Privacy

Privacy
Housing 21 (“We”) are committed to protecting and respecting your privacy. This privacy notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we treat it.

Who We Are

We are the data controller and we are registered with the Information Commissioner’s Office (ICO) (Registration Number: Z5515259). We are an exempt charitable housing association. We are incorporated under the Industrial and Provident Societies Act 1965 (Registration number IP16791R) and under the Housing and Regeneration Act 2008 (Number L0055). Housing 21 is also a registered society under the Co-operative and Community Benefit Societies Act 2014.

We Take Privacy Seriously
This privacy notice tells you what to expect when Housing 21 collects your personal information. Please click to view our Data Protection Policy.

It is important that you read this notice, together with any other privacy notice(s) we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Housing 21 complies with the General Data Protection Regulation (GDPR) 2018 and the Data Protection Act 2018 (DPA18) in relation to the personal information that you provide us and ensures that it is not misused. The DPA18 together with the GDPR defines a set of rules and guidelines we must follow when handling your information, these are referred to as the Data Protection Principles. These principles state that personal information shall be:

a) processed lawfully, fairly and in a transparent manner in relation to individuals;
b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal information that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal information are processed; personal information may be stored for longer periods insofar as the personal information will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals;
f) processed in a manner that ensures appropriate security of the personal information, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How We Use Your Personal Information
The personal information you provide us with will be retained only for as long as necessary to fulfil the purposes for which it was collected or as required by law. We do not share personal information with third parties except as necessary to carry out our business or as required by law or other legal processes, and we never sell your personal information or pass it to marketing companies. Personal information collected by us may be transferred to other wholly owned subsidiary companies where it is necessary to meet the purpose for which it was submitted.

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

Where we need to perform the contract we have entered into with you.
Where we need to comply with a legal obligation.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

Where we need to protect your interests (or someone else’s interests).
Where it is needed in the public interest or for official purposes.

Information We May Hold About You

The information we hold on our records concerns our relationship with you. For example:

(This list is not exhaustive)

We hold names, addresses, dates of birth, photographic ID and information about your previous housing circumstances to assess housing applications and help prevent tenancy fraud.
We hold contact details for you, such as postal address, telephone number and email address, so we can communicate with you by your preferred means, and keep you informed about services we offer which may be useful to you.
We record information about your needs (for example if you have a carer or social worker; if you need adaptations in your home; if you need large print or translated text) to ensure that we take account of any support needs in our dealings with you, and to improve our communications with you.
We record information to enable us to provide housing management services. For example, we record reports of anti-social behaviour; complaints; change in circumstances and information about housing options (e.g. if you have a medical need which means you need to move).
We keep financial records about the amount of money you have paid us; any amount(s) outstanding and action taken to recover money you owe.
We may hold information about you if you are engaged with our additional guidance and support services. For example, in connection with access to training and employment we may hold information about your job history and skills and experience, or if we support you to improve your financial circumstances, we may hold information about your household income and expenditure.
We may capture your image on our CCTV systems if you visit a property, office or court which is covered by this facility. Any CCTV recordings will be held in accordance with our document retention policy before being erased.
We record the findings of surveys and other research to help us improve our service to customers. The information you provide will be anonymous unless you agree that we can use your details.
Where applicable, we will use the personal data you have provided us to help us to support your Local Authority to administer and manage your Housing Benefit.
We may also conduct voluntary, anonymous surveys to monitor our equality and diversity profile ‘equality profiling data’, to ensure our services are delivered in a fair and equitable way and to better understand the demographics of our residents and employees to ensure they are representative of the communities we work in.

We hold robust records of most of the contact we have with you, or about you, and we process this information so we can deliver services to you, generally, the information we hold will have been provided by you (on application or enquiry forms or when we communicate with you). However, we may also hold information provided by third parties where this is relevant to your housing circumstances e.g. from social workers and health professionals (such as doctors, carers and occupational therapists).

We will only ask for personal information that is appropriate to enable us to deliver services to you. In some cases you can refuse to provide your details if you deem a request to be inappropriate.

However, it is important to note that where you refuse to provide information, in the performance of your tenancy agreement with us, it may impact upon our ability to provide certain services to you.

Situations in Which We Will Use Your Personal Information

We need all the categories of information listed in this notice, primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below:

Making a decision about your tenancy contract/agreement
Dealing with legal disputes involving you, or other residents, our employees, workers and contractors, including accidents at work
Complying with health and safety obligations
For the prevention and detection of fraud and apprehension and prosecution of offenders
Managing your rent including, where applicable, liaising with your respective local authority to administer and manager your Housing Benefit.

Some of the above grounds for processing your personal information may overlap and there may be several grounds which justify our use of your personal information.

Sharing Your Information

Housing 21 will only disclose and share your personal information to third parties with your consent; however, we may sometimes need to share information without your consent to comply with any legal obligation or to fulfil the purposes for which it was submitted. For example, to process Housing Benefit payments and to liaise with your respective local authority to manage your rent service charges.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions as part of a contractual obligation.

We will not transfer your personal information inside or outside of the UK unless there is adequate protection in place.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Within Property Sales and Lettings – we process data using consent (where necessary), legitimate interests or a contractual obligation as a legal basis to process your data in the following instances:
- Online Enquiry Forms
- General Sales Enquiries via email or telephone
- Corporate Enquiries via email or telephone
- Enquiries in writing
- Enquiries via the telephone

Within the Communications Team – we process data using consent (where necessary), legitimate interests or a contractual obligation as a legal basis to process your data in the following instances:
- Conference participants
- Resident information

Promotional Offers from Us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us only, or have received services from us and, in each case; we will only share this information with you where you have consented to receiving that marketing. This also applies when you have expressed an interest in one of our properties and consented to Housing 21 keeping you on a waiting list and/or sharing details of similar properties which may of interest to you.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any company outside Housing 21 for marketing purposes.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by contacting the Communications Team or the Data Protection Officer (DPO) .

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service or other transactions, such as signing up to a tenancy agreement.

Your Rights

Right to Data Portability
When processing your personal information to fulfil a contract to which you are a party, you have the right to request electronically held personal information to enable easy transfer to another organisation. Where it is technically feasible you may request that the information be transferred directly between organisations. Once the request is made, the information should be provided to you within 1 month (30 calendar days).

Right to be Forgotten
You have the right to have the information we hold on you deleted where the use of that information would no longer meet the requirements of the General Data Protection Regulation or the Data Protection Act 2018. Once the request is made, the information must be deleted within 1 month.

Where the information in question has been made public or transferred to a third party, we must also take reasonable steps to inform those third parties about the request for deletion including any links to, or copies of that personal information.

The above does not apply when it is necessary to keep the information in relation to legal proceedings, to comply with a statutory obligation, or to perform tasks in the public interest.

Right to Rectification, to Object and to Restrict Processing

Rectification: you have the right to have inaccurate and incomplete information about you rectified and completed.
Right to object: in certain circumstances, you have the right to object to your personal information being processed. Depending on the legal basis for processing, this may either be an absolute right (i.e., direct marketing), or may be subject to us being able to demonstrate compelling legitimate grounds which would override your own interests, or where the information is needed for the purposes of legal claims.
Right to restriction: you have the right to request that information is no longer processed (other than it being stored) in particular circumstances, such as when we are dealing with the correction of any inaccurate information; the processing is unlawful, but you object to its erasure; or the information is no longer needed but you require the information to be kept for the purposes of a legal claim.

Consent

Where we are relying on consent to process your personal data, you have the right to withdraw consent at any time, so long as, the information is not part of a statutory or contractual requirement/obligation. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. We would like you to be aware that this may affect the quality of service we can provide to you. For example, we need to know the composition of your family so that we can allocate a suitably sized property to you.

You have the right to object to direct marketing from the association, this may include post repair surveys, tenant satisfaction questionnaires, tenant profiling etc. To withdraw consent at any time, please contact the Data Protection Officer.

Accessing the data held about you

Housing 21 recognises its responsibility for protecting the privacy of your personal information. You have a legal right to see the personal information we hold about you; this is called a subject access request and by law we have 30 calendar days to respond to you. We will seek to comply with your request however there may be some circumstances where it may not be possible to comply with your request fully, i.e., we may refuse or charge for requests that are manifestly unfounded or excessive. If your request is refused, we will write to you within 30 calendar days to advise you why, you will then have the right to complain to the supervisory authority and to seek a judicial remedy.

If you wish to submit a subject access request, please contact the Data Protection Officer (DPO) at dataprotection@housing21.org.uk.

Retention of Your Information
We have a Document Retention Policy & Procedure and Retention Schedule in place, which outlines how long we keep different types of information for. This policy is regularly reviewed based around good practice guidance issued by the National Housing Federation.

Information We Collect Via Our Website

We collect various types of information from visitors to our websites.

We do not pass on any personal information you have given us to any other site, the system will record information if volunteered to us by you, for example on the online forms. This will be treated as confidential.

Our website contains links to other websites. This privacy notice applies only to our site. If you move to another site that collects information you should read their privacy statement.

Cookies

Our website uses cookies to track visitors via Google Analytics. You can find out more about what this means and how to turn off cookies in your browser by visiting about cookies.org. For more information about the cookies we use, please see Housing 21 - Cookie policy.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do this.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law, such as for the prevention and detection of fraud and/or the apprehension and prosecution of offenders.

What We May Need from You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Changes to this Privacy Notice

We keep our privacy notice under regular annual review and will place any updates on our website; you will be notified of any major changes to this notice.

Concerns
You have the right to complain to the Information Commissioner’s (ICO) Office if you think there is a problem with the way in which Housing 21 are handling your information. To contact the ICO, please call 0303 123 1113 or visit their website at https://ico.org.uk/. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Contact us
If you have any questions about the administration of your personal information please contact the Data Protection Officer on 0300 790 1325 or at:

Data Protection Officer (DPO)
Housing 21
Tricorn House
51-53 Hagley Road
Birmingham
B16 8TP