Introduction
This privacy notice applies to personal data held by Halton Housing about housing applicants, tenants, leaseholders, residents, advocates and any other customer of Halton Housing.
Who we are
Halton Housing is a registered provider of social housing, or housing association. We are regulated by the Regulator of Social Housing.
Halton Housing is a data controller of your personal data. This means we are responsible for collecting and using information about you so that we can deliver our services as a housing association to you.
About this Notice
This Notice explains what personal data we process, why it’s used and how it’s stored.
We may change this privacy notice from time to time in order to reflect changes in the law and/or our privacy practices.
As well as this notice, we may provide you with other privacy notices to deal with specific occasions when we are collecting or processing personal information about you. It is important that you read all such privacy notices so that you are aware of how and why we are using such information.
Why we use your personal data
We use your personal data so that we can deliver our services as a housing association to you.
Any personal data we process about you will be done so strictly in accordance with UK Data Protection Legislation (including the UK General Data Protection Regulation (UK GDPR), tailored by the Data Protection Act 2018).
Most commonly, we use it:
• to enter into a contract with you, or deliver a contractual service to you
• to comply with our legal obligations
In some cases, we process your personal data because there's a legitimate interest to do so. When this is the case we will always consider your interests before this processing begins and balance the rights and freedoms of our customers against the personal data processing being proposed. Some examples of this include recording calls with our Customer Hub and contacting you about activities we think may be of interest to you.
There are times when we’ll rely on your consent to process your personal data. We’ll always let you know at the time you give consent, and you always have the right to remove this consent. Some examples of this include asking for consent to use your image to use to promote the work of Halton Housing, or to deal with a third party acting on your behalf.
In rare cases we may rely on vital interests as the basis for processing personal data. This is likely to be limited to emergency medical situations.
Where we process special category, or sensitive, information about you, we will only do this where we are able to. This may be to comply with our responsibilities under equalities legislation and our own associated policies by providing assistance and making adjustments when delivering services to you, and to ensure equitable outcomes.
What we use your personal data for
We will use your data for one or more of the following reasons:
- To administer the housing register and allocate properties. We are a partner to Property Pool Plus, the register for social & affordable homes across Halton, Knowsley, Liverpool, Sefton and Wirral. The Property Pool Plus privacy notice can be found here: https://www.propertypoolplus.org.uk/PrivacyPolicy
- To communicate with you regarding our services
- To manage your tenancy including pre-tenancy work, tenancy changes, tenancy visits, mutual exchanges, and end of tenancy administration
- To deliver repairs and other works to your home
- To inform you about your rent, take rent payments and manage your rent account
- To deliver environmental and estates services
- To seek feedback from you on the contractual services we provide to you
- To engage you in helping to shape how our services are delivered
- To tailor our contact with you so that you receive information we think may be of interest to you
- To provide housing support for customers in independent living and sheltered housing schemes
- To deliver services within our independent living schemes
- To provide support to vulnerable customers
- To offer advice and assistance on household debt issues and welfare benefit entitlement
- To respond to any enquiries, compliments or complaints you contact us about
- To respond to any accidents or incidents
- To respond to any claims
- To recover any debt owed to us
- To deal with complaints of anti-social behaviour
- To take any action necessary for breach of tenancy
- To process any application from you to exercise your Right to Buy or Right to Acquire
- To process the buy back of Right to Buy of independent living properties
- To enter into a lease for a shared ownership property
- To provide services to leaseholders
- To raise any sundry invoices or process any ad hoc payments
- Where necessary, to protect our employees and other individuals
- For security purposes we may capture your image on our CCTV systems if you visit Waterfront Point or other premises which is covered by this service
- To record calls to help us review our performance and investigate complaints or claims
What kinds of personal information about you do we process?
Personal information that we use includes, where relevant:
- Name and contact details
- Records of your contacts with us
- NI number
- Gender
- Date of Birth
- Household and other information about your circumstances
- Welfare and support needs
- Financial information
- Employment information
- Bank details
- Images
- Next of kin contact details to use in case of an emergency. Please ensure your emergency contact is happy for you to disclose their information to us before providing their information.
We may also process special category, or sensitive, data such as:
- Physical or mental health information
- Racial or ethnic origin
- Religious or similar beliefs
- Sexual orientation
- Criminal activity
Most of the information we hold will be collected directly from you, but we may also obtain information from another person or organisation if they are permitted to share it with us. This could include the local authority, your previous landlord, your doctor or other health professionals.
Sharing your data
When we use your data for the purposes described above, this may include sharing your data with third parties. We will only share your data where the law allows us to do so.
We may share your personal data with organisations that we contract or partner with to provide services to our customers and that provide us with professional and other services. When we use third party service providers, we only disclose the personal data that’s necessary to deliver the service and we have a contract in place that requires them to keep your personal data secure as required by UK Data Protection Legislation.
We may also share data with bodies such as the local authority, police, fire service, DWP, support agencies and utility companies.
Experian Rental Exchange
We have teamed up with Experian to take part in The Rental Exchange. The Rental Exchange is a way to strengthen your credit report without you needing to take on new credit. The scheme enables us to share details about the rent you pay with Experian on a monthly basis. This is then included in your credit report, meaning you will then be recognised for paying your rent on time.
There is a legitimate interest in the sharing of data into Rental Exchange for these purposes, which forms our legal ground for the sharing of this data into the Rental Exchange.
If you would like to see more information about this, please follow this link: www.experian.co.uk/crain (Credit Reference Agency Information Notice (CRAIN)).
What should you do if your personal information changes?
You should tell us so that we can update our records. You contact us in a number of ways to do this: Get in touch | Halton Housing
How long do we keep your information for?
We only keep your information for as long as it is needed. This is so that we can meet our operational needs and to meet any legal and regulatory requirements.
We use guidance from the National Housing Federation to help us decide how long we should keep your information for.
How do we keep your data secure?
We hold all our data in secure data centres and it is backed up on a regular basis to separate locations. Access to data is strictly controlled and monitored. All devices and servers are kept up to date with security patches and virus definitions. We employ a number of security monitoring solutions that ensure our systems are regularly audited and tested to make sure that we are following procedures and to detect and address potential security risks.
What are your rights under data protection law?
Data Protection legislation provides rights for individuals over their data.
You have several rights which allow you to choose and control how we use your data. These rights are explained below. If you would like to exercise these rights, please see the How to contact us section.
Transparency
You have the right to be informed about how we are using your data. This Privacy Notice gives a general overview of the use of your data by Halton Housing.
Access
You have the right to ask us what personal information we hold about you, in the form of a Subject Access Request (SAR).
Rectification
If you think that the personal data we hold about you is inaccurate or incomplete, you have a right to request that it be rectified.
Erasure
You can ask us to delete your personal data where it is no longer necessary for us to use it, where you have withdrawn consent (if we process based on consent), or where we have no lawful basis for keeping it.
Restriction
You can ask us to restrict the personal data we use about you where you have asked for it to be erased or where you have objected to our use of it.
Data portability
You can ask us to provide you, or a third party (if possible), with some of the personal data we hold about you in a structured, commonly used, electronic form so that it can be easily transferred.
Objection
You can object to the processing of your personal data. You should note that this right does not apply in all circumstances, for example, where we are processing information because it is necessary in the performance of a contract we have with you, we will not be able to stop processing this information.
A list of these Rights, and more information about what they mean can be found at the Information Commissioner’s Office website: https://ico.org.uk/
How to contact us
We have a dedicated Data Protection Officer (DPO). If you’re not satisfied with the way we’ve handled with your personal data or have any questions, please let us know and we’ll try and resolve your concerns. You can contact our DPO at dpo@haltonhousing.co.uk
Who can I complain to if I am unhappy about how my information is used?
You can complain directly to Halton Housing’s Data Protection Officer at dpo@haltonhousing.co.uk or in writing to:
Data Protection Officer
Halton Housing
Waterfront Point
Warrington Road
Widnes
WA8 0TD
You also have the right to complain to the Information Commissioner’s Office: Information Commissioner's Office (ICO)