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Contents
Introduction
Who we are
The personal identifiable information we use
How we gather your personal identifiable information
Sharing your personal information with others
How we lawfully use your personal identifiable information
Why we use your personal information
- To assess your eligibility for services
- To manage our tenancies, leasehold agreements or care and support services
- To fulfil health & safety and crime prevention obligations
- To support our vulnerable people
- To share information with agencies, where it is believed you or other persons’ vital interests are at risk
- When you request extra support, guidance or advice
- To monitor our performance
- Keeping in touch with you, understanding your needs and inviting you to events or property viewings
- Meeting the requirements of our regulators;
Automated Decision Making
Transferring personal identifiable information outside of UK
How long we retain your personal information
Keeping your personal information secure
Your Privacy Rights
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure (to be forgotten)
- The right to restrict processing, and the right to object
- The right of data portability
- Your rights in respect of automated decision making and profiling
Introduction
Estuary Housing Association (Estuary, us, we) are committed to handling your personal information fairly, lawfully and securely in line with current data protection laws. We are required to collect and process personal data to deliver our services such as:
- Tenancy management & property maintenance services
- Delivering care and support services
- Providing, managing and developing social and affordable housing and homes for outright sale and shared ownership.
- Child Care services
We take your privacy seriously and this notice explains your privacy rights and how we collect, use, share and secure your personal identifiable information. It explains the types of personal identifiable data we will collect and hold about you. This information may be provided by you or a third party.
Our Privacy Notice is subject to regular review and will be updated as necessary and available on our website. If you would like to receive a printed copy of this notice, please contact our corporate services team on 0300 304 5000, alternatively you can request a copy by emailing info@estuary.co.uk
If you have questions relating to data protection and how we use your personal information you can contact our Data Protection Officer by email at dpo@estuary.co.uk or by writing to the Data Protection Officer, Estuary Housing Association Ltd, Centre Place, Prospect Close, Southend-on-Sea, Essex, SS1 2JD.
This privacy notice replaces any previous published.
Who we are
We were founded in the 1970s and registered with the Housing Corporation in 1984. It is a Registered Society under the Co-Operative and Community Benefit Society Act 2014, with charitable rules and status. As a registered social housing provider, we are regulated by the HCA’s regulation directorate, the Regulator of Social Housing (RSH).
We as a ‘data controller’ is responsible for determining the means of collection and use of this information. For some services we provide we are joint data controllers with our partners.
We is registered with the ICO under registration reference number Z5301256
The Personal Identifiable Information we use
We use a variety of personal identifiable information depending on the services we deliver to you. For most products and services we need to use some or all of the following personally identifiable information about you, occupants of your home, or our representatives:
- Contact details – name, address, email, home and mobile telephone numbers
- Age – Date of Birth
- Gender
- Identification documents, information to allow us to check your identity
- Financial information, credit history
- Photographs – for identification purposes
- On-line identifiers (IP address) information recorded when you engage with us electronically
- National Insurance Numbers, information required to carry out functions such as universal credit or supporting people/personal care services
- Next of kin and/or emergency contact details
- Marital status.
Special Category Information
- Health, to support our housing functions and vulnerable customers
- Ethnicity, to support our equality monitoring purposes as required by our regulator
- Race, optional and solely to support our equality monitoring purposes
- Religion, to support our equality monitoring purposes
- Sexual life or sexual orientation to support our equality monitoring purposes
- Convictions, to prevent and detect crime, fraud, anti-money laundering, and to aid in the prosecution and rehabilitation of offenders.
We may collect less information for the other occupants of your property unless they also have a direct relationship with us (obtain services from us directly).
Supplying us with your personally identifiable information may be essential to enter into a contract or agreement with you, or to meet some of our legal or regulatory duties, for example:
- Tenancy or leaseholder agreements
- Care and support services
- Processing benefits
- Equality monitoring and regulatory reports.
If you choose not to provide the personal information required we may not be able to provide some of our services to you.
How we gather your personal identifiable information
In most cases the personal information we hold about you is information you have provided to us or has been collected by us when we provide products and services to you.
We may also receive information about you from third parties, such as local authorities, your doctor or a previous landlord.
Examples of how we may collect your personal identifiable information include:-
- Directly from you, in person, by email, telephone, text, letter or form that you have completed to access our services or products
- By observing how you use our housing, support, products and services, for example from the transactions and operation of your accounts and online services
- From other organisations, such as former housing or support providers, health, social care, benefit and law enforcement agencies, energy or utility companies
- From other people that you are connected to; for example a joint tenant, a relative, a person nominated to act on your behalf, your legal representative, or people living in the same community (e.g. those making reports of anti-social behaviour)
- From monitoring or recording calls as part of quality and complaints monitoring. Calls are also recorded for training purposes and to ensure the safety of our staff. We will not record any payment card details as part of our payments operations.
- From the CCTV systems and Body Work Cameras used for the prevention and detection of crime, damage or vandalism to our properties and to ensure the safety and security of our staff and individuals obtaining services from us.
Sharing your personal information with others
We will share your personal information within our organisation and with others outside of Estuary Housing Association where we need to do that to make products and services available to you, meet or enforce a legal obligation or where it is fair and reasonable for us to do so.
Who we share your personal information with depends on the products and services we provide to you and the purposes for which we use your personal information.
We will only share your personal information where we have a legal obligation or legitimate interest to do so. This may be with:
- Our contractors in order that they may carry out repairs, maintenance and improvement works
- Debt and money management advisors
- Local authority teams such as social services, environmental health, council tax departments, benefit agencies and nomination teams
- Utility companies (and their representatives) to ensure billing details are correct
- Third parties providing services on our behalf. For example, a mailing company distributing our correspondence; a research company carrying out a customer satisfaction survey, or a debt collection agency pursuing former tenant arrears.
- Agencies committed to protecting public funds and/or preventing fraud
- Police and other relevant authorities (e.g. Department of Works and Pensions, 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
- Government Departments and Agencies for statistical and analysis purposes, such as the Ministry of Housing, Communities and Local Government (MHCLG), you can access their Privacy Statement here.
Where the information is classed as sensitive personal information i.e. 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.
We may also share information when required by law, for example when ordered by the Court or to protect an individual from immediate harm.
Estuary Housing Association will never sell or lease your personal data to third party organisations for marketing purposes.
How we lawfully use your personal identifiable information
We only use your personal information for the purposes permitted by the laws that protect your privacy rights.
We only use personal information where:
- We need to use the information to comply with our legal obligations
- We need to use the information to perform a contract with you
- We determine it is fair to use the personal information either in our interest or someone else’s interest, and doing so does not result in harm to you
- If you provide information to us on the basis of consent you have the right to subsequently withdraw your consent at any time.
Where we collect sensitive information, for example regarding your health, ethnic origin, political views we will only use this type of information where:
- We have a legal obligation to do so (e.g. to protect vulnerable people)
- It is necessary to protect your vital interests (e.g. a medical emergency)
- It is in the substantial public interest
- It is necessary for the prevention or detection of crime
- You have specifically given us consent to use the information.
Why we use your personal information
To provide you with our services we may collect and use your information as follows;
To assess service eligibility and enter in to tenancy agreements;
To complete our pre-tenancy assessments (e.g. affordability) and if we offer you a tenancy we will collect detailed personal information about you and other household members:-
- age, gender, date of birth
- ethnicity
- income (including benefits)
- employment status
- relationship status
- disabilities
- religion
- sexuality
- nationality
- caring responsibilities
- access to financial services and bank account details
- medical information
- unspent criminal convictions
We have a legal duty to confirm a person’s eligibility for housing and their right to reside in the United Kingdom. We may require details of your citizenship and copies of your identification documents (e.g. passport, driving licence) to meet this requirement.
To enable us to support our customers who have vulnerability and/or receive support or care services from us we may also require health and social care information, such as physical, social or mental health information or medication.
We will also collect information relating to other members of your family/household to ensure that the accommodation offered is adequate and appropriate for your needs.
To manage and administer our tenancies, leasehold agreements and care and support services;
We will use your personal identifiable information to meet our responsibilities set out in your tenancy agreement or contract as follows:
- Your contact details, to enable us to discuss services e.g. repairs, rent payments - please ensure you keep us updated when these change
- Supporting documentation regarding any change in your circumstances e.g. change of name, a birth, a medical need that means your housing requirements need to be re-assessed
- We will keep records of all our contact with you, your contact with us and any contact from third parties concerning you
- We will keep financial records, i.e. rent payments, benefit payments, bank account details. Where you are in receipt of certain benefits we will receive and share information with relevant agencies. Depending on how you make payments to us, we may share financial details with bureaus, such as allpay.
- We may also use your contact information to advise you of products or services which may help you sustain your tenancy.
To fulfil our health & safety and crime prevention obligations and to support our vulnerable people;
- We use your personal and sensitive identifiable data to meet our legal and regulatory obligations for health and safety and crime prevention
- This may include information about vulnerabilities or behaviour to ensure that services meet your needs or safeguard our staff or any third parties working on our behalf
- Indicators may be placed on your record and shared with contractors and sub-contractors to ensure health and safety measures are in place
- Your image may be captured on our CCTV systems which have been installed outside our offices and in some of our schemes. Signage at each location provides details of the purpose of the system.
To report or share information with agencies where it is believed that vital interests are at risk;
- We will share or use your personal and sensitive information if necessary to protect your vital interests (or others), which is a legal, moral and regulatory obligation
- We will do this where you or another person is at risk of physical or mental harm
- Where you or another person needs to be protected as a vulnerable person from significant harm or serious exploitation.
When you engage with our teams for support and guidance;
- We will use your personal identifiable information to ensure that we are providing the correct support and guidance based on your circumstances. It is in our legitimate interest to help our customers sustain their tenancies.
To monitor our performance and meet our regulatory obligations;
- It is in our legitimate interests to use your personal information for this purpose to enable us to monitor our performance, and that of our partners
- We will undertake customer satisfaction surveys for this purpose and to help us improve our services
- We undertake call recordings for training and quality monitoring purposes
- To enable us to perform statistical analysis to help us improve our services and to meet the requirements of our regulator.
Automated Decision Making
- Your personal identifiable information may be used in automated processes to help us to make decisions about you, for example determining your eligibility for a mutual exchange. We do this to help ensure decisions are made accurately, fairly and efficiently and to meet your needs.
Transferring personal identifiable information outside of the United Kingdom;
- All customer personal identifiable information will, wherever possible, remain within the United Kingdom or European Economic Area.
There may be occasions where we need to process your information outside of the European Economic Area (EEA). Where this is necessary, any personal identifiable information will be limited and appropriate measures will be taken to ensure that your information remains secure.
How long we retain your personal information:
- We will retain your personal information in accordance with our regulators requirements, guidance and best practice. If you would like further information on data retention please contact the Data Protection Officer, dpo@estuary.co.uk
Keeping your personal information secure
- We apply both technical and governance measures to ensure that your personal information is secure
- We apply strict controls with our third party suppliers regarding confidentiality, security and retention of personal data
- To help us ensure the confidentiality of your personal information we will ask you security questions when you contact us to confirm your identity. We will not discuss your personal information with anyone other than you without prior authorisation from you, unless we have a legal or regulatory requirement to do so.
Your privacy rights;
With effect from the 25th May 2018 data subjects have the following rights:
The right to be informed
- The lawful grounds for obtaining and processing your personal identifiable data
- How this data will be retained, secured and shared.
The right of access
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 of any changes. You can view and update your personal information on the resident portal ‘My Estuary’ If you have not registered and would like further information on this service please contact corporate services on 0300 304 5000 or by email to info@estuary.co.uk
The right to erasure (the right to be forgotten)
- In some circumstances you can request us to delete or remove your personal identifiable information where there is no legitimate reason for us to retain it. This is not an absolute right and will be considered in line with our legal and regulatory rights to retain and process this data.
The right to restrict processing and the right to object
- You can object and request us to restrict processing if you feel that Estuary Housing Association is using your personal identifiable information unlawfully, holding inaccurate, inadequate or irrelevant personal identifiable information which if used may have a detrimental impact on you or your rights.
The right of data portability
- You can request us to transfer data we hold about you to other services or organisations (conditions apply).
Rights in relation to automated decision making and profiling
You can obtain further information and independent advice about data protection and data privacy concerns in the United Kingdom by contacting the Information Commissioner (ICO), online at www.ico.org.uk or by phone on 0303 123 1113.
You can also make a complaint to the data protection supervisory authority, where your personal identifiable information is being held and processed. In respect of the United Kingdom, complaints should be directed to the Information Commissioner’s Office, contact details as above.
