How we use your personal information
This privacy notice tells you what to expect when Clarion Housing Group (CHG) processes personal information. It applies to information about applicants, residents and other service users.
Why do we collect and store personal information?
CHG needs to collect, process and store personal information about you and other household members (as applicable)*, in order to operate as a registered provider of affordable housing and deliver efficient and effective services. * When you provide information about household members we assume that you do so with their full knowledge and consent.
Information we may hold about you and how we use thisThe information we hold on our records concerns our relationship with you. For example:
- We hold names & dates of birth, photographic ID and information about your previous housing circumstances to assess housing applications and help prevent tenancy fraud and illegal subletting.
- We hold contact details for you so we can communicate with you, and to keep you informed about other services we offer which may be useful to you*.
- We record information about your needs and requirements to ensure our services are accessible; that we take account of any support needs in our dealings with you; and to improve our communications with you. For example, if you are involved with a carer or social worker; if you need adaptations in your home; if you need large print or translated text.
- We record information to assist us in delivering housing management services including reports of antisocial behaviour; complaints; change in circumstances e.g. if you have a medical need which means you need to move.
- We keep financial records about the amount of money you have paid us; any amount(s) outstanding and associated recovery action. Depending on your chosen method of payment, we may hold your bank account details.
- We may hold information about you if you are engaged with our additional guidance and support services. For example in connection with access to training and employment we may hold information about your job history and skills and experience, or if we support you to improve your financial circumstances, we may hold information about your household income and expenditure.
- We may hold recordings of your telephone calls to us, as some calls to our contact centre are recorded for training and monitoring purposes so we can ensure we’re delivering a good service**
- We may capture your image on our CCTV systems if you visit an estate, office or community facility which is covered by this facility**
- We may carry out market research and customer satisfaction surveys to help us to monitor our performance and to improve our services to our customers.
* We would like to provide you with information about other products and services (of ours and other reputable companies we work with) which do not form part of our core landlord services but which we think may be of interest to you. This would include information such as accessing training and employment, financial guidance and digital support. You can let us know at any time how you prefer to be contacted or if you do not want us to contact you with this information. We never provide your personal information to other companies for their marketing purposes.
** Call recordings and CCTV recordings will be held in accordance with our corporate retention policy before being erased. This list is not exhaustive, as we hold records of most contacts we have with you, or about you, and we process this information so we can deliver services to you.
Generally the information we hold will have been provided by you (on application or enquiry forms or when we communicate with you), but we may also hold information provided by third parties where this is relevant to your housing circumstances e.g. from social workers and health professionals (e.g. doctors and occupational therapists).
We will only ask for personal information that is appropriate to enable us to deliver our services. In some cases, you can refuse to provide your details if you deem a request to be inappropriate. However, you should note that this may impact our ability to provide some services to you if you refuse to provide information that stops us from doing so.
How we manage your personal informationProcessing of your personal information will be undertaken in accordance with the principles of the Data Protection Act 1998. Access to personal information is restricted to authorised individuals on a strictly need to know basis. We will treat your personal information fairly and lawfully and we will ensure that information is:
- Processed for limited purposes;
- Kept up-to-date, accurate, relevant and not excessive;
- Not kept longer than is necessary;
- Kept secure.
We are committed to keeping your personal details up to date, and we encourage you to inform us about any changes needed to ensure your details are accurate. To help us to ensure confidentiality of your personal information we will ask you 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. Anyone calling on your behalf may also be subject to security questions to ensure we’re taking adequate steps to protect your personal information.
We may apply markers to your information (for example, in relation to your vulnerability or health status) to enable us to tailor and deliver services to you. CHG 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.
Sharing your personal informationNormally, only CHG staff will be able to see and process your personal information. However, there may be times when we will share relevant information with third parties for the purposes as outlined in section two, or where we are legally required to do so. When sharing personal information, we will comply with all aspects of the Data Protection Act.
Sensitive information about health, sexual life, race, religion and criminal activity for example is subject to particularly stringent security and confidentiality measures.
Where necessary or required, we may share your personal information as follows:
- With our contractors, in order to undertake repairs, maintenance or improvement worksWith third party service providers, in connection with services performed on our behalf. For example if we use a research company to carry out a resident satisfaction survey or if we use a mailing house to distribute our newsletters.
- Our relationships with such providers are governed by our contracts with them which include strict data sharing and confidentiality protocols.
- With other housing associations, trusts and landlords, in connection with tenancy references and associated enquiries.
- With community partners in connection with the delivery of co-ordinated local services.
- With utility companies (and their representatives) and Council Tax Offices, to ensure billing details are correct.
- With credit reference agencies and debt collection agencies, in connection with some housing applications and in relation to any outstanding charges.
- With local authorities and government departments, as necessary for administering justice, or for exercising statutory, governmental, or other public functions.
- With police and other relevant authorities (e.g. Probation Service, Department of Work & Pensions, HM Revenues & Customs) in relation to the prevention or detection of crime and fraud; the apprehension or prosecution of offenders and the assessment or collection of tax or duty.
- With other statutory organisations, e.g. social services & health authorities, as necessary for exercising statutory functions
- With our regulator, the Homes & Communities Agency (HCA), to comply with our regulatory obligations.
- With other companies in the Clarion Housing Group (as may be necessary): Affinity Sutton Homes, Community Building Services Ltd, Affinity Sutton Repairs Ltd, Grange Management (Southern) Ltd
- This list is not exhaustive as there are other circumstances where we may also be required to share information, for example:
- To meet our legal obligations
- In connection with legal proceedings (or where we are instructed to do so by Court order)
- To protect the vital interests of an individual (in a life or death situation)
- National Fraud Initiative (NFI)
The Clarion Housing Group is required by law to protect the public funds administers. CHG may share information with other bodies responsible for auditing or administering public funds, in order to prevent and detect fraud.
Clarion Housing Group intends to participate in the 2016 National Fraud Initiative (NFI) data matching exercise carried out by the Cabinet Office. Our participation in the NFI will assist in the prevention and detection of fraud against Clarion Housing Group and organisations within the public sector. We will participate on a voluntary basis and provide the Cabinet Office with particular sets of data in the autumn for matching as set out in the Cabinet Office’s guidance.
The Cabinet Office conducts data matching exercises to assist in the prevention and detection of fraud.
Data matching involves comparing sets of data, such as the tenancy, payroll or benefits records of a body, against other records held by the same or another body to see how far they match. The data is usually personal information. The data matching allows potentially fraudulent sub letting, benefit claims and payments to be identified. Where a match is found it may indicate that there is an inconsistency that requires further investigation. No assumption can be made as to whether there is fraud, error or other explanation until an investigation is carried out.
The processing of data by the Cabinet Office in a data matching exercise is carried out with statutory authority under its powers in Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under the Data Protection Act 1998.
Data matching by the Cabinet Office is subject to a Code of Practice.
6. Access to Your Personal Information
Under the Data Protection Act, 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 identify.
If you are seeking to obtain specific information (e.g. about a particular matter of 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).
In accordance with the Data Protection Act, we charge a £10 processing fee for responding to SARs. This can be paid by cheque or postal order payable to ‘Affinity Sutton Homes’.
We have 40 calendar days 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, details of contractor visits, or general property maintenance information as this is unlikely to be ‘personal information’.
If you need us to correct any mistakes contained in the information we hold about you, you can do so by contacting the Company Secretariat (see section 7).
7. Changes to this privacy notice
We keep our privacy notice under regular review and we will place any updates on our website. Whilst we recommend that you keep up to date via the website, any major changes will be brought to your attention.
This privacy notice was last updated August 2016.
8. Further Information
For further information on how to request your personal information and how and why we process your information, you can contact us using the details below
157-159 Masons Hill
0300 100 0303 / firstname.lastname@example.org
(If you have a general customer service query e.g. related to a repair or your account, please email email@example.com or use the contact us section of the website)
The Information Commissioner (ICO) is also a source of further information about your data protection rights. The ICO is an independent official body, and one of their primary functions is to administer the provisions of the Data Protection Act 1998.
Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF 0303 123 1113 / http://www.ico.org.uk/