How we use your information

We collect and use the following types of personal information:

Identity information: name, gender, date of birth, national insurance number, identity documents (such as a copy of a passport or driving licence), photograph, password.

Contact information: address, telephone number, email address, emergency contact/next of kin details.

Financial information: rent and service charge payments, benefit entitlements and payments, income, and expenditure.

Household information: details of who lives in our homes.

We may also collect that is more sensitive, which includes:

• Racial or ethnic origin
• Religious beliefs
• Health information, including any disabilities
• Details of criminal activity and legal proceedings

Other types of information we collect includes:

• Immigration status
• How customers use our services
• Customer feedback, including satisfaction surveys and complaints
• CCTV images
• Call recordings (this only applies when you call our customer contact centre on 0345 678 0555)
• Images, video or audio recordings to help us provide services, including repairs, estate services and ASB

Your credit or debit card information

If you use your credit or debit card to pay your rent or service charge, we pass your card details securely to our payment processing partner as part of the payment process. We do this in line with the Payment Card Industry Data Security Standards (PCIDSS) that we must comply with. We do not store your card details on our website or on our databases.

Data protection law allows us to use personal information but only if we have a proper, lawful reason to do so. We use information for the following lawful reasons:

• To manage a contract that you have with us or will be entering into with us. This will be your tenancy agreement or your lease.
• To meet a legal duty.
• To do something that is in the public interest.
• When you give us permission (consent) to use your information in a particular way. You can withdraw your consent at any time, if you'd like to withdraw your consent, please get in touch.
• To protect a person’s vital interests (in other words, to protect someone from serious harm).
• When it is in our legitimate interests to do something. This applies when we have a genuine business reason to do something, but even then, it must not unfairly go against what is right and best for you. Our legitimate interests are:
  • preventing fraud;
  • making sure our systems are secure;
  • promoting our services;
  • advertising our homes;
  • measuring customer satisfaction;
  • monitoring how customers use our website and our systems.

If we need to use personal information that is more sensitive (information about your health for example), we will get your permission first, unless we need to use the information to establish or defend legal claims or if there is a substantial public interest, such as safeguarding someone from harm.

Here is a list of all the different ways that we use your personal information.

Applying for a home

When you apply for a home with us, we’ll need to collect information about you and the people who will be living with you. We collect this information to make sure that you are eligible for a home and to make sure that we find a home suitable for you. It could affect your application if you are unable to provide the information we need.

We will ask about where you are currently living, the type of home you are looking for and if you have any health, medical needs or special family circumstances that mean you need a specific type of home (like a ground floor flat for example).

For legal reasons, we must ask for proof that you and any household members over the age of 18 have the right to rent a home in the UK. You can find out more information about why we do this here. We will also need to take your photograph for fraud prevention reasons.

We need to make sure that you can afford to live in your home so we will ask you to provide information about your income and expenditure and any benefits you may be receiving. We will need to carry out some checks with your previous landlord and, in certain circumstances, contact other agencies such as the housing benefit department, the police or the probation service.

In certain cases, we may need to carry out extra checks on the information you have given us. For example, we may need to do a credit check or check the electoral register.

Managing your tenancy or lease

Whilst you are living in your home, we will use your information to make sure that you are meeting the contractual obligations set out in your tenancy agreement or your lease and to make sure we are meeting our obligations to you.

We will use your information to collect your rent and service charge and arrange repairs and servicing to your home. We may sometimes need to use your information to deal with anti-social behaviour or to investigate and respond to complaints or other feedback you may give us.

We may sometimes share personal information with utility companies and council tax departments to make sure that any bills connected with your home are paid and up to date.

Improving our services and customer satisfaction
We often use your personal information to look at ways to improve our services and to better understand your needs, circumstances, preferences, and interests.

We may ask you to take part in customer satisfaction surveys. These surveys are always optional, and you can ask us not to include you in future surveys by clicking on the opt-out link that we include at the bottom of all our surveys. Alternatively, you can get in touch with us using the one of the methods on our contact us page.

Calls to our customer contact centre (0345 678 0555) are recorded and used for training and monitoring purposes. We keep call recordings for 6 months.

Keeping your information up to date

When you call our customer contact centre, we will ask you to confirm some security questions and then check the contact details that we have for you to make sure that they are up to date. You can help us by letting us know whenever any of your information changes by calling us on 0345 678 0555 or updating your own information using MyAccount.

Marketing, profiling & research, and keeping in touch

If you have opted-in to receiving promotional messages from us or asked us to include you on our homes marketing lists, we will send you the information by email or by text. You can opt-out of receiving marketing messages at any time by clicking on the unsubscribe link at the bottom of the email, by getting in touch with us using the details here or by updating your contact preferences using MyAccount.

We will never share your information with other organisations for marketing purposes.

From time to time, we may get in touch with you to tell you about service changes and other things that affect you. You can tell us how you would like us to contact you by getting in touch with us or by updating your contact preferences using MyAccount.

We analyse some of your personal information to help us manage and collect your rent and service charges. We use software to identify customers who may need our support or advice and the best way to get in touch. We use this information to prioritise our services to customers who are most in need of help to manage their rent and service charges. If you would like to know more about this, or if you would prefer us not to use your information in this way, please contact us.

Photographs and publications

With your permission, we may use your photographs and video recordings in our magazines, newsletters, annual reports and on our website and social media channels. If you want us to stop using your images in this way you please get in touch.

We will keep your images for up to three years but, if we have used them in any leaflets or publications, they may circulate in the public domain for longer.

Keeping our homes, customers, and colleagues safe

Some of our schemes and offices have CCTV installed to prevent crime and anti-social behaviour and to keep our customers, colleagues, and visitors safe. CCTV footage is automatically deleted after 30 days unless we need to use it as evidence. We sometimes install noise monitoring equipment to investigate noise nuisance and our customers and members of the public may send us images, videos, and audio files to help us investigate crime and anti-social behaviour.

We often need to share personal information with other organisations. Here is a list of the different ways that we share information and why:

• We share your contact information and any safety alerts with our repairs contractors so that they can arrange repairs and servicing visits to your home.
• We share your contact information with companies that carry out surveys and research for us.
• We share information about your rent and service charges with local authorities and the Department for Work and Pensions to help with housing benefit and Universal Credit claims.
• We may be asked to give references to other housing associations or landlords if you move home.
• We may sometimes need to carry out identity checks or credit searches when customers apply for a home with us. This will involve sharing information with credit reference agencies.
• We share information with the police, courts, probation services and other law enforcement agencies for crime prevention purposes or when taking legal action.
• If we think that someone may be committing fraud, for example by illegally sub-letting their home, we will need to investigate and share information with local authorities and fraud prevention agencies.
• If we have concerns about an individual’s health, safety, or well-being, we may share information with social services, health providers and support agencies, including charities and other voluntary organisations.
• We share information with our auditors, financial and tax advisors, solicitors, and other professional advisers.
• If there are any unpaid debts connected to your home that you are responsible for (council tax or gas/electric bills for example) we will share information with local authority council tax departments and utilities providers.
• If you have given us permission, we will share information about your tenancy with your nominated representative.
• If there are any outstanding rent or service charge debts, we will share information with debt recovery agencies.
• We have to share statistical information with our regulators and other government departments about the types of homes that we rent and sell and the people we provide homes to.

We usually keep information relating to your tenancy or lease for six years after your tenancy ends or when you sell your home. It is then securely destroyed or deleted. This allows us to meet certain legal duties and provide further services that you might need, like giving references to another landlord. However, if you still have outstanding debt or if there are other outstanding legal matters, we may need to keep your information for longer than six years.

Security

We will take steps to protect any information that you (or other organisations) have given to us. We hold Cyber Essentials Plus certification and have technical security measures in place as well as policies, procedures, and training to safeguard the information that we hold.

If we need to give personal information to another organisation to provide services on our behalf, we carry out checks to make sure they can look after the information, and we put contracts in place to make sure your information is handled properly and securely.

Transferring your information outside the UK

We may occasionally use suppliers or service providers that are based overseas. We will always make sure that there are appropriate safeguards in place before doing this and the safeguards will be listed in the contracts that we use.

Data protection law gives you certain rights over how your information is used. These are explained below:

• You have the right to know why and how we use your information, how long we keep it for, and who we share it with.
• You have the right to see or have a copy of your information, this is called a subject access request or SAR. We will need you to provide us with details of what information you need, (using the contact details below) and, in most cases, there will be no charge.
• You have the right to ask for information to be corrected if it is incorrect or incomplete.
• You have the right to ask for information to be deleted if we don’t need it anymore or we are using based on your consent.
• You have the right to ask us to restrict how we use your information or object to how your information is being used.
• You also have the right to ask us not to profile you and you can challenge any automated decisions we might make about you.

If you would like to exercise any of these rights or know more about how we use your information, get in touch.

If you would like to exercise a right of access you can use this Subject Access Request form.

For any other rights or if you would like to know more about how we use your information, get in touch.

If you are not happy with how we use your personal information, you can make a complaint. You can find details of our complaints process and how to make a complaint here.

If you are still unhappy with how we handle your personal information after contacting us, you have the right to complain to the Information Commissioners Office. You can also write to the information commissioners office at:

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Freedom of Information Act

The Freedom of Information Act does not apply to us, but we want to be accountable for what we do. We want to give you the chance to see how we carry out our business and challenge us on anything you think is expensive, unreasonable, or unnecessary.
We will consider any requests for information, but we may refuse if we feel that releasing information will put our business or customers at risk, if it concerns legal matters, or if it would breach data protection or confidentiality. We will always consider the following when asked to share information:

• Whether the information will be useful to the person asking for it.
• Value for money – whether the cost of providing the information is justified.
• Whether the information is sensitive to our business or any individual.

The final decision about whether to share or not will rest with the executive team or customer services committee.