Privacy notice

1.1. 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.

1.2. 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.

1.3. 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.

1.4. 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 UK General Data Protection Regulation (GDPR).

1.5. We will keep your personal data 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 payment details, before it’s safely destroyed.

2.1. Our Privacy Notice applies to all the personal data that Onward Homes collects and uses.

2.2. References in this Privacy Notice to “Onward Homes”, “we”, “us” or “our” mean Onward Homes Limited (a registered society under the Co-operative and Community Benefit Societies Act 2014 (31216R), regulated by the Homes &Communities Agency (No. (4649).

2.3. We control the ways your personal data are collected and the purposes for which your personal data are used by Onward Homes and are the “Data Controller” for the purposes of the UK GDPR and the Data Protection Act (2018).

3.1. When using the term “personal data” in our 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.

3.2. Your personal data may include, for example, your name, your 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.

3.3. We collect 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 contractors/suppliers who provide services to you on our behalf and our partners Agencies.

3.4. The majority of the personal data we collect and use is on the basis of managing your tenancy contract, in the legitimate interests of you or the business, or with your consent.

3.5. We will collect and process the following categories of information about you:

3.5.1. Your name and contact details for use across the organisation and by our contractors/suppliers;

3.5.2. We may also collect and process detailed personal data, such as:

• Bank details
• Benefits
• Caring responsibilities
• Name and contact details of individuals who you want us to communicate with on your behalf
• Date of birth
• Education details
• Employment details
• Family details
• Financial information (such as income, expenditure details)
• Lifestyle & social circumstances
• National identifiers (such as National Insurance Number)
• Nationality
• Reference information
• Relationship status
• Safety & security details
• Visual images, personal appearance and behaviour
• Your particular needs and preferences, and how you use our services so that we can understand them better
• Your right to live in the UK

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

4.2. Such information is included within the “Special Categories of Personal Data” under the UK GDPR. We only collect this information where you have given your explicit consent, it is required in relation to legal matters, it is necessary for legislative purposes, to protect the vital interests (i.e. health and safety) of you or another person or you have deliberately made it public.

4.3. If you do not provide or allow us to process special category personal data, this may mean we are unable to provide all or parts of the services you have requested from us.

5.1. We use your personal data for the following purposes:

5.1.1. Assessing your application to us for housing, checking your right to rent and to administer housing waiting lists

5.1.2. Entering into and managing our tenancy contract with you , and contacting you about your housing needs including:

• Your support needs, so we know how we can assist you before and during your tenancy;
• The repair and maintenance of your property;
• Records of payments for the services provided to you;
• Feedback from our contractors/suppliers, about their appointments with you;
• Details about complaints about our service or other individuals, accidents or incidents involving you or your home;
• We may also record factual information whenever you contact us or use our services, so we have a record of what happened.

Without this we cannot progress or manage your application or tenancy.

5.1.3. To help you buy part or the whole of your home, including:

• Undertaking affordability checks;
• Assessing credit rating data.

5.1.4. To provide security and ensure health and safety:

• We operate CCTV systems, which collect and record images, and are used in accordance with relevant government guidance;
• We may hold information about your history, for example, related to offences, to look after our staff, business or anyone else.

5.1.5. To provide additional services, advice and support, including:

• Sharing your name and contact details to allow support services to contact you (the person may be a member of our staff or from another organisation that we will tell you about);
• Care and support requirements, this may also require us holding detailed information about you and your family’s needs;
• Financial problem assistance (we will hold detailed information about your income and financial situation);
• Training or other learning opportunities (we will ask about your employment and learning history).

5.1.6. When we process information about you on behalf of another organisation you receive services from:

• We will receive the information we need to provide a service to you;
• We may receive information, or related information, from our partner organisations, your family, friends or neighbours, or public information sources including credit reference agencies or the criminal records bureau.

5.1.7. To communicate with you and manage our relationship with you, such as:

• We (including our contractors/suppliers) 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;
• To seek your feedback to improve our services and the customer experience.

5.1.8. To personalise and improve your customer service experience:

• We may use your personal data to evaluate your preferences and our performance. Some of these contacts may be automated, however we will ensure that any such processing of this kind does not have any legal or similarly significant effect on you;
• 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;
• Voice recordings for quality management;
• With your written consent, your name, photo, video or story could be used for brochures, advertising, press releases or internal news stories.

5.1.9. To inform you about our news and service that may be of assistance:

• Where you have positively opted in to receiving any marketing communications the details will be explained to you at the time;
• You can choose to opt out from receiving marketing communications at any time, by clicking on the relevant unsubscribe link at the bottom of any marketing related contact 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 (Tel. 0300 555 0600) or send an email to protection@onward.co.uk with the subject title “Unsubscribe” and details of the marketing received.

5.1.10. To fulfil our administrative purposes and support 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.

5.1.11. To comply with our legal obligations

For example, our obligation to provide your information to the Department for Work and Pensions (DWP) & HM Revenue and Customs (HMRC).

6.1. The UK GDPR provides all UK citizens with specific privacy rights. Onward Homes is committed to upholding these rights and takes its responsibilities regarding our customers privacy very seriously.

6.2. These include your rights to request that Onward Homes:

• Responds to your Subject Access Requests, providing copies of your personal data where required;
• Where we require consent, allow this to be withdrawn, however you should be aware that by withdrawing consent Onward Homes may no longer be able to provide you with services that relate to the information you are no longer consenting to us processing;
• Corrects any inaccurate or incomplete personal data which Onward Homes holds about you;
• Provides you with a copy of your personal data for you to move elsewhere;
• Stop processing your personal data, whilst an objection from you is being resolved;
• Permanently erase all your personal data promptly, and confirms this has been done;
• Responds to your objections about any automated decisions made about you using the personal data you’ve provided.

6.3. We will consider each and every request and respond within one month of receiving a valid request. If your request is particularly complex we may extend this, by exception, for up to a further 2 months.

6.4. If you have questions in relation to exercising any of your privacy rights, please contact Onward Homes Data Protection Officer in the first instance at data.protection@onward.co.uk

6.5. If, for any reason, Onward Homes does not address your request, or fails to provide you with a valid reason why it is unable to do so, you have the right to contact the Information Commissioner’s Office (ICO) to make a complaint. They can be contacted via their website www.ico.org.uk or by telephone 0303 123 1113.

7.1. Onward Homes 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.

7.2. As detailed in this Notice, we may in some instances disclose your personal data to third parties. Where Onward Homes 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.

7.3. 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 and in order to comply with appropriate laws and standards.

8.1. On occasions it’s in everyone’s best interests for us to share some of the information we have about our customers with other organisations. This may be to provide additional services, to fulfil a legal obligation or 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 and charges are directed correctly.

8.2. If you decide to leave your property without paying or arranging to pay any arrears you are in, we may decide it’s necessary to share your details with a Debt Collection Agency to help us recover these arrears.

8.3. We will also provide some details to our contractors/suppliers, 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.

8.4. In certain circumstances we may feel it’s necessary to provide your details to partner agencies (e.g. Police Local Authority) where there are concerns of criminal activity, an individuals health and safety or we have been made aware of potentially anti-social behaviour.

8.5. 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.

8.6. We’d like to stress that under no circumstances do we ever sell or pass on your information to businesses 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.

8.7. Listed below are the categories of third parties we may share some of your personal data with. We will ensure that any information sharing is undertaken in compliance with the UK GDPR.

• Advocacy partner organisations
• Banks and Financial Service providers to process secure payments
• Charities & Voluntary Organisations
• Choice Based Letting Partners
• Contractors and suppliers who provide services to you, or who provide services on our behalf
• Credit Reference Agencies for rental tenants, such as Experian as part of the Rental Exchange. You can read the Rental Exchange Privacy Notice below.
• Debt Collection Agencies
• External Auditors
• Insurance companies
• Mediation partner organisations
• Organisations that support Onward Homes and the services we provide, such as Local Authorities, other housing providers, statutory agencies, support organisations
• Probation Services
• Professional Advisors & Consultants
• Solicitors
• Social Welfare organisations
• Survey & Research organisations
• Training providers or learning institutions
• Utility companies

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

• Central Government Departments
• Courts & Tribunals
• Statutory agencies
• 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
• Regulators

8.9. Onward Homes 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.

9.1. We will endeavour to limit the occasions where your personal data is transferred outside of the UK/EEA.

9.2. Where your data is transferred outside of the UK/EEA, we will make sure that transfers are only made to countries in which the UK has made an ‘adequacy decision’, or where appropriate safeguards are in place e.g. contractual conditions.

9.3. We may share your personal data with third parties or companies that perform services on our behalf, all third parties operate in accordance with legally binding contracts.

10.1. We may make changes to our Privacy Notice from time to time. Any updates to the Privacy Notice will be published on our website where we will publish a new version of this Notice.

11.1. Any questions or requests regarding this Privacy Notice should be addressed to Onward Homes Data Protection Officer at data.protection@onward.co.uk

Onward has joined Experian Rental Exchange which means we will be able to work with you more closely to manage your existing tenancy agreement, your track record as a tenant will enable Experian to use the information supplied to them to assist other landlords and organisations to:

• assess and manage any new tenancy agreements you may enter into;
• assess your financial standing to provide you with suitable products and services;
• manage any accounts that you may already hold, for example reviewing suitable products or adjusting your product in light of your current circumstances;
• contact you in relation to any accounts you may have and recovering debts that you may owe;
• verifying your identity, age and address, to help other organisations make decisions about the services they offer;
• help to prevent crime, fraud and money laundering;
• screen marketing offers to make sure they are appropriate to your circumstances;
• for Experian to undertake statistical analysis, analytics and profiling,
• and for Experian to conduct system and product testing and database processing activities, such as data loading, data matching and data linkage.

If you would like to see more information on these, and to understand how the credit reference agencies each use and share rental data as bureau data (including the legitimate interests each pursues) this information is provided in this link: www.experian.co.uk/crain (Credit Reference Agency Information Notice (CRAIN)).

We will continue to exchange information about you with Experian while you have a tenancy with us. We will also inform Experian when your tenancy has ended and if you have outstanding rental arrears, Experian will record this outstanding debt. Experian will hold your rental data for the time limits explained in CRAIN (section 7). Rental data falls into the Identifiers (e.g. your name, address, date of birth) and financial account categories (i.e. tenancy account, rental payment information).

Onward and Experian will ensure that your information is treated in accordance with UK data protection law, so you can have peace of mind that it will be kept secure and confidential and your information will not be used for prospect marketing purposes.

If you would like advice on how to improve your credit history you can access independent and impartial advice from www.moneyadviceservice.org.uk (you can get a copy of your Statutory Credit Report by visiting www.experian.co.uk/consumer/statutory-report).

If you are unhappy with anything relating to Rental Exchange, please contact us on 0300 555 0600. You also have the ability to get in touch with the Information Commissioner’s Office. More information about this can be found using this link here: https://ico.org.uk/concerns/.