Our privacy notice

Introduction

  • This privacy notice explains what we do with your personal data that we collect from you, from your household, from people or organisations if you’ve given them permission to share it with us, from available public sources, from third parties when it relates to the management of your tenancy and when you use our website, and it explains the reasons why we use it.
  • When we collect your personal data, we make sure we protect it. When we say ‘personal data,’ we mean any information that can be used to identify you either directly or indirectly, especially when it is paired with other information that can be used to identify you.
  • We’re committed to keeping your personal data secure and only ask for it or collect where we have a good reason to do so, which we explain below.
  • Origin Housing Limited and Origin Housing 2 Limited are registered as data controllers with the Information Commissioner’s Office having registration numbers Z6107036 and ZA003434.
  • Under the General Data Protection Regulation (GDPR) and the Data Protection Act (DPA) UK we have a legal duty to protect any information we collect from you or have about you from other sources.
  • When handling your information, we must follow the DPA’s rules and guidelines, referred to as Data Protection Principles.

 

What personal data we collect

  • To deliver services and carry out our other duties as a business, we collect and process personal information from the groups of people listed below, including your name, address, bank details, phone number, email address, doctor’s name and address, support workers details, equality and diversity monitoring information, next of kin and employment history.
 
Residents, service users and leaseholders and occupants of our homes
  • During your tenancy we will collect and process information about you and members of your household.

 

Contractors, suppliers, partners or agents
  • We collect information from you relating to your staff, including names, phone number, email and qualification information.

 

Board members and panel members
  • Throughout your appointment as a Board and/or a panel member we will collect and process personal data about you, including your name, email, phone number and address.

 

Staff, contractors, temporary workers, bank workers, agency workers and volunteers
  • We collect personal and sensitive personal data relating to our workforce, meaning all our staff, contractors, temporary workers, bank workers, agency workers and volunteers. Personal data we collect includes your name, email, phone number, address, information about your health, equality and diversity information, employment history and any police or criminal records.

 

Residents living in our supported housing
  • During your residency in our supported housing we will collect and process information about you, your family members or next of kin. This includes the name, phone number, email and address of you and your family members or next of kin, information about your health.

 

Website visitors
  • We ask for and collect different types of your personal information depending on the web form that you are filling in. The personal data we will collect includes: your name, address, email, phone number, age and employer, through online forms on our website.
  • We collect information about your visit to our website including your IP address and how you use our website through the use of cookie technology.

 

How your personal data is collected

  • This privacy notice includes information on personal data collected on our website and does not cover the links within this site to other websites. If you click a link and it takes you to another website you should read and understand the privacy notice of that website as it will differ to ours.
  • We collect your personal data if you complete one of our forms or enter into a contract with us. This includes if you live with someone who is one of tenants or leaseholders. 
  • We also collect information from trusted third parties where is it relevant to our relationship with you. This includes staff and customer survey providers or organisations that carry out maintenance and repair services on our behalf, as well as:
    • Local councils and central government departments such as the Department of Work and Pensions – for information about your benefits
    • Local authorities, health and social care professionals, previous care providers – for information about your health, care and support needs, and those of your household (including your children)
    • Previous landlords and credit agencies such as Experian – for your rental history, credit checks and information about your financial status/history
    • Home Office, local authorities – for information about your immigration status, where relevant
    • Police and other public authority fraud departments, local authorities – for information on criminal activity, but only where it is relevant to your tenancy or application
    • Other residents – we may receive information in relation to complaints
 
Website visitors
  • We collect your personal data through online forms, web analytics services and the use of cookies. We use consent as our legal basis for processing cookie data. You can read more about our use of cookies here.
  • Google Analytics is a web analytics service, that Google provides, which uses cookies to help us analyse how visitors use our website. The cookie collects information about how you’re using our website, including your IP address, which is sent to Google who will store it on their server. The information we collect from Google Analytics helps us to improve our website. You can find more information about Google Analytics’ privacy policy here.
  • We use Kentico, a content management system, to create our website and it has a built-in Online Marketing service too. As well as using cookies, if you submit forms or comment on any posts, Kentico collect the information you type so that we can use it to help respond to your enquiry. You can read their privacy policy here.
  • We use Hotjar which is an analysis and feedback tool that shows us how our users behave on and experience our website, which means we can make the experience better. Hotjar will never sell your information to anyone. Hotjar blank out phone numbers and email addresses that appear on our site, so that they never store this information on their server, which makes your information anonymous. You can read their privacy policy here. They use tracking cookies and collect information including your IP address and how you use our website.
  • We put YouTube videos on our website. If you watch any, YouTube process information about your activity, including cookie data, the video you watched, about your device, your IP address and location. You can view Google’s privacy policy here, which covers YouTube.
  • If you choose to register for and use ‘My account’, Orchard’s software used for this self-service portal relies on the use of session cookies.
  • If you apply for a job through our website, you’ll share personal data with CIPHR whose recruitment platform, iRecruit, we use. You can read CIPHR’s privacy notice here.
  • As well as the online forms on our website, we sometimes use Typeform forms. Typeform have access to your responses in their forms, and data about your use of their services. You can view their privacy policy here.
  • We use an online scheduling tool called Setmore for our employment support appointments, which collects your contact information. You can view their privacy policy here.
  • We use a venue booking tool called Skedda for hiring out our community halls, which collects your contact, payment, technical, usage and location information as well as third-party login identifiers such as Facebook, Google or Twitter if you choose not to use a password-based login. You can view their privacy policy for venue users here.

 

How we use your personal information

  • We only ask for and use your personal information for reasons that support us to run as a business.

 

Residents, service users and leaseholders and occupants of our homes and supported housing residents
  • Our legal basis to process your personal data is is to comply with our obligations under the contract we have with you.
  • We process your data for the following purposes:
    • To manage your tenancy and our property it relates to;
    • To monitor compliance with the terms of your tenancy or service agreement;
    • To deliver support for special needs to you or any member of your household;
    • To share information with other agencies where we have your agreement;
    • To conduct transactional surveys in order to monitor and improve our services, for example repairs and maintenance, complaints, lettings, anti-social behaviour issues and training;
    • To monitor Equality and Diversity (the information provided is anonymised and used only for statistical monitoring purposes which help us make improvements);
    • To provide information about additional services we offer, including opportunities to participate in meetings, training and events;
    • To comply with our safeguarding duties.

 

Contractors, suppliers, partners or agents
  • Our legal basis to process your personal data is to comply with our obligations under the contract we have with you.
  • The purpose of processing your data is to enable you to provide services to us or to our residents.
 
Board members and panel members
  • Our legal basis to process your personal data is our legitimate interest.
  • We process your data for the following purposes:
    • To contact you in relation to your role as a Board or panel member;
    • To monitor compliance with the terms of your Agreement for Services, Terms of Appointment;
    • To deliver tailored training and support;
    • To monitor Equality and Diversity (the information provided is anonymised and used only for statistical monitoring purposes which help us make improvements).
 
Staff, contractors, temporary workers, bank workers, agency workers and volunteers
  • Our legal basis to process your personal data is to comply with our obligations under the contract we have with you.
  • We process your data for the following purposes:
    • Recruitment and appointment purposes
    • Administration purposes (e.g. to operate payroll, pensions etc.)
    • Conduct performance reviews, manage performance and determine performance requirements
    • To offer any necessary support requirements in your role
    • Compliance with legal or industry standards (e.g. to prove eligibility to work in the UK and meeting our Health and Safety requirements)
    • To conduct transactional surveys to monitor and improve our services, for example following training courses
    • To monitor Equality and Diversity (the information provided is anonymised and used only for statistical monitoring purposes which help us make improvements)

 

Website visitors
  • Our legal basis to process your personal data through our forms on our website is our legitimate interest. Below is a complete list of our legitimate interests.
    • Responding to support enquiries
    • Answering queries submitted through our ‘Contact Us’ form
    • Receiving job applications
    • Supporting you through financial help: money and benefits
    • Answering enquiries about adapting your home
    • Getting involved with our community: Origin Hive; Origin spotlight; volunteering; about crowdfunding
    • Helping to book our community halls
    • Providing information about keeping a pet
    • Allocating parking spaces
    • Providing information on swapping or moving to smaller home
    • Passing your tenancy on
    • If you’re interested in renting one of our properties
    • If you’re interested in Right to Buy or Right to Acquire
    • Arranging a Handy Heroes appointment
    • Responding to enquiries from potential suppliers
    • Providing information on planned maintenance in your area
    • Responding to an issue you’ve contacted us about
    • Enabling you to log in to and use ‘My Account’
  • When you submit an online form on our website, the information is sent via email to our relevant employees to allow us to carry out customer service and won’t be used for marketing purposes. Each form describes the purpose for which we will process your personal information.
  • We process the personal information that you provide to us on our website for the following purposes:
    • To update your details where appropriate;
    • For monitoring purposes to ensure equality of access;
    • For tailoring purposes to improve services for all our customers;
    • To contact you about your enquiry or to visit you at your property;
    • When you book appointments;
    • When you apply for jobs;
    • Site safe information from session cookies and log files;
    • Surveys and polls about the website;
    • For direct marketing purposes, to keep you up to date with our latest news, services or offers. You can choose to opt out of receiving any direct marketing by contacting us. See below.
  • This privacy notice includes information on personal data collected on our website and does not cover the links within this site to other websites. If you click a link and it takes you to another website you should read and understand the privacy notice of that website as it will differ to ours.

 

Who we share your personal information with

  • There are times when we need to share your personal information with third parties.
  • We will also share your personal details, if required to do so, by law or any government body.
  • For residents and service users, we share your data with external companies to allow us to carry out our obligations as a landlord or as an employer.
  • Third parties include:
    • Contractors;
    • Out of hours call centre service;
    • Health and safety and compliance checks (e.g. gas servicing, lifts, asbestos, legionella);
    • Electricity, water and gas companies;
    • Homeswapper;
    • Local councils, government departments and governing bodies;
    • Credit check authorities;
    • MPs and Councillors acting on your behalf;
    • Health and care services;
    • Social housing regulator;
    • External survey companies.

 

Personal information collected on our website
  • We use external companies to deliver certain areas of our business, including web services and to fulfil our obligations as a landlord, including fire safety, gas and electrical safety checks, repairs and planned maintenance to your home or block. 
  • To achieve our stated purpose we will need to transfer personal data to third parties. The third parties we share personal data obtained on the website with are:
    • Web analytics and tools;
    • Online appointment booking system;
    • Maintenance contractors;
    • Out of hours call centre service.
  • We’ll only share the minimum information necessary for the contractor to carry out their services on our behalf. We’ll never sell personal information to a third party.
  • When using our website, including when cookies are enabled, the below organisations will be a recipient of your data:
    • Our employees;
    • Google Analytics;
    • Kentico Online Marketing Solution;
    • Hotjar;
    • YouTube;
    • Typeform;
    • Setmore;
    • Skedda;
    • iRecruit;
    • Orchard.

 

How we safeguard your personal information

  • We take appropriate measures to prevent the loss, misuse or alteration of your personal information.
  • We have some paper files that are stored securely in our offices in line with our data retention policy.
  • We store the personal information on our secure servers, which have access control. We use a firewall, have an in-house data centre and our website is secured by encryption.
  • The third parties we share your personal data with comply with current EU legislation and you can visit their websites to find out about their privacy policies.
  • We have a number of IT systems that host the personal data that you provide us outside of the EU. Some of these systems are owned by American companies who participate in the EU-US Privacy Shield programme. For IT service companies who are based outside the EU and are not on the Privacy Shield programme we use standard contractual clauses as the safeguard for the personal data we share. Finally, in some rare circumstances we have to use the performance of our contract to you as the safeguard for your data.

 

How long we keep your personal information for

  • We have a data retention policy which sets out how long we keep different types of information for.
  • We follow legal requirements and best practice. Please contact us if you’d like to understand how long we retain your data for.
  • We are happy to erase your data in line with your right to erasure if the correct conditions are met.

 

Fraud detection

  • We use data shared with us for the purpose of preventing and detecting fraud. 
  • Any personal data shared with us can be used for the purpose of preventing and detecting fraud. This includes information provided on our website, on the My Account area, or in any other way provided to us online or not.
  • The data collected can be used for the purpose of data matching and for further investigations. This involves comparing the data we hold on you with that held by third parties solely for the purpose of detecting and preventing fraud. We also use your data to further investigate fraud that we think might have been committed. 
  • This involves checking with various third parties, such as the Land Registry, banks, schools and utility companies. 

 

Your Rights

  • These are your rights as an individual whose personal data we process, if you’d like to speak with us about this, please fill out the form on the Contact Us page.
    • right to be informed: in this privacy notice we let you know how we use your personal data through our website.
    • right of access: if you want to find out more about the personal information we have about you, you can make a subject access request.
    • right to rectification: you can let us know that we’ve got incorrect or incomplete information about you, so that we update it and we’ll let you know we’ve done so.
    • right to be forgotten: you can ask us to get rid of personal information we have about you unless we have reasonable grounds to refuse to get rid of it. If you’d like to find out what these grounds are, please use the contact form.
    • right to restrict processing: if you ask us to stop processing your data, we’ll only keep the amount of personal data about you that we need to make sure no more processing happens.
    • right to data portability: in some cases you can ask for a copy of your personal data and for it to be sent to another data controller.
    • right to object: unless we have good enough legitimate grounds for processing your data, you can object to us processing it.
    • rights with respect to automated decision-making and profiling: automated decisions and automated processing of personal data to evaluate certain things about you
    • right to report a concern: you can report a concern to the Information Commissioner’s Office here.

 

How we use cookies on our website and how you can opt-out

  • When we provide services, we want to make them easy, useful and reliable. Where services are delivered on the internet, this sometimes involves placing small amounts of information on your device, for example, your computer or mobile phone. These include small files known as cookies, which nearly all websites use. They cannot be used to identify you personally and don’t harm your system. We use them to ensure a good experience when using our website.
  • Our website’s content management system, Kentico, uses cookies. Some cookies are essential which means you will not be able to access all of our website properly if you opt-out of all cookies.
  • Google Analytics uses cookies to help us analyse how visitors use our website. The cookie collects information about how you’re using our website, including your IP address, which is sent to Google who will store it on their servers. If you’d like to opt out of making information about your visit to our website available to Google Analytics, you can install the Google Analytics Opt-out Browser Add-on here.
  • Kentico has a built-in Online Marketing service called Kentico Online Marketing Solution which uses cookies to collect information about your visit and to help them analyse traffic patterns on our website. They also use Google Analytics, so if you want to opt-out to them using cookies, click on the link above.
  • Hotjar stores information about your visit to our website in a user profile that won’t be used to identify you. For more details, please see Hotjar’s privacy policy here. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your use of our website and Hotjar’s use of tracking cookies on other websites by following this opt-out link.
  • We put YouTube videos on our website. If you watch any, YouTube process information about your activity, including cookie data, the video you watched, about your device, your IP address and location. You can view Google’s privacy policy here, which covers YouTube.
  • If you choose to use ‘My account’, you will have to have cookies enabled in your browser, because it cannot work without the use of session cookies.
  • You can also visit www.aboutcookies.org to find out more information on cookies on a wide variety of browsers.
  • You have the right at any time to ‘opt out’ of us using your personal information for direct marketing purposes. If you wish to do this please contact us.

 

What you can do if you’ve got a complaint

  • If you feel we haven’t handled your personal data properly, you can log a complaint with us by using our contact form here, sending an email to complaints@originhousing.org.uk or by calling 0300 323 0325.
  • You can also contact the Information Commissioner’s Office for advice on your rights.

 

Contact us

  • Origin Housing is the data controller for all personal data captured and processed on originhousing.org.uk. You can contact us about data protection on 0300 323 0325, email enquiries@originhousing.org.uk or fill in the enquiry form on the Contact us page. You can also write to us at:

Origin Housing

St Richards House

110 Eversholt St

London

NW1 1BS

 

We are currently in the process of working towards compliance with General Data Protection Regulation which comes into force on the 25 May 2018.

In order to facilitate this we have engaged the professional consultancy services of Cybercrowd Limited

Our path to compliance will be aligned with ICO’s guidance “12 steps to take now” with an additional focus on security and controller/processor agreements that are not covered within the aforementioned ICO guidance.

It is our intention that we will meet the criteria for compliance as soon as practically possible following the advice and information that we are supplied.