Privacy Notice for Residents, Supported Residents and Service Users
Last updated 6 September 2018
Personal data we collect
- If you are a resident, a supported resident or a service user we may collect the following personal data about you:
- Name, date of birth and contact details for you and members of your household.
- Tenant reference information, including details of previous tenancies, references from former landlords, your employment history and information about your financial status and credit checks.
- Details of CCJs, bankruptcy, court orders or criminal convictions where they are relevant to your tenancy or tenancy application.
- Your bank details and, if appropriate, details of cards you use to make any payments to us.
- Details of any deposit, fees, rental charges and payments made.
- Information about benefits you receive, where applicable.
- Information relating to your immigration status, if applicable.
- Information about your health and medical conditions and the heath and medical needs of members of your household, including the name and contact details for your doctor and support worker.
- Names and contact details for next of kin.
- Records of maintenance of the property and its fixtures and fittings
- Energy meter reading details at the start and end of the tenancy.
- Your forwarding address at the end of the tenancy.
- Details of any complaints made by anyone in relation to your tenancy.
- Information required for equality and diversity monitoring.
- Any other personal data you give us.
We collect personal data when you give it to us (usually through forms you fill out and send back to us) and from information we learn about you through our relationship with our residents, supported housing residents and service users. Our employees and sub-contractors (such as our property maintenance providers) may also create personal data about you, such as file notes and reports.
We also collect personal data about you from third parties, including the following:
- Former landlords and tenancy and credit checking agencies (such as Experian) for information about your rental history, credit checks, your financial history and employment status.
- Local authority and central government departments for information on your benefits.
- Local authorities, heath and social care providers, and previous care providers for information about your health, care and support needs, and those of your household (including children).
- Home office and local authorities for information on your immigration status, where relevant.
- Police and other agencies for information on criminal convictions and court orders, where it is relevant to your tenancy or application.
- Third parties, such as neighbours or other residents if they make a complaint about your tenancy.
- If you live with or are related to a resident, a supported resident or a service user we may collect your name, email address, postal address and telephone number. If you live with a resident or supported resident, we may also collect information about your health and medical needs. We collect this information when you provide it to us or from the resident, supported resident or service user.
How we use your personal data
Your personal data is used to manage your tenancy, to provide care and support to you and members of your household, to process payments, maintain the property meet and our obligations as a landlord. This includes:
- Monitoring compliance with the terms of your tenancy or service agreement.
- Providing support or any special need that you or a member of your household has.
- Sharing your personal data where it is lawful for us to do so.
- Conducting surveys to monitor and improve our services.
- Carrying out repairs and maintenance.
- Managing and responding to complaints and anti-social behaviour.
- Providing employee training.
- Monitoring equality and diversity.
- Sending you customer satisfaction surveys.
- Providing you with information about opportunities to participate in meetings, training and events.
- Contacting you with our latest news, and details of our services and offers and for other marketing purposes.
Basis for using your data
We primarily use your data because it is necessary for the tenancy agreement or other agreement we have entered in to with you. In some cases, we use your data because it is in our legitimate interests as a landlord and for the purposes of our business or because it is in the legitimate interests of a third party (such as a utilities provider to whom you are liable to make payments).
If we collect information about your health or medical needs (as we do with supported residents, for example) we do so because it is in our legitimate interests to use this personal data to provide you with the necessary care and support or because it is necessary for the performance of a task carried out in the public interest or in the exercise of official authority. We only process health and medical information for purpose of providing you with health and social care.
When we collect personal data relating to your racial or ethnic origin for the purpose of monitoring equality and diversity, we do so on the grounds of substantial public interest, specifically for the purpose of keeping under review equality of opportunity or treatment.
We send you marketing news and marketing communications because it is in our legitimate interests to send you marketing and promotional materials from time to time or because you have given us your consent to do so. You can tell us to stop sending you marketing information at any time by objecting or by withdrawing your consent. You can do so by contacting us, using the details below.
Preventing and detecting fraud
We also use your personal data to prevent and detect fraud and to investigate fraud that we reasonably think might have been committed. This involves comparing your information with information held by third parties, such as the Land Registry, banks, schools and utility companies, solely for the purpose to preventing and detecting fraud. We use your personal data for this purpose because it is in our legitimate interests to ensure individuals do not defraud us. It is also in the legitimate interests of our customers and the public in general to ensure that fraud is detected and prevented.
Sharing your data
Care and support agencies
If we provide you with support and care, we share your personal data with third party agencies involved in caring for and supporting you, including health professionals, health and care service providers, care commissioning bodies, local authorities, government departments and governing bodies.
Other third parties
Your personal data may also be shared with third parties to whom you will be liable as a tenant in one of our properties (such as including utility providers), with local councils, government departments and governing bodies, the Regulator of Social Housing, the ‘Homeswapper’ service provider and your MP, local councillors, or other elective representatives or officials acting on your behalf. We will also share your data if it is necessary for the purposes of preventing or detecting fraud.
Our data processors
We share your personal data with third parties who provide you or us with services, including:
- Our out of hours call centre service.
- Health and safety compliance providers.
- Property maintenance sub-contractors.
- Other contractors working for Origin Housing.
- Our tenancy reference and credit checking agencies.
- Our IT and cloud software and service providers.
All third-party service providers to Origin Housing (our data processors) with whom we share your personal data are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may also share your personal data with our professional advisers, including our lawyers and auditors where it is strictly necessary or to comply with applicable laws or with valid legal processes, such as in response to a court order.
Location of your personal data
We do not transfer your personal data out of the UK, but our IT and cloud service providers may transfer the personal data we store on their systems outside the European Union, to data centres located in other countries, such as the USA. Where this happens, we will ensure that appropriate safeguards are in place that ensure your personal data is protected to the standard expected in the European Union. These safeguards typically include standard contractual clauses approved by the European Commission for international transfers or (in the case of processors located in the USA) participation in the EU-US Privacy Shield Framework.
How long we keep your data
We only retain your personal data 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. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Our Data Retention Policy sets out the retention periods for the different types of information we collect and hold. Please contact us is you would like to know the retention period applicable to your personal data.
How we protect your personal data
We have implemented appropriate technical and organisational measures to prevent the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data.
We apply information governance and security best practice. We have implemented appropriate policies and procedures and provide all employees with information security and data protection awareness training. We restrict access to personal data to only those employees who need to know it for the purposes of their role. We have implemented technical security controls and have back-up and disaster recovery systems in place.
Data subject rights
You have the following rights in respect of your personal data:
- You have the right of access to your personal data (commonly known as a “subject access request”) and can request copies of it and information about our processing of it.
- If the personal data we hold about you in incorrect or incomplete, you can ask us to rectify or add to it.
Where we are using your personal data with your consent, you can withdraw your consent at any time. 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.
Where we are using your personal because it is in our legitimate interests (or those of a third party) to do so, you can object to us using it this way.
You can ask us to restrict the use of your personal data if:
- It is not accurate;
- It has been used unlawfully but you do not want us to delete it;
- We do not need it any-more, but you want us to keep it for use in legal claims; or
- if you have already asked us to stop using your data but you are waiting to receive confirmation from us as to whether we can comply with your request.
- In some circumstances you can compel us to erase your personal data or request a machine-readable copy of your personal data to be transferred to another service provider.
How to exercise your rights
If you wish to exercise your rights, please contact us using the information provided below.
You will not have to pay a fee to access your personal data (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.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Lodging a complaint with the ICO
You can also lodge a complaint with the Information Commissioner’s Office. They can be contacted using the information provided at: https://ico.org.uk/concerns/.
Your duty to update us
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 working/volunteering relationship with us.
If you have any questions, or wish to exercise any of your rights, then you can:
Call us on 0300 323 0325
Email us at email@example.com
Use the enquiry form on our Contact Us page of our website
Write to us at:
St Richards House
110 Eversholt St
You can also contact our data protection officer by emailing firstname.lastname@example.org.
Origin Housing reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. When changes are made, we will update the ‘Last Updated’ date at the top of this page. We may also notify you in other ways from time to time about the processing of your personal information.