Clarion Housing Group need to process personal data about you in order to provide services to you as applicable:
- To log your interest in sales of properties and manage our website
- To facilitate the sales process
- To deliver on our Group Ambition to transform lives and communities.
This privacy notice explains how we will process your personal information in relation to property sales. This is the main privacy notice for property sales. If you go on to receive any other services from the Clarion Housing Group, you will be referred to the relevant Clarion Housing Group Privacy Notices which can be found on the Clarion Housing Group website.
We keep our privacy notice under regular review and we will place any updates on our websites. If you would like to receive a hard copy of our current privacy notice, please let us know.
For more information, please contact our Data Protection Officer at Level 6, 6 More London Place, Tooley Street, London SE1 2DA or by emailing firstname.lastname@example.org
For independent advice about data protection, privacy, e-privacy and data sharing issues, you can contact the Information Commissioner. (Lots of useful information is accessible on their website):
Phone: 0303 123 1113
We’ll only collect personal information when we need this and we’ll make it clear when you do not have to provide us with information and any consequences of not providing this.
Most information we hold will be collected from you but where necessary we may also obtain this from third parties such as property portals like Zoopla and Rightmove, our appointed selling agents, financial advisers, mortgage advisors, solicitors or legal representatives, or Help to Buy agents.
We collect information from you (as applicable):
- To manage our records of people interested in a development
- We will need details of what locations and type of properties you are interested in and up to date contact details (including telephone numbers, email addresses and details of anyone you may choose to represent you) so we can reach you when we need to discuss details pertaining to your potential purchase. We will also use your contact information to tell you about changes to Clarion, for example our organisational structure and governance arrangements, and to resolve or investigate complaints.
This information is processed at your request. If you would like us to remove you form our records, or would like to change your communication preferences, please just let us know.
- To manage your reservation or sales process:
- We will hold financial records about any deposits taken. Depending on your method of payment, we may hold your bank account details.
- We will need details of your solicitor and other relevant information to proceed with the sales process such as proof of your identity (passport/driving licence). This will be fully explained to you at the time.
- We will hold records of all our contact with you, your contact with us, and any contact from third parties representing you or about you. This may include call recordings.
- We will hold details relating to any works to be carried out to the property during any applicable defects period (although this information will not necessarily constitute your personal data).
Provision of the information is a ‘Contractual Requirement’. Without this information, we may be unable to manage your services. For example, we cannot proceed with a sale if we do not hold your contact details. Please speak to us with any concerns.
- To prevent fraud
- we will collect enough information to verify your identity.
Processing for the purpose of fraud prevention is required in order to meet our legal obligations. Therefore if we are unable to verify your identity we may not be able to provide services to you.
- To assist with personal security and prevention and detection of crime
- we may capture your image on our CCTV systems if you visit a sales office or show cabin.
Processing of this information may be required to meet Clarions’s legal obligations and our legitimate business interests around health and safety and crime prevention.
- To understand how we’re performing we may use your contact details to:
- carry out market research and customer satisfaction surveys to help us to monitor our performance and to improve our services to our customers.
- to segment customers to help target our resources and prioritise services.
- in managing and analysing complaints.
- for statistical analysis.
It is in our legitimate interests to understand how we are performing so we can meet our mission statement and objectives.
There may also be a legal obligation for us to process the information or to demonstrate to our regulator that we are fulfilling our obligations, for example around anti-discrimination laws.
- We also use your personal information in the following ways:
- Keeping in touch with you, understanding your needs, and inviting you to events.
It is in our legitimate interests to communicate with you and keep you up to date with news and events in order to meet our objectives
- Prevention and detection of crime, and quality management.
We do this to meet our legal obligations.
- Meeting our legal obligations including the requirements of our funders or regulators.
This is a legal obligation on Clarion.
As well as personal information (such as your name, address and date of birth) we may collect sensitive personal information (also known as special categories of data) which may include:
- Racial or Ethnic origin
- Religious or Philosophical Beliefs
- Sexual Orientation
- Health information
We use this data to ensure services are delivered appropriately and to monitor Equality, Diversity and Inclusion.
We will apply additional security and confidentiality measures when processing your sensitive personal information.
Where provision of special categories of data is optional, we will make this clear at the point of collection and will ask for your specific informed consent to process this data. Where you provide consent for us to process data, you have the right to withdraw this consent at any time.
There may be times where we will not need your consent to process (including sharing) this type of data. This will apply where we are permitted or required to do so by law, for example under Health and Safety Legislation or where processing of this data is necessary in order for us to carry out our obligations under Social Protection Law. This will apply where we cannot provide services to you without doing this. If you do not wish for us to process this data, you will be unable to continue to receive services from Clarion.
We may also process confidential data about you including bank account information and property access codes.
We will apply appropriate technical and organisational measures to ensure your personal information is secure. For example, we have systems in place to ensure that access to personal information is restricted to authorised individuals on a strictly need-to-know basis.
When we need to share personal data with our contractors and third party suppliers, our relationships are governed by our contracts with them which include strict data sharing and confidentiality protocols.
To help us ensure confidentiality of your personal information we may ask you (and any of your representatives) security questions to confirm your identity when you call us and as may be necessary when we call you. We will not discuss your personal information with anyone other than you, unless you have given us prior written authorisation to do so or where we have received a clear verbal instruction from you (as a one-off circumstance).
Sometimes we need to share personal information we hold about you with other organisations that we work with or who provide services on our behalf. When sharing information we will comply with data protection legislation.
Where the information is of a sensitive nature, for example about your health, we will generally obtain consent from you prior to sharing this information, unless we are required or permitted to share this by law.
Where ‘sharing’ is in our ‘legitimate business interests’, we may share your information without seeking your consent first. This may be with:
- Our agents who advertise our developments or properties on our behalf.
- Other organisations in the Clarion Housing Group that provide services. For example, the contractor who manage the defects period.
- Local authority teams such as environmental health
- Utility companies (and their representatives) and Council Tax Departments to ensure billing details are correct.
- Third parties providing services on our behalf. For example a mailing company distributing our newsletter or a research company carrying out a customer satisfaction survey.
- Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative. More information can be found on the work undertaken by the Cabinet Office at: https://www.gov.uk/government/collections/national-fraud-initiative
- Police and other relevant authorities (e.g. Department of Work & Pensions, Probation Service, HM Revenue and Customs) in relation to the prevention and detection of crime, the apprehension of offenders or the collection of tax or duty.
- Other statutory organisations e.g. social services and health authorities as necessary for exercising statutory functions.
We may also share information when required by law for example where ordered by the Court or to protect an individual from immediate harm.
We will routinely use your contact details to send you information and communicate with you about the sales process and developments and areas you have expressed an interest in or that you may be eligible for via email, phone, text and post. You can update your contact preferences at any time on the website or ask us to stop sending you these types of messages. Please note: If you opt of marketing messages, we will still send you service messages, which sometimes may contain a paragraph on marketing.
Once you have reserved a property, we will use the contact details you have provided to help guide you through the sales process.
We will never sell your personal data to 3rd party organisations for marketing purposes.
Clarion only holds records during the period of our relationship and for a set period afterwards to allow us to meet our legal obligations including resolving any follow up issues between us.
Generally we will remove all personal information from your account 6 months after your account remains untouched unless you have asked us to delete your information prior to this date. If you go on to purchase a property we will retain relevant information and you will be re-issued with a new Clarion Housing Group Privacy Notice which will explain how we will process and store your information.
Clarion is committed to upholding your rights in respect of your personal data.
The right to be informed
Through the provision of our suite of privacy notices, we will be open and transparent about how and why we use your personal information.
The right of access
You have a right to ask us what personal information we hold about you and to request a copy of your information. This is known as a ‘subject access request’ (SAR).
SARs need to be made in writing (we have a subject access form you can use for this purpose), and we ask that your written request is accompanied by proof of your address and identify.
If you are seeking to obtain specific information (e.g. about a particular matter or from a particular time period), it helps if you clarify the details of what you would like to receive in your written request.
If someone is requesting information on your behalf they will need written confirmation from you to evidence your consent for us to release this and proof of ID (both yours and theirs).
We have one calendar month within which to provide you with the information you’ve asked for (although we will try to provide this to you as promptly as possible). In response to SARs, we will provide you with a copy of the information we hold that relates to you. This will not generally include information about your property such as repair logs or details of contractor visits as this is unlikely to constitute your ‘personal information’. Please be clear if you are seeking property or repairs related information as a SAR is unlikely to fulfil your information requirements.
The right to rectification
You can ask us to rectify your personal data if it is inaccurate or incomplete. Please help us to keep our records accurate by keeping us informed if your details change.
The right to erasure
The right to erasure is also known as ‘the right to be forgotten’. In some circumstances, you can ask us to delete or remove personal data where there is no compelling reason for its continued processing. This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data. Our response will also be guided by the provisions of our retention schedule.
The right to restrict processing
In some circumstances you can ask us to restrict processing, for example
- if you disagree with the accuracy of personal data
- if we’re processing your data on the grounds of legitimate interests (as detailed earlier), and whilst we consider whether our legitimate grounds override those of yours.
The right to data portability
If the situation arises where it would be helpful for you to move, copy or transfer personal data we hold about you, across different services, you may be able to ask us to do this. Please contact us to discuss.
The right to object
You can tell us if you object to our processing of your personal data:
- based on legitimate interests
- for the purpose of direct marketing (including profiling);
Rights in relation to automated decision making including profiling.
We do not currently undertake automated decision making or profiling which has a legal or significant effect on you. We will advise you if this position changes.
If you’d like to talk to us about your rights, you can contact us at email@example.com. Alternatively, if you want to raise a complaint about our processing of your data or would like to seek an independent view, you can contact the Information Commissioner using the contact details provided at the start of this notice.