or who provide services on our behalf.  When sharing information we will comply with all aspects of data protection law.

Where the information is of a sensitive nature, for example about your health, we will generally obtain consent from you prior to sharing this information, unless we are required or permitted to share this by law.

If we do share your information it will only be for the following reasons

• To make sure you receive all the benefits you are entitled to,
• To prevent fraud or other crime,
• To protect public funds,
• To protect your health or wellbeing, that of members of your household or the wider community,
• To fulfil our statutory or regulatory obligations.

Where ‘sharing’ your data is in our legitimate interests, we may share relevant information without seeking your consent first. This may be with:

• Our contractors to facilitate repairs, maintenance or improvement work to your property.
• Local authority teams such as social services, environmental health and benefit agencies.
• Utility companies (and their representatives) and Council Tax Departments to make sure your billing details are correct.
• Third parties providing services on our behalf. For example, an out of hours call centre; a mailing company distributing our newsletter; a research company carrying out a customer satisfaction survey; a translation service to communicate with you in your preferred method or a debt collection agency pursuing former tenant arrears.
• Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative.
• Police and other relevant authorities (e.g. Department of Work & Pensions, Probation Service, HM Revenue and Customs) in relation to the prevention and detection of crime, the apprehension of offenders or the collection of tax or duty.
• Other statutory organisations e.g. social services and health authorities as necessary for exercising statutory functions.

We may also share information

• When required by law for example where ordered by the Court or to protect an individual from immediate harm.
• To third parties in relation to a property sale/[purchase.

Much of the personal information that we process is held electronically with our servers located locally

If personal information is transferred outside of the European Economic Area we will take steps to ensure that your privacy rights continue to be protected.

You have the right to see any information we hold about you. You can ask for this information, called a Subject Access Request, by talking to us, emailing us or writing to us.

We will supply the information to you free of charge. However the law allows us to charge a reasonable fee for supplying information for repeated requests for the same information, where the request is excessive or where the request is manifestly unfounded. We may ask you to complete a form which will enable us to more quickly define and locate the information you have requested.

If you are seeking to obtain specific information (e.g. about a particular matter or from a particular time period), it helps if you clarify the details of what you would like to receive in your written request.

If someone is requesting information on your behalf then we will need written confirmation from you to evidence your consent for us to release this and proof of ID (both yours and theirs).

We will acknowledge your request straight away and we will respond to you within 30 calendar days.

If you feel that the data held about you is incorrect you can ask us to change it. In some circumstances we may need to verify the accuracy of the data to be changed.

In some circumstances you can ask us to delete or remove personal data where there is no compelling reason for its continued processing. This is not an absolute right and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data. Our response will also be guided by the provisions in our retention schedule.

If you are not happy with the way we process your data please contact the Data Protection Officer in the first instance. If you feel that you need further clarification or support you may wish to contact the Information Commissioners Office by ringing 0303 123 1113 or go to their website, www.ico.org.uk