1. Aim of policy
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).
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 payment details, before it’s safely destroyed.
2. Who is responsible for your data?
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 GDPR and UK Data Protection Act (2018).
3. What personal data do we collect about you?
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.
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 Bank details
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 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
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 for legislative purposes, or you have deliberately made it public.
If you do not allow us to process any sensitive personal data, this may mean we are unable to provide all or parts of the services you have requested from us.
4. How and why we use your personal data
We use your personal data for the following purposes:
1. When you first make an application to us for housing, and to administer housing waiting lists.
2. Information required 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
• Voice and image recordings for safety, crime prevention and quality management
3. To help you buy part or the whole of your home, including:
• Affordability checks
• Credit rating data
4. To provide security
• We operate CCTV systems, which collects and records images, and is used in accordance with CCTV codes of practice.
5. When you ask for additional services, advice and support
• 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 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 ask about your employment and learning history;
• We may hold information about your history, for example, regarding credit status or offences, if we need it to look after our staff, business or anyone else
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 get the information, or related information, from you or our partner organisations, your family, friends or neighbours, our staff or public information sources including credit reference agencies or the criminal records bureau;
• We may also record factual information whenever you contact us or use our services, so we have a record of what happened.
7. To communicate with you and manage our relationship with you
• We may need to contact you by telephone, email and/or SMS for administrative,operational, or tenancy related issues e.g. in order to send you confirmation of your property repair bookings, gas servicing and your payments;
• These communications are not made for marketing purposes and as such, you will continue to receive them even if you opt-out from receiving marketing communications;
• 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.
8. 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 use your personal data to evaluate your preferences, such as how we contact you. 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;
• 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.
9. 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, if you are happy to receive marketing communications, we may send you communications promoting our partners’ products and services;
• Please note that we do not share your contact details and other personal data with other companies for marketing purposes, unless we have obtained your explicit consent to do so;
• 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 communications at 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 (Tel. 0300 555 0600) or send an email to Data.Protection@onward.co.uk with the subject title “Unsubscribe”.
10. To fulfill 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.
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).
5. Your Privacy Rights
The introduction of GDPR provides all UK citizens new and enhanced privacy rights, which Onward Homes are committed to upholding and takes its responsibilities regarding our customers privacy rights very seriously.
These include your rights to request that Onward Homes:
• Responds to your Subject Access Requests and confirm what personal data we hold about you, if any, and for what purposes;
• Changes the consent which you have provided in relation to your sensitive personal data, 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 sensitive 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, although there may be reasons why we may be unable to fulfil your request;
• Responds to your objections about any automated decisions made about you using the personal data you’ve provided.
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
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.
6. Security of your personal data
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.
As detailed in this Policy, 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. Sharing your personal data
Sometimes it’s 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’s 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.
If you decide to leave your property without paying or arranging to pay and you are in arrears we may decide it’s 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’s necessary to provide your details to the Police or the Local Authority Social Services Department where there has been a case of criminal activity, a breach of your tenancy agreement or we have been made aware of potentially Anti-Social Behaviour.
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.
Regardless of the circumstances, if we find ourselves in a situation where we need to share your information with another organisation and you haven’t already given your consent for us to do this, then we will ask for it before releasing any information about you.
We’d like to stress that under no circumstances do we 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 Onward Homes 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
• Debt Collection Agencies
• External Auditors
• Insurance companies
• Mediation partner organisations
• Organisations that support Onward Homes and the services we provide including
o Local Authorities
o Other housing providers
o Statutory agencies
o Support organisations
• Probation Services
• Professional Advisors & Consultants
• 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
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. Contact information
Linked documents: Data Protection policy
Date implemented: August 2019
Policy lead: Andy Paton Data Protection Specialist, Business Assurance
Approved by: Executive Management Team
Approved on: 20 August 2019
Next review date: May 2021
Reference number: PRIV01
Document replaces: Version 1