What do we use your personal data for and what are our legal grounds for this?
• To administer the housing register and allocate properties. This is necessary to enter into a contract with you and meet our legal obligations.
• To administer the sale and re-sale of properties where applicable. This is necessary to enter into a contract with you and for the performance of the contract between you and us.
• To contact you and respond to contacts you make to us. This is necessary to for the performance of the contract between you and us, and to meet our legal obligations.
• To manage your tenancy including pre-tenancy work, tenancy changes, mutual exchanges, and end of tenancy administration. This is necessary to enter into a contract with you, for the performance of the contract between you and us and to meet our legal obligations.
• To deliver repairs and other works to your home and any communal areas. This is where necessary for the performance of the contract between you and us and meet our legal obligations.
• To take rent payments and manage your rent account. This is necessary for the performance of the contract between you and us.
• To take payments for any service charges and other non-rent services. This is necessary for the performance of the contract between you and us and where necessary to meet our legal obligations.
• To respond to any enquiries or complaints you contact us about. This is in our legitimate interests and where necessary to meet our legal obligations.
• To deal with complaints of anti-social behaviour. This is necessary for the performance of the contract between you and us and to meet our legal obligations.
• If we identify through contact with you any additional support needs you have, we will tailor the way we engage with you to help you successfully maintain your tenancy. This is in our legitimate interests and where necessary to meet our legal obligations.
• To provide housing support where applicable. This is where necessary for the performance of the contract between you and us.
• To contact you to seek feedback on the contractual services we provide to you. This is necessary for the performance of the contract between you and us.
• To engage you in the delivery of our services. This is in our legitimate interests and necessary to meet our legal obligations.
• To take any action necessary for breach of tenancy. This may be necessary for the performance of the contract between you and us and/or where it is in our legitimate interests to do so.
• To recover any debt owed to us. This is in our legitimate interests.
• To process any application from you to exercise your Right to Buy or Right to Acquire. This is necessary to meet our legal obligations.
• Where necessary, to protect our customers, colleagues, and other individuals we may capture your image on our CCTV systems. This information may be necessary for the purposes of public safety and crime prevention.
• We record calls to help us review our performance and investigate complaints or claims. It is in our legitimate interests to do this.
• We may from time to time send surveys to you to review the performance of our services. This may be necessary for the performance of the contract between you and us.
• We may use your image in photographs for publicity material, where we have your consent to do so. When we obtain your consent for this, we will tell you how you can withdraw your consent.
* Some of the above information that we need to collect is sensitive in nature and is considered to be in a ‘special category’ i.e. racial or ethnic origin, health or disability, religion and sexuality.
Where does this information come from?
We obtain personal data by various means; this can be through face-to-face contact, email, telephone, written correspondence or receiving this information from others, for example: a local MP who represents you, the police, health or social care agencies, or government agencies. We can also receive information about you from other people who know you or are linked to you, e.g. relatives, persons nominated to act on your behalf or your legal representative.
Lawful basis for collecting and processing your personal data
We only collect and process personal data about you where we have the lawful basis to do so. The majority of personal data we hold and process for you is based on the operation of your Tenancy Agreement.
There may also be a legal obligation with which we have to comply. For example, we share information with local authorities, the Police, the Department of Welfare and Pensions, Probation Service, HM Revenue and Customs etc.
There are also legitimate interests basis for us to collect information for example, we collect and process your National Insurance number for the purposes of housing fraud detection and prevention. We also pass on certain personal details to Experian in order to track former customers who owe us rent or service charges and we have not been able to contact them. Sharing information is also in our legitimate business interests, we may share your information without seeking your consent first. This may be with:
• Other statutory organisations e.g. social services and health authorities
• Solicitors or legal advisors
• Other landlords (if you want to move to another property or to get references)
• Energy/water suppliers and Council Tax departments, to set up your utilities or to ensure billing details are correct
In a limited number of occasions, we may expressly ask you to give us your consent. Where you have given your consent, you have the right to withdraw it later. We will let you know how to do this at the time we gather your consent and we will be clear about what we are seeking consent to do.
Special protection is given to certain kinds of personal data which is particularly sensitive. This is information about your health status, your children, racial or ethnic origin, political views, religious or similar beliefs, sex life or sexual orientation, genetic or biometric identifiers, trade union membership or criminal convictions or allegations.
We will only use this kind of personal information where:
• We have a legal obligation to do so (for example to protect vulnerable people);
• It is necessary for us to do so to protect your vital interests (e.g.an immediate medical need whilst on our premises);
• It is in the substantial public interest;
• It is necessary for the prevention or detection of crime;
• It is necessary for insurance purposes; or
• You have specifically given us ‘affirmative’ consent to use the information.
We may also share information when required by law for example where ordered by the Court or to protect an individual from immediate harm. We will only share the minimum amount of personal data necessary to enable us to fulfil our legal obligations. We will not sell your personal or sensitive data.
whg is a member of Rental Exchange. We share 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. This gives you the credit you deserve for paying your rent on time – in the same way as your mortgage payments would if you were a homeowner – and improves your credit report. It creates an online history of your rental payments to prove to companies that you are a reliable potential customer by proving who you are and where you live.
A good credit profile will make it easier for you to open or change bank accounts, shop online, get better mobile phone rates or better gas and electricity rates, or get a better credit card deal.
This arrangement also helps us as your landlord to build a clearer view of your financial well-being, to identify customers who may be in financial stress or are at risk of falling behind on payments in future. This helps us to help you if you are in danger of getting into difficulties. Not only will we be able to work with you more closely to manage your existing tenancy agreement, your track record as a customer will enable Experian to use the information supplied to them 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 product in light of your current circumstances;
• contact you in relation to any accounts you may have and recovering debts that you may owe;
• verifying your identity, age and address, to help other organisations make decisions about the services they offer;
• help to prevent crime, fraud and money laundering;
• screen marketing offers to make sure they are appropriate to your circumstances;
• for Experian to undertake statistical analysis, analytics and profiling; and
• for Experian to conduct system and product testing and database processing activities, such as data loading, data matching and data linkage.
If you would like more information about this please go to https://www.experian.co.uk/legal/crain/
(Credit Reference Agency Information Notice). If you do not want your data to be shared with Rental Exchange, please email firstname.lastname@example.org with your name and address with the words Rental Exchange opt-out in the subject line. If you have no access to email you can also call 0300 555 6666 and ask to speak to the Data Protection Officer about the Rental Exchange programme.
When we need consent
From time to time, we may send you marketing communications, if you have indicated that you are happy to receive these, for example when you create an account on our website or apply for a property. If you are happy to receive marketing communications, we will provide you with news from us such as new housing that you may be interested in and about our employment and wellbeing services or to give feedback about services we provide outside your tenancy. We may also contact you for other research and monitoring purposes, such as sending you surveys, using your preferred method of contact.
If you do not want to receive marketing communications from us, you can simply tell us so by clicking the relevant box before making your application. You can also choose to opt out from receiving marketing communications at any time, by updating your preference through your online account. If you prefer, you can also call our Customer Service team and express your preference to not receive marketing communications or send an email to email@example.com with the subject title ‘Unsubscribe’.
In certain circumstances you may need to set up a third party to act on your behalf, you can do this by contacting whg and providing the persons details and any relevant documents, such as a certified copy of the Power of Attorney or Court Order.
Violent or abusive behaviour
If you are violent or abusive to whg colleagues, customers or other people, we may decide to place a “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, so long as we deem notification not to be a threat to our colleagues. Where appropriate, we will share this information with our partners, for example our contractors to protect their colleagues too.
Keeping your information
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 will usually keep information about you for as long as you are our customer and for a further six years. Legal documents may need to be kept for a minimum of 12 years. We will store your information securely in computer systems or in certain circumstances in manual files. We will dispose securely of all information when it is no longer necessary for the purposes of administering your tenancy.
How we protect personal data under our control
We are committed to ensuring that your information is secure. All our colleagues receive appropriate training on confidentiality of information. We apply appropriate technical and organisational measures to ensure your personal information is secure. Access to data is strictly controlled and monitored. All devices and servers are kept up to date with security patches and virus definitions. Our systems are regularly audited and tested to make sure that we are following procedures and to detect and address potential security risks. When we need to share personal data with third parties, we ensure data sharing and confidentiality protocols are in place.
To help us ensure confidentiality of your personal information we will ask you (and any of your representatives) 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, there is a court appointed deputyship or Power of Attorney, or where we have received a clear verbal instruction from you (as a one-off circumstance).
Manage your Home Online
Our customers are able to manage their home online with us via manage your home online.
Through this service customers can view rent account details, contact us, raise repairs etc, whenever and wherever you need to.
This service is encrypted using SSL security. SSL stands for Secure Sockets Layer, a global standard security technology that enables encrypted communication between a web browser and a web server. It is used by online businesses and individuals to decrease the risk of sensitive information (e.g. credit card numbers, usernames, passwords, emails, etc.) from being stolen or tampered with by hackers and identity thieves. In essence, SSL allows for a private “conversation” just between the two intended parties.
Phishing is the name given to attempts to steal personal details and financial account information from a website user. “Phishers” use fake or spoof emails to lead users to counterfeit websites where the user is tricked into entering their personal details, such as credit card numbers, usernames and passwords. We will never send emails asking you for such details.
Transfers of personal data outside the UK
Personal data relating to whg customers, colleagues and others is usually stored in the UK or in the European Economic Area (EEA) or other jurisdictions recognised as adequate by the UK and the European Union. If we need to share information with organisations outside the UK, the EEA or a jurisdiction that the European Commission regards as having adequate levels of protections for personal data, we will put in place appropriate safeguards (such as contractual commitments), in accordance with applicable legal requirements, to ensure that your data is adequately protected.
We may get your information from social media, whether on our own sites or elsewhere. Where you make something public on whg’s website or social media you give us your consent, to copy, use and reproduce any of your contributions for any purpose as this is in the public domain.
Where a post on social media (whether on our own site or elsewhere) is inappropriate and constitutes a breach of our policies or any legislation, we may take the following actions:
• Issue you with a warning.
• Commence legal proceedings to take down the post and recover legal costs resulting from the breach.
• Report you and disclose information to the appropriate law enforcement authorities or statutory body as we deem necessary.
We may also withdraw your right to use our social media platforms or remove/edit any posts or material uploaded by you.
Website privacy and cookies
Cookies are small text files that are sent by websites that you visit for a number of purposes, including to make those websites work, or work more efficiently, and to recognise who you are when you return there for convenience. The files are stored on your computer’s hard drive and are read by your web browser.
For more specific information on the cookies used on our website and the easiest way to manage these, please see our cookies policy.
If you would like to block cookies and stop sites from storing cookies on your devices, there are a number of ways you can do this depending on what browser you’re using. The following website offers advice on how you can disable cookies: https://cookies.insites.com/disable-cookies/
Please be aware blocking cookies may affect pages you are able to view and your user experience when using some websites.
As a website user, we will collect:
• Information about your computer and about your visits to and use of this website (including your IP address, your cookie preferences, geographical location, browser type, referral source, length of visit and number of page views)
• Information relating to any transactions carried out between you and us on or in relation to this website
• Information that you provide to us for the purpose of registering with us or subscribing to our website services including name, address, email, telephone number and, where relevant, the type of property you are looking for
• Any other information that you choose to send to us.
We will use this to:
• administer the website and improve your browsing experience by personalising the website
• provide relevant website services, for example, raising a request for us to contact you, to report a complaint and to make payments
• monitor the usage of website to help us improve our services
• produce anonymous statistical information about our website users to help us develop our website and services
• deliver tailored messaging to you, on and off our website.
If at any time you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the permission you grant to us.
We also use third party cookies and may share information about your use of our site with our trusted advertising, analytics and social media partners.
whg is not responsible for the privacy policies or practices of third-party websites accessed through links on our site.
Your rights in relation to your data
As a data subject, you have a number of rights, where you can:
• access and obtain a copy of the data we hold by making a Subject Access Request
• ask us to your personal data that is inaccurate or incomplete
• ask us to delete or remove personal data where there is no compelling reason for the processing to be continued
• object to the processing of your data where we rely upon legitimate interests as the legal basis for processing
• ask us to stop processing your data for a period of time if it is inaccurate or there is a dispute in relation to whether your interests override our legitimate grounds for processing your data.
What if I am unhappy about how my information is used or want to exercise my rights?
In the first instance please contact whg’s Data Protection Officer:
Email: firstname.lastname@example.org Phone: 0300 555 6666 Post: whg, 100 Hatherton Street, Walsall, WS1 1AB
You can make a complaint about the way that we handle your personal information by following our usual complaints procedure or by contacting email@example.com.
If you feel that we have not dealt with your complaint properly, you can contact the Independent Information Commissioner’s Office. Go to https://ico.org.uk/global/contact-us/contact-us-public/ or telephone 0303 123 1113.
‘whg’ is a social housing provider, our registered office is at 100 Hatherton Street, Walsall WS1 1AB.
whg is registered as a ‘Data Controller’ on the Public Register of Data Controllers which is maintained by the Information Commissioner’s Office(“ICO”) under registration number Z667510X.