We are guardians of our customer and employee information and we take the privacy and the security of it very seriously. This notice sets out our approach to safeguarding the privacy of the personal information we hold.
Housing Plus group is responsible for collecting, processing and storing your information as well as keeping it secure. We manage personal information in accordance with the General Data Protection Regulation (EU) (2016/679) and the Data Protection Act 2018 (together the ‘Data Protection Legislation’). We are registered as data controllers with the Information Commissioner’s Office (ICO), registration number Z1210914.
Who are we?
Housing Plus group is a housing provider registered with Homes England, reference L4491 and is a Community Benefit Society, reference 30224R.
Housing Plus group consists of (each of which is referred below as a ‘member’ of the Housing Plus group):
- Homes Plus which is a housing provider registered with the Regulator of Social Housing (reference LH4121) and a Charitable Community Benefit Society (reference 28312R).
- Homes Plus Housing; a housing provider registered with Regulator of Social Housing (reference LH4325) and a Charitable Community Benefit Society (reference 8084)
- Stafford & Rural Homes (Homes Plus) which is a housing provider registered with the Regulator of Social Housing (reference L4458) and a Charitable Community Benefit Society (reference 7852).
- Care Plus Staffordshire Limited (Care Plus); a provider of care and support services for older people and those with disabilities or health conditions. Housing Plus group is registered with the Care Quality Commission (CQC) in relation to the care and support services provided by Care Plus, Care Plus is a Charitable Community Benefit Society, reference 30948R.
- Property Plus; a specialist service delivering repairs and maintenance across the Housing Plus group including maintaining communal areas and undertaking disabled adaptations.
- Housing Worx; a specialist service delivering planned maintenance work to Homes Plus properties;
- Severn Homes is a commercial landlord specialising in private sector housing for rent, sale and shared ownership.
More information on the Housing Plus group and its member organisations is available at www.housingplusgroup.co.uk
This notice applies to all personal information collected by Housing Plus group and our members listed above. Housing Plus group and its members each have separate registration with the ICO.
Where do we operate?
The Housing Plus group and its members operate in Staffordshire, Shropshire, Telford and Wrekin and Dudley.
During the course of their work, all members of Housing Plus group collect personal and sensitive personal data from individuals. We are committed to being open, transparent, clear and fair with individuals regarding the information we collect. Protecting your information and complying with the Data Protection Legislation is taken very seriously.
Personal data is any information which relates to an identified or identifiable individual, examples include, but are not limited to, name, address, National Insurance number, date of birth, contact details (such as a telephone number or email address), photographs or CCTV images.
Sensitive personal data (also known as special category data) is information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.
Criminal offense data refers to a wide range of information about criminal activity, allegations, investigations and proceedings. It includes not just data which is about a specific criminal conviction or trial, but also any other personal data relating to criminal convictions and offences, including unproven allegations, information relating to the absence of convictions and personal data of victims and witnesses of crime.
This privacy notice sets out what data we collect and why. It covers:
- How we collect, store and use the information that you and/or any third parties provide to us including:
- why we use the information;
- when we will pass information to third parties;
- what we expect of organisations we pass information to.
- How we comply with the requirements of the Data Protection Legislation.
- How we comply with the rights you have, including letting you know what information we have about you, how you can access this and make other requests such as correcting any inaccurate data.
- How we can be contacted for more information and how you can make a complaint.
What does it cover?
We collect personal and sensitive personal data from you in a range of ways and at a number of different times. This can be:
- When you apply for a rented property with any members of the Housing Plus group. Information will be collected on application forms and in supporting documentation which can include identification documents such as passports or identity cards.
- As part of the application process for purchasing a shared ownership or outright sale property for example, financial information and supporting documentation.
- During the course of any tenancy or licence that you are granted. Contact details, information relating to welfare benefits, your income and savings will be collected as well as any information gathered as part of any investigations into nuisance or anti-social behaviour.
- When you reply to surveys or requests from us for information for example, satisfaction surveys, questionnaires, feedback forms, contact preferences and other profiling data.
- When you participate in any competitions and provide contact details and other information as part of this.
- When you request a repair or report other issues such as nuisance or anti-social behaviour.
- At the end of a tenancy, for example, you may leave us with a forwarding address.
- As part of the development process for example, sharing resident names and addresses with contractors or consultants to facilitate consultation meetings, deal with boundary enquiries and defects work etc.
- As part of the planning and delivery of any care (including residential care and/or nursing care) and support service to you for example, GP name and address, past and current medical history, DNAR status, power of attorney/court of protection, financial details (social service contracts, CCG and complex care assessments, agreements and contracts), health support needs, medical and next of kin details.
- We may record telephone calls made to the Housing Plus group and/or its members for training and security reasons but we will tell you if we are going to do this.
- We may capture images on CCTV in the public areas of our offices, car parks, estates, schemes and residential care homes.
- We may ask you to provide your name and contact information, and record the date and time of your visit to some of our sites (for example, our Digital Dens), in order to comply with the NHS ‘Test and Trace’ scheme. If during your visit you only interact with one member of staff, we will also record the name of the staff member that you saw.
We collect criminal offense data in a limited number of circumstances in accordance with the requirements of the Data Protection Act 2018 and associated conditions required to process criminal offense data. For example:
- We may collect criminal offense data in application forms where there is a specific need to understand your circumstances.
- We may collect criminal offense data if you choose to disclose this information to us. For example, during an interaction with customer services or in a text field on a form.
The website and most of the services provided through the website can be accessed without you having to tell us who you are or providing any personally identifiable information. Any information entered into a form on the website or emailed to us may contain personal information which will be transmitted securely and treated in accordance with this notice and the Data Protection Legislation.
What do we use your information for?
We collect and process personal and sensitive personal data to allow us to:
- Develop, allocate and manage homes for rent and sale.
- Deliver and improve services including housing management, repairs and property improvements and care (including residential and nursing care) and support.
- Monitor performance of the Housing Plus group and its members.
- Keep and administer internal records.
- Undertake market research and profiling for example, building up a picture of an area by gathering specific information on people who live there.
- Send information to you electronically and in writing for example, customer newsletters and formal legal notices.
- Contact you by post, telephone, text, email or social media.
- Customise communications with you. This can be via the website or in the form of written letters which meet individual contact or communication needs.
- Identify residents in our care homes.
- Meet the health and care needs of residents in our care homes.
- Arrange payment for care of residents in our care homes.
- Comply with statutory reporting obligations.
We are required to deliver services to you which are set out either in legislation or a contract, this could be a tenancy agreement, licence or lease, residential care and/or nursing contract, or other such agreement which we have entered into with you. Based on this, once you supply your details you do so in the understanding that we have a legitimate purpose to use this information.
Profiling and segmentation
We may use personal and sensitive personal data for customer profiling and segmentation work to help us improve services and deliver them in a more targeted way, for example we may use someone’s credit history to help manage arrears or offer money advice.
- Segmentation is using information to divide customers into groups of individuals that are similar in specific ways, such as age, gender, interests and spending habits.
- Profiling is using information to describe a customer or set of customers that includes demographic, geographic and other characteristics, as well as payment patterns, creditworthiness and purchase history.
We may use personal and sensitive personal data for large scale analysis. This information may or may not be made anonymous for this analysis. For example, we may calculate the average rent arrears in one area by using data from all tenants in that area.
Markers and flags
We may apply markers or flags to your information (for example, in relation to your vulnerability or health status) to enable us to tailor and deliver services to you.
We may also use a marking system and apply relevant flags where a member of staff has a concern about someone’s safety, health or behaviour. When applying these warning flags we will take into account regulatory advice and our own internal procedures regarding risk assessment, informing the individual concerned and reviewing any such situations.
How does the Housing Plus group protect data?
The Housing Plus group takes the security of your personal and sensitive personal data very seriously. We have appropriate technical and organisational measures in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed and is not accessed except by employees, agents, or other parties working on behalf of the Housing Plus group that need access to, and use of, personal and sensitive personal data in order to carry out their assigned duties. Access to data is protected by unique profiles for data use depending upon the need of the individual and is secure through password entry. The password entry systems are compliant with the Housing Plus group’s security processes.
Where the Housing Plus group engages third parties to process personal data on our behalf, the companies do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data. Such third parties will also be required to enter into an appropriate data sharing agreement with the Housing Plus group and comply with the Data Protection Legislation.
Who can we pass your information to?
From time to time we may share personal and sensitive personal data with other organisations. Any data sharing will always be subject to appropriate safeguards and contractual arrangements being in place between us and the other organisations. We may share information with members of Housing Plus group to enable effective delivery of services, to deal with queries or to answer customer questions. For example, a complaint from a Care Plus customer may need investigation by Care Plus because they are a service provider and Homes Plus because they are the landlord and this will involve sharing data. Personal and sensitive personal data will also be shared with contractors who undertake work for the Housing Plus group, for example, gas contractors and those involved in delivering property improvements or healthcare providers attending a residential care home.
We share information where there is a lawful basis to do so. Lawful basis is one or more of the following:
- Where we have to meet contractual obligations (this is usually to meet the requirements of any tenancy, lease, residential care and/or nursing contract or other legal agreement you have with us).
- Where there is a legal requirement to do so.
- When it protects your vital interests.
- When it is to carry out or perform a task in the public interest or to exercise official authority.
- When it is in our legitimate interests, which are not overridden because the processing prejudices your interests or fundamental freedoms.
- Where we have your consent to do so.
If we need to obtain your consent to process or share personal and sensitive personal data we will do so in a number of different ways. This is usually via a signed agreement which sets out the details of the consent (for example, a housing application form, tenancy agreement or residential care and/or nursing contract).
Wherever possible we will inform you when we intend to share your information. We will only share your information in compliance with this privacy notice and the Data Protection Legislation.
If you provide us with an email address, we will contact you using this unless you tell us otherwise. You can change your contact preferences at any time by using the unsubscribe option on emails or by contacting us.
Requests to withdraw consent to share information
You have the right to request that we do not share your details or that your details are only used for certain purposes. This may affect the level of service you receive and/or mean that you cannot access some services.
Sharing information without consent
There are some occasions when we do not need your consent to share your personal and sensitive personal data with other organisations because there are other ‘lawful basis’ for processing/sharing your personal and sensitive personal data. We may pass on personal and sensitive personal data to other organisations such as Government Departments, local authorities, the courts or the emergency services, particularly the police. We do this when it is requested or we have a legal requirement to do so. In such circumstances, we ensure compliance with the Data Protection Legislation.
Some examples of this are:
- To prevent or detect crime or fraud including assisting with a criminal investigation or a court case
- As part of a safeguarding issue involving a child or a vulnerable adult
- To help assess and administer welfare benefits including Universal Credit
- As part of a report of, or investigation into, benefit fraud
- In response to an emergency situation when required by the emergency services or local authority
- If requested to do so by NHS Test and Trace
To the extent we have a lawful basis to do so, we may pass your personal data to other organisations to enable them to deliver services for us, usually to meet the requirements of any tenancy, lease or other legal agreement you have with us. Personal data may include name, address, telephone number, email address and any known specific communication or access needs. Some examples of this are where we:
- Provide contact details to contractors, surveyors, maintenance providers, or tradespeople engaged by the Housing Plus group (or its members) so that they can contact you to visit your property to carry out repairs, maintenance or improvement works, safety checks and any audit or property survey work.
- Provide forwarding addresses and/or other contact information and confirmation of tenancy start and end dates to utility companies, other service providers and/or their agents (such as debt collection agencies) who approach us about debt(s) you have accrued with them during your tenancy with us.
- Provide contact details and other relevant information (such as specific communication needs and any no lone working or other similar information) to organisations which provide out of hours call handling and emergency response services for us.
- Ask a research company to undertake a survey for us.
- Pass your contact details to a mailing house or similar distribution organisation to send out information, such as newsletters or mailshots, on our behalf.
- Discuss and share information regarding individual property sales with relevant organisations such as Government departments (for Right to Buy, Right to Acquire and any other statutory schemes), financial advisors or other agents.
- Provide details to healthcare providers to support and meet your healthcare needs.
We may enter into an individual or multi-agency partnership with other organisations such as other housing providers, local authorities and the police. An example of this is a partnership with the Police and local authority to help prevent anti-social behaviour in an area where we operate.
We are clear with all organisations we share data with that they must comply with Data Protection Legislation with regard to the personal and sensitive personal data we have provided to them. This includes how they will process, store and share such personal and sensitive personal data.
We expect that all organisations we share personal and sensitive personal data with will agree either:
- A contract, service level or other binding agreement which includes data protection clause(s) which comply with the Data Protection Legislation; or,
- A specific data sharing agreement which complies with the Data Protection Legislation; or,
- Compliance with the Housing Plus group’s data sharing standards.
Data Protection Legislation includes specific requirements to ensure the safety and security of data transferred outside of the European Economic Area (EEA). The Housing Plus group does not transfer or process any personal and sensitive personal data outside of the EEA.
Your personal data may be used by Housing Plus group for direct marketing purposes to keep you updated with our latest services and offers if you have given us your consent for this. For example, if you have indicated you are interested in shared ownership on your housing application form, we will send you details of properties as they become available.
We will not sell, distribute or lease your personal or sensitive personal data to third parties unless we have your permission to do so.
How we keep your information secure
We store personal and sensitive personal data both electronically and in paper form. We use a range of controls to keep the information you provide to us, and information we collect from you and/or third parties, secure from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. These include security policies, processes and technical physical security solutions.
Information kept on computer is protected by system security such as passwords, firewalls, virus protection software and encryption. Systems are backed up daily with copies of the backed up data kept securely off-site.
Information kept in a paper format is placed in secure storage such as lockable filing cabinets.
When you contact us
When you call our customer service team we will ask you security questions to clarify your identity before disclosing any account-related information. We do this to protect you and to make sure that other people cannot obtain information about you that they are not entitled to know.
Save for circumstances where someone holds a power of attorney or other legal right to act on your behalf, if you would like another person to talk to us about your account, you will need to give them your permission to do so and make us aware of this, otherwise, we cannot discuss your personal situation or disclose information about you. You can explain this arrangement verbally every time you call us if the other person is with you or put it in writing so we do not have to ask every time the other person contacts us on your behalf.
Staff training and support
Staff receive data protection awareness training as part of their induction and undertake scheduled refreshers. Staff also have access to various good practice guides and other advice and materials to help them keep your information secure. There are regular data protection compliance checks and audits undertaken by the Housing Plus group staff in addition to formal internal audits.
How we keep your information up-to-date and what happens when we no longer need it
We may check what information we hold about you when you contact us. We also ask you to keep us up-to-date with any changes to your information and to complete regular audits to help us with this.
We want to make sure that the personal and sensitive personal data we hold about you is accurate and up-to-date. You can ask us to correct or remove information that you think is not accurate, or complete any incomplete information.
We only keep your information for as long as we need it. This may be a minimum time set in legislation or specific regulatory guidance and we have detailed information on this based on advice issued by the National Housing Federation (NHF) or other relevant body such as Care England. At the end of the relevant retention period, we will erase or otherwise dispose of your personal and sensitive personal data securely.
You have a number of rights under the Data Protection Legislation. These are:
- The right to withdraw consent to processing of your personal and sensitive personal data at any time.
- The right to be informed about what data is collected and how it is used. This notice helps comply with this right.
- The right to request access to your personal and sensitive personal data held by us.
- The right to have any mistakes or inaccuracies in your personal and sensitive personal data put right.
- The right to request the deletion or removal of personal and sensitive personal data if it is no longer necessary for which it was collected or processed (subject to any reasonable grounds we may have to refuse to delete/erase personal and sensitive personal data, i.e. retention of data for audit purposes).
- The right to restrict the processing of personal and sensitive personal data.
- The right to portability, which ensures data is provided in a readily useable format.
- The right to object to processing personal and sensitive personal data based on legitimate interests.
- The right to be informed about and object to data being used for some automated decision making, such as profiling.
Requesting a copy of your information
You have a right to request a copy of information held about you. This is called a subject access request.
You will need to put your request in writing and provide proof of your identity. Once these are received, we will respond within one (1) calendar month.
There are some reasons why we may withhold information from you, for example, if it contains the personal details of another person or is part of an ongoing investigation. If we do withhold any information we will tell you why this is.
We reserve the right to refuse subject access requests where these are repeated requests, where information has already been provided or the request is manifestly unfounded or excessive. If we consider this the case, we will tell you why this is.
If you wish to request information about any of your rights, please contact us.
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The websites of Housing Plus group and its members contain links to other sites. The Housing Plus group privacy notice only applies to our websites and when you access others you should check their own privacy notices.
Where can I get more information?
Housing Plus group has a range of policies covering data protection and information security. These policies are available on request. Please contact email@example.com or call 0800 048 8955.
For more information on the Data Protection Legislation and requirements, you can also contact the Information Commissioners Office (ICO) at www.ico.org.uk or by calling 0303 123 1113. The ICO has registration details of Housing Plus group and each of its members which set out what personal and sensitive personal data they collect and why.
How can I make a complaint?
If you feel we have not complied with this privacy notice or other Housing Plus group policies or you are unhappy with the service provided to you, you can make a complaint using the Housing Plus group’s complaints procedure. Please contact firstname.lastname@example.org or call 0800 048 8955.
You can also make a complaint to the Information Commissioners Office (ICO) via their website at www.ico.org.uk/concerns or by calling 0303 123 1113.
How to contact us
Please do not hesitate to contact us if you have any questions about this privacy notice, the information we hold about you, our overall approach to data protection across and within the Housing Plus group, confidentiality or to make a subject access request.
You can contact us in the following ways:
- 0800 048 8955, please ask for the Data Protection Officer
- Write to Data Protection Officer, Housing Plus group, Acton Court, Acton Gate, Stafford, ST18 9AP
Please use the contact details above for data protection queries or questions about the Housing Plus group and its members.