Privacy & data protection

Protecting your data... keeping your confidence.

In order to help provide you with the best and most appropriate service, we need you to help us by providing us with your detailed information.

We begin the process of collecting information about you and if appropriate your family when you apply to us either directly or through one of our Choice Based Letting partners.

We appreciate that some of the information you give us will be very sensitive including details about your health and any disabilities you may have. Because the information you provide us is very personal we take your privacy & confidentiality very seriously.

We aim to keep your information as up-to-date as possible so that when your needs change over time, the services we provide you can change to reflect these different needs. We will also ensure we make every possible effort to fulfil our obligations under the General Data Protection Regulation (GDPR) which takes effect on the 25^th May 2018 and the new Data Protection Act 2018  

We will keep your personal information secure and only keep it as long as we need to, although please bear in mind we are legally obliged to keep some records for an extended period of time, such as housing benefit payments, before it’s safely destroyed.

Who is responsible for your data?

Our Privacy Notice applies to all the personal data that Your Housing Group collects and uses.

References in this Privacy Notice to “Your Housing Group”, “we”, “us” or “our” mean Your Housing Group Limited (a Charitable registered society under the Co-Operative and Community Benefit Societies Act 2014 (30666R) registered with the Homes & Community Agencies (L4203).

We control the ways your personal data are collected and the purposes for which your personal data are used by Your Housing Group, and are the “Data Controller” for the purposes of the General Data Protection Regulations (GDPR) and UK Data Protection Act (2018) when it comes into force.

What personal data do we collect about you?

When using the term “personal data” in this Privacy Notice, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold.

Your personal data may include, for example, your name, contact details, information relating to your tenancy (e.g. your Tenancy Reference Number) or information on how you use our website and online services or how you interact with us.

We collect some personal data from you, for example when you first apply for a property, use our website or contact us. We may also receive your personal data from our commercial partners who provide services to you on our behalf, and our partners’ agencies. 

We may collect and process the following categories of information about you:

• Your name and contact details for use across the organisation and by our suppliers and partners;
• Detailed personal information, such as:

o    Age
o    Bank details
o    Benefits
o    Caring responsibilities
o    Contact details of individuals who you want us to communicate with on your behalf
o    Date of birth
o    Education details
o    Employment details
o    Family details
o    Financial information including income, expenditure details,
o    Lifestyle & social circumstances
o    National Insurance number
o    Nationality
o    Reference information
o    Relationship status
o    Safety & Security details
o    Visual images, personal appearance and behaviour
o    Your particular needs or preferences so that we can understand them better

We may sometimes collect additional information about you from third parties. If we do we will seek to ensure that the information is accurate and up to date.

We will only use your personal information when the law allows us to.  These reasons for processing are known as "processing conditions" and we will always ensure that we have a lawful processing condition whenever we process your personal data. 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, such as providing information HRMC or DWP.
• 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.

Situations in which we will use your personal information 

We need all the categories of information in the list above primarily to allow us to perform our contract with you to provide you with housing and other services with you and to enable us to comply with our 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.

For example we rely on the legitimate interest of using CCTV to provide a safe working environment for our staff and visitors to our premises but we will not use CCTV in areas where you would expect privacy such as toilets or areas provided for prayer and we rely on legitimate interests of securing funding to provide social housing when we provide data about our tenants to funding bodies awarded grants or lenders.  

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

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Change of purpose

We will only use your personal information 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 information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Special Categories of Personal Data  

In the course of providing services to you, we may collect information that details your gender and gender identity, racial or ethnic origin, physical or mental health, sexuality, religious beliefs or alleged commission or conviction of criminal offences.

Such information is included within the “Special Categories of Personal Data” under the GDPR. We only collect this information where you have given your explicit consent, it is necessary under laws relating to social security and social protection law or it is necessary in connection with legal proceedings or you have chosen to make it public.

If we are collecting special category data which we can only process with your explicit consent, we will make this clear at the time.  You will have the right to withdraw that consent and we will explain to you how you can do that when your provide the consent but this may mean we are unable to provide all or parts of the services you have requested from us.  

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of social protection or social security.   In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your tenancy with us that you agree to any request for consent from us.

How and why we use your personal data

We may use your personal data for the following purposes:

1. To process your application for housing, and to administer housing waiting lists. This is likely to include processing information about your history, for example other social housing tenancies you have held or about past criminal offences if we need it to ensure that we can protect our staff and the communities we work.

We may only use information relating to criminal convictions where the law allows us to do so.

2. To manage your tenancy contract, and contact you about your housing needs including:

• Your support needs, so we know how we can assist you before and during your tenancy
• Details relating to the repair and maintenance of your property
• Feedback from our contractors, about their appointments with you

3. Voice recordings to prevent fraud, to ensure we have accurate records and to improve our internal training and quality management
   
   To help you buy part or the whole of your home, including:

• Affordability checks

4. Credit rating data
   
   To provide security:

• We operate CCTV systems this is to provide security for our staff and tenants to help detect and prevent crime. The system will collect and records image, and is used in accordance with CCTV Codes of Practice, which are available on request.

5. To provide additional services, advice and support if you ask for these – this may require us to process the following information

• Name and contact details for someone to contact you (the person may be a member of staff or from another organisation that we will tell you about);
• If you ask us for care and support requirements, we will need to hold detailed information about you and your family’s needs;
• Records of payments for the services provided to you;
• If you contact us about financial problems we will hold detailed information about your income and financial situation;
• If we offer you training or other learning opportunities we will need to ask about your employment and learning history;

6. To communicate with you and manage our relationship with you

• We may need to contact you by telephone, email and/or SMS for administrative or operational reasons e.g. in order to send you confirmation of your property repair bookings, gas servicing and your payments;
• We will use your personal data if we contact you after you have sent us a request, filled in a web-form through our website or contacted us on social media;
• Your opinion is very important to us, so we may send you an email or SMS to seek your feedback;
• We will use the communications you exchange with us and the feedback you may provide in order to manage our relationship with you as our customer and to improve our services and experiences for other customers. 

7. To personalise and improve your customer service experience

• We may use your personal data in order to tailor our services to your needs and preferences, and to provide you with a personalised customer experience e.g. if you inform us about your disabilities;
• We may also collect information on how you use our website, which pages of our website you visit most, which online services you use, in order to understand what you like. We may use this information to tailor the content and services and, if you have agreed to receiving marketing communications, to send you relevant messages;
• If you are in the process of making a request under your account and you leave our website before your request has been completed, we may contact you in order to help you easily complete your request or make payment;   
• You may choose to provide details of your friends, relatives or neighbours who you trust to contact us on your behalf;
• Your name and contact details for customer satisfaction surveys, newsletters and service information;
• With your consent, your name, photo, video or story could be used for brochures, advertising or press releases;
• Details about complaints about our service or other individuals, accidents or incidents involving you or your home;
• Your comments about our service or our suppliers’ services.

8. To inform you about our news and service that you may like

• We may send you marketing communications, if you have indicated that you are happy to receive these, for example when you create an account on our website or apply for a property, and you do not express a wish to not receive such communications;
• If you are happy to receive marketing communications, we will provide you with news from us such as new developments that you may be interested in.
• In addition, we may ask you if you are happy to receive communications promoting our partners’ products and services. We will only do this if you have given your explicit consent which you can withdraw at any time.
• If you do not want to receive marketing communications from us, you can simply tell us so by clicking the relevant box before making your application. You can also choose to opt out from receiving marketing communicationsat any time, by clicking on the relevant unsubscribe link at the bottom of any marketing related email you may receive from us;  
• If you prefer, you can also call our Customer Service team and express your preference to not receive marketing communications send an email to dataprotection@yourhousinggroup.co.uk with the subject title “Unsubscribe”.

9. To fulfil our administrative purposes and protect our business interests 

• The business purposes for which we will use your information include accounting, billing and audit, credit or other payment card verification, fraud screening, safety, security and legal purposes, statistical and marketing analysis, systems testing, maintenance and development. 

10. To comply with our legal obligations

• For example, our obligation to provide your information to the Department for Works & Pensions & HMRC.

Automated Decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

• Where we have notified you of the decision and given you 21 days to request a reconsideration.
• where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
• In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
• If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights. 

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Data Retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a tenant or service user we will retain and securely destroy your personal information in accordance with our data retention policy or applicable laws and regulations.

Your Privacy Rights

The introduction of GDPR provides all UK citizens new and enhanced privacy rights, which Your Housing Group are committed to upholding, and takes its responsibilities regarding our customers privacy rights very seriously.

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

Under certain circumstances, by law you have the right to request that Your Housing Group: 

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.
• If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact [POSITION] in writing.

Accessing your personal data

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Find out how to request the information we hold about you dataprotection@yourhousinggroup.co.uk

Data Protection Officer 

We have appointed a Data Protection Officer to oversee compliance with this privacy notice.

If you have questions in relation to exercising any of your Privacy Rights or you have a question or concern about how we process your data, please contact Your Housing Group’s Data Protection Officer in the first instance at dataprotection@yourhousinggroup.co.uk   

If, for any reason, Your Housing Group does not address your request, or fails to provide you with a valid reason why it is unable to do so, or if you are unhappy with the way we have dealt with your personal data you have the right to contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues to make a complaint. They can be contacted via their website www.ico.org.uk or by telephone 0303 123 1113.

Security of your personal data

Your Housing Group are committed to taking appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage. When you provide your personal data through our websites or online portal, this information is transmitted across the internet securely using appropriate strength encryption.

As detailed in this Notice, we may in some instances disclose your personal data to third parties. Where Your Housing Group does disclose your personal data to a third party, we require that third party to have appropriate technical and organisational measures in place to protect your personal data; however in some instances we may be compelled by law to disclose your personal data to a third party, such as the Police, and have limited control over how it is protected by that party.

The information that you provide us will be held in our systems, which are located on our premises or those of a contractually appointed third party. We may also allow access to your information by other third parties who act for us for the purposes described in this Privacy Notice or for other purposes approved by you. Your personal data may be accessed by and processed outside the European Economic Area (the European Economic Area being the European Union and Iceland, Liechtenstein and Norway, also referred to as the “EEA”) - Where your personal data are transferred outside of the EEA, we require that appropriate safeguards are in place. 

We will retain your personal data for as long as we need it in order to fulfil our purposes set out in this Privacy Notice or in order to comply with the law. 

Sharing your personal data

Sometimes it is in everyone’s best interests for us to share some of the information we have about our customers with other organisations.  Sometimes this is because we have a legal obligation to do so and sometimes it is to ensure you get the best service possible, for example we will forward your details on to utility companies to ensure that you’re supplied with energy and water in your home.

If you decide to leave your property without paying or arranging to pay and you are in arrears we may decide it is necessary to share your details with a debt collection agency to help us recover our money.

We will also share some details with our contractors, so they can contact you if your property is in need of repair or scheduled for improvement work, to arrange a suitable time to visit.

In exceptional circumstances we may feel it is necessary to provide your details to the police or a local authority social services department where there has been a case of criminal activity, a breach of your tenancy agreement, we have been made aware of potentially anti-social behaviour or if we believe it your vital interests of you or those of someone who lives with you..

In the event you do leave us and move to a new landlord we might be contacted for a reference and may provide some of your details to them.

If we want to share data your data because we think it is in your interests but we do not have a legal basis for sharing we will always ask for your consent.

We’d like to stress that under no circumstances do Your Housing Group ever sell or pass on your information to business or organisations so they can get in touch with you directly either by phone, email or in writing in order to sell you their products or services.

Listed below are the categories of third parties we may share some of your personal information with. Where required we will ensure that any information sharing is supported by GDPR compliant contracts or there are appropriate Information Sharing Protocols in place.

• Advocacy partner organisations
• Banks and Financial Service providers to process secure payments;
• Charities & Voluntary Organisations
• Choice Based Letting Partners
• Contractors and suppliers who:

o    Provide services to you, or who provide services on our behalf;
o    Enable Your Housing Group meet their compliance responsibilities e.g.  Gas Servicing, Fire Safety, Asbestos Management;
o    Undertake repairs or improvements to your property & neighbourhood;
o    Provide Technology & Telephony software, services & equipment;
o    Manage out-of-hours service calls;
o    Provide printing and mailing services

• Credit Reference Agencies for rental tenants
• Debt Collection Agencies
• External Auditors
• Insurance companies
• Mediation partner organisations
• Organisations that support Your Housing Group, and the services we provide including

o    Local Authorities
o    Other housing providers
o    Statutory agencies
o    Support organisations

• Probation Services
• Professional Advisors & Consultants
• Solicitors
• Social Welfare organisations
• Survey & Research organisations
• Training providers or learning institutions
• Utility companies

In some cases we may also have a duty to disclose your information by law to:

• Central Government Departments
• Courts & Tribunals
• Fire services
• Health authorities, trusts or medical staff
• Local Authorities
• Organisations who support crime prevention or detection, the prevention and detection of fraud, and for the purposes of the National Fraud Initiative)
• Other Registered Providers of Social Housing
• Partner organisations whose purposes are compatible with ours
• Members of Parliament or Local Councillors
• Police
• Regulators

Your Housing Group will not share or disclose your information with anyone who claims to represent you or be acting on your behalf unless we have verified you have appointed them or they are acting in some recognised official capacity.

Updates to our Privacy Notice

We may make changes to our Privacy Notice from time to time, including as part of GDPR, which will start to apply on 25 May 2018. We will update the Privacy Notice and we will publish on our website any new version of this Notice

Freedom of Information

All public bodies are subject to the Freedom of Information Act. This means you’re entitled to request certain details from them.

Your Housing Group isn’t a public body for the purposes of this Act, so we’re exempt from the requirements, but regardless we’ll still consider particular information requests and help you if we can

Contact information

Any questions or requests regarding this Privacy Notice should be addressed to Your Housing Group’s Data Protection Officer at dataprotection@yourhousinggroup.co.uk