Privacy statement for our customers
whg holds lots of personal information about our customers and we need to make sure it is handled and kept carefully in line with the Data Protection Act.
We have introduced this Privacy Statement that tells you everything you need to know about:
• what information we collect from you
• how we store it
• why we collect it
• who we share it with and why.
Information we may collect from you
We may collect the following personal information about you:
When you first come to see us
- Your name and contact details for use across whg and by our suppliers and partners
- Detailed personal information such as age, sex, date of birth, ethnicity, disability, employment status, particular needs or preferences so that we can understand you and your needs better and tailor our service to you
For housing management purposes
- Your housing needs, so we can find a property that suits you when available from us or selected other landlords
- Bank details and direct debit information to make payments to us such as rent or service charges (we only exchange the details with the account holder and the third party who manages our direct debits)
- If you pay us using your payment card we do not store the details, for your added security (and we only exchange the details with the person we believe to be the card holder).
- Benefit and council tax information to verify your circumstances
- Details relating to the repair and maintenance of your home
- Information that you provide to your whg housing advisor, neighbourhood impact officer, asset management team member, or any other contact at whg
- Information for contents insurance
- Feedback from our contractors, about their appointments with you
- Voice and video recordings (e.g. CCTV) for safety, crime reduction and quality management
- Proof of identity for new lettings (e.g. passport or biometric residence permit)
To improve your experience with whg
- You can give us details of your friends, relatives or neighbours who you trust to contact us on your behalf, e.g. to arrange one of our services for you
- You can give us details of anyone you have formally authorised (such as giving them a Power of Attorney) to contact us on your behalf
- Your name and contact details for Customer Satisfaction surveys, newsletters and service information
- With your consent, your name, photo, video or story for brochures, advertising or press releases or use by the media
- Any information about complaints about our service or other individuals, or accidents or incidents involving you or your home
- Your comments about services from us or our suppliers
If you ask for additional whg services
- Your name and contact details for someone to contact you (the person may be a whg colleague or from another organisation that we will tell you about)
- If you ask us for care and support requirements we will hold detailed information about your needs and/or your family’s needs
- Records of payments for the services
- If we arrange insurance for you, we will process your details required by the insurer, and will receive account reports from the insurer
- If you contact us about money problems we will hold detailed information about your income and debts; we keep this separate from our other information about you
- If you use our Skills Centre we will ask about your employment and learning history
- If you access any of our other involvement and support projects we will ask you for personal information relevant to these projects.
- We may hold information about your history, e.g. regarding credit, or offences, if we need it to look after our colleagues, business or anyone else
- If you make a complaint we will keep the details separate from our other information about you
If we are providing a service to you on behalf of another organisation
- We will receive information from your service provider and we will exchange the information we need to provide services to you on their behalf
- We may receive management information about the accounts we manage
We may get the information, or related information, from your or our partner organisations (see below), you, your family, friends or neighbours, our colleagues or public information sources including credit reference agencies or the Disclosure and Barring Service (previously known as the Criminal Records Bureau).
We may also record factual information whenever you contact us or use our services, as well as information about other action we take, so we have a record of what happened.
Violent or abusive behaviour
If you are violent or abusive to whg colleagues, customers or other residents, we may decide to place a “violent warning marker” on your customer record in order to protect whg colleagues.
If we do this, we will write and tell you why and you will have the right to appeal against our decision. We will share this information with our partners, for example our contractors or the Fire Service in order to protect their colleagues too.
Credit reference agencies
To ensure our records are up to date and for the prevention, detection and prosecution of crime, including social housing fraud and benefit fraud ; we will from time to time use credit reference agencies. Any information we receive will not be passed on to third parties and will not be used for any inappropriate purposes.
If we access your data, we will in all cases seek to check with you that the information is correct.
Where we store your personal information
We are committed to holding your personal information securely. This means only those of our colleagues and contractors that need to see it have access.
If we can store your personal information solely on computers we will, however there will be cases where we have paper copies instead, or as well.
Our computer system is at our offices in Walsall but we do use computers (including laptops and tablets) outside our offices if they are secure and under our control. Sometimes we also use computers which are owned or managed by our suppliers, if the computers are secure and under our control.
What we use your personal information for
- As above, and generally for providing our services for you
- Keeping in touch with our customers, understanding your needs and preferences, inviting you to events, and offering and booking appointments with you. This includes sending text messages.
- Telling you about changes to whg and its services
- Meeting your housing management needs, including if you ask for a transfer to another housing association
- Managing payments from you, to you or on your account, and for accounting purposes
- Providing additional services, where available, at your request including skills training and every day support services
- Prevention, detection and prosecution of crime, including social housing fraud and benefit fraud
- Quality management
- Informing our colleagues, contractors or others (as appropriate) about past incidents e.g. anti-social behaviour, for their protection, in line with our policies
- Meeting our legal obligations including information we have to provide to our funders or regulators
- Us or your other suppliers exercising legal rights, including under contract with you
- Other purposes - we may anonymise your information so that it cannot be linked to you. In that case we may use the data for any purpose
Who else we may pass on your information to
Normally, only whg will be able to access your personal information. However there may be times when we disclose your details to others, as follows:
- Companies within the whg group
Our suppliers who enable us to provide our services to you, or who provide services on our behalf:
- Contractors e.g. to undertake repairs or improvements to your home
- IT providers who own or manage the computers, phones or systems we use
- Our contractor(s) who handle your out of hours service calls for us
- Banks e.g. to carry out payments through a secure system
- Companies that assist us in mailing out our leaflets / newsletters
- Additional colleague resources, such as consultants or agency staff
- Our professional advisors, auditors and providers of financial services
Our partner organisations whose purposes dovetail with ours so that they can provide you with a service:
- Training providers or learning institutions, for example Steps to Work
- Other housing associations
- External assistance where you have agreed to the referral, for example to do with money problems
- Local authorities and Government departments who provide relevant services for you, including benefits
- The Police, Fire Service, health authorities or medical staff who provide services for you
Others who may request information from us for their own purposes:
- Utility companies including water companies
- For crime prevention or detection, risk assessment, resolution of complaints or other issues
- Local authorities, Safeguarding Boards, regulators, Government departments and other public authorities, such as for preventing payment errors or fraud
- The Police, Fire Service, health authorities or medical practitioners
We may sometimes be obliged to disclose your personal data by law such as by a regulator with appropriate power (e.g. the Homes and Community Agency), or court order. Information held by public bodies or us can be subject to freedom of information.
We do not give anyone else access to your information in return for payment, for their marketing or commercial purposes.
Unless you pay our bills using direct debit we will not usually retain your payment details. Whoever pays your bills will have to give us the payment card details each time they make a payment.
We will not share your personal information with anyone who claims to represent you unless we are satisfied that you have appointed them or they act in some recognised official capacity. There may be a delay to us dealing with requests whilst we confirm the caller’s identity, or check that we have your approval to deal with them.
whg is a member of Rental Exchange. We will be sharing your tenancy details and rent payment history with a company called Experian to help you create an online proof of identify, proving to organisations that you are who you say you are. A good credit profile will make it easier for you to open or change bank accounts, shop online, receive better mobile phone rates, receive better gas and electricity rates, or obtain cheaper credit.
Not only will we be able to work with you more closely to manage your existing tenancy agreement, your track record as a tenant will enable Experian to use the information supplied to them in the future to assist other landlords and organisations to:
- assess and manage any new tenancy agreements you may enter into;
- assess your financial standing to provide you with suitable products and services;
- manage any accounts that you may already hold, for example reviewing suitable products or adjusting your current product in light of your current circumstances
- contact you in relation to any accounts you may have and recovering debts that you may owe;
- contact you in relation to any accounts you may have and recovering debts that you may owe;
- verify your identity and address to help them make decisions about services they offer; and
- help prevent crime, fraud and money laundering.
We may get your information from social media, whether on our own sites or elsewhere. Where you use whg’s website or social media you grant us an irrevocable, royalty-free, non-exclusive licence, and give us your consent, to copy, use and reproduce any of your contributions for any purpose.
Where you make a contribution to any social media (whether on our own site or elsewhere) we may use that information for any of the purposes stated in this privacy statement.
Where a contribution to any social media (whether on our own site or elsewhere) constitutes a breach of whg’s IT Security policy or any other policies, terms and conditions or laws that apply, we may take the following actions:
- Issue you with a warning.
- Start legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach.
- Take further legal action against you (including, but not limited to, proceedings for a breach of your contract of employment or other contract you may have with us).
- Report you and disclose such information to the appropriate law enforcement authorities or statutory body in any jurisdiction as we reasonably feel is necessary.
- Publish such information about you as we reasonably feel is appropriate, publicly (which may include social media).
We exclude liability for actions taken in response to breaches of any whg policy. The responses described in this privacy statement are not limited, and we may take any other action we reasonably deem appropriate and we are not obliged to take any action.
Where you make a contribution to our social media, we may also take the following actions in addition to any other actions described above:
- Immediate, temporary or permanent withdrawal of your right to use our social media.
- Immediate, temporary or permanent removal or editing of any posting or material uploaded by you to our social media.
You have the right to ask us not to process your personal information however we may be unable to provide our service to you if we are unable to record and process certain details.
You have the right to complain to the Information Commissioner if you think there is a problem with the way we have handled your personal information. The Information Commissioner can be contacted on 0303 123 1113 and has a useful website at www.ico.org.uk where you can find more information.
Accessing the information we have about you
You have a legal right to access information that we hold about you. If you ask us, we will charge of fee of £10 to meet our costs. You can ask any of our colleagues or write to our Data Protection Officer at our registered office address, 100 Hatherton Street, Walsall WS1 1AB.
We will respond to your request with 40 days and in most cases we will be able to comply with your request. However we may not be able to provide you with your request if your personal information contains details about another person.
If you want to make a complaint to whg about the way we have handled your personal information or want to know how that information will be used, contact the Data Protection Officer at 100 Hatherton Street, Walsall, WS1 1AB.
Changes to our Privacy Statement
This Statement may change. We will display the new Statement in all places where it can usually be found, such as on our website, and at our offices and outlets.
Our nominated representative for the purposes of the Act is Helen Lane, Governance Manager.
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