We are guardians of our customers and employee’s information and we take your privacy and the security of your information very seriously. This policy sets out our approach to safeguarding the privacy of the personal information we hold. The Housing Plus Group is responsible for collecting, processing, storing and keeping your information secure. We manage personal information in accordance with the Data Protection Act 1998, and are registered (registration number Z1210914) as Data Controllers with the Information Commissioner’s Office (ICO).
Who are we?
The Housing Plus Group is a housing provider registered with the Homes and Communities Agency (reference L4491) and is a Community Benefit Society (reference 30224R). The Housing Plus Group was created on 1st October 2016 by a merger between Severnside Housing Association and South Staffordshire Housing Association.
Housing Plus Group consists of:
- South Staffordshire Housing Association which is a housing provider registered with the Homes and Communities Agency (reference LH4121) and a Charitable Community Benefit Society (reference 281312R).
- Severnside Housing Association which is a housing provider registered with the Homes and Communities Agency (reference LH4325) and a Registered Charity (reference 1166317).
- Care Plus which is a provider of care and support services for older people and those with disabilities. Care Plus is registered with the Care Quality Commission (reference 2000032662) and is a Charitable Community Benefit Society (reference 30948R).
- Property Plus provides a specialist repairs and maintenance service, including communal areas and disabled adaptations.
- AWE Contractors which is a registered company (reference 8331962) and undertakes the electrical works to our properties including repairs and a 24 hour call out service
- 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 policy applies to all personal information collected by the Housing Plus Group, our subsidiaries and partners, and contractors acting on our behalf. Subsidiaries, partners and contractors will be registered separately with the ICO.
Where do we operate?
The Group operates in Staffordshire, Shropshire and Dudley.
In the course of their work, all members of the 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 about them. We take protecting your information and complying with your data protection rights very seriously.
Personal data is information which can be used to identify an individual. Examples include, but are not limited to, name, address, National Insurance number, date of birth, contact details (such as a telephone number or e-mail address) and photographs or CCTV images.
Sensitive personal data is information about a characteristic of an individual. Examples include but are not limited to gender, racial or ethnic origin, religious or similar beliefs, sexuality, membership of a union or society and details of any convictions, proceedings and criminal acts.
This policy covers how we:
- Process (that is collect, store and use) the information that you provide to us including:
- the purposes(s) we use the information for
- in what circumstances we will pass information to third parties, and
- what we expect of organisations we pass information to.
- Comply with the requirements of the Data Protection Act 1998
- Can let you know what information we have regarding you and how you can access this
- Can be contacted for more information
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. These include but are not limited to:
- When you apply for a rented property with us (for example, application form and supporting information – this could 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 (for example, contact details, information relating to welfare benefits and your income and savings and 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, preference and profiling data)
- When you report repairs or other issues (such as nuisance or anti social behaviour) to us (for example, details of what is wrong or access details)
- At the end of a tenancy (for example, 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).Information when you complete surveys, questionnaires, feedback forms and participate in competitions.
- As part of the planning and delivery of any care and support service to you (for example, support needs, medical and next of kin details).
- We may record telephone calls made to our Customer Services Team for training or 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 or schemes.
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 Policy.
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 and support.
- Performance monitoring.
- Internal record keeping and administration.
- Market research and profiling (for example, building up a picture of an area by gathering specific information on people who live in that area).
- Sending information to you electronically and in writing (for example, customer newsletters and formal legal notices).
- Contacting you by telephone, text, e-mail or social media.
- Customising communications with you (such as via the website or written letters) to better meet individual contact or communication needs (for example, recording which customers tell us they need large print etc).
We are required to deliver service(s) to you which are set out either in legislation or your legal agreement with us (this could be a Tenancy Agreement, licence or lease 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 ground to use this information. Therefore once you supply your contact details you do so knowing we will use these for operational purposes.
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.
We may apply markers 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 in regards to someone’s safety or behaviour. When applying these warning flags we will take account of ICO advice and our own internal permission procedures.
Applications for employment
If you submit an application to work for us we will use your personal information to process your application and to produce and monitor recruitment statistics. We will not take up references without your prior permission. We will not share or disclose your information unless you have given us your consent or we are required to by law. Where we are required to carry out a Disclosure and Barring Service check we will comply with the law and your rights when carrying out these checks.
We retain personal information relating to unsuccessful applicants for a minimum of 6 months, for use in the event of an appeal, or future vacancies. We produce statistical information to assist with recruitment analysis.
Who can we pass your information to?
We may from time to time share personal and sensitive personal data with other organisations. These could be different organisations in the Housing Plus Group to enable effective delivery of services, to deal with queries, answer customer questions etc. For example, a complaint from a Care Plus customer may need investigation by Care Plus (as the service provider) and SSHA (as the landlord) which will involve sharing data. Personal and sensitive personal data will also be shared with contractors who undertake work for the Group (for example, gas contractors and those involved in delivering property improvements).
Our normal practice is not to share your information without your consent unless we are required to do so by law or regulation or if sharing information is required to perform our operations.
We can obtain your consent in different ways; this can be when you apply for housing or employment with us, when you sign your tenancy licence or lease agreement and/or activate your right to buy status. We can also inform you by letter, website, forms, and newsletters and so on where we intend to obtain, use and share your information.
We may pass on personal and sensitive personal data to other organisations (such as local authorities, the Courts or the Police) where this is requested or we have a legal requirement to do so. In these circumstances, we do not require your permission to pass on information.
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
- As part of a report of or investigation into benefit fraud
- In response to a emergency situation when required by the emergency services or local authority
We may pass your contact details (including name, address, telephone number, e-mail address and any known specific communication or access needs) to other organisations to enable them to deliver services for us. Some examples of this are:
- We may ask a research company to undertake a survey for us
- We may ask a marketing company to provide details of products or services you may be interested in (such as new housing developments for sale or rent)
- We will provide contact details to maintenance providers, tradespeople or contractors engaged by the Association so that they can contact you and/or attend your property to carry out repairs, maintenance and/or improvement works
- We will provide forwarding addresses to utility companies pursuing debt after the end of a tenancy
- Where necessary we will discuss and share information regarding individual property sales with relevant organisations (such as a financial advisors or the Homebuy Agent).
- We may pass your contact details to a mailing house or similar distribution organisation to send out information (such as newsletters) on our behalf.
We may enter into partnerships with other organisations such as other housing providers, local authorities and the police. An example of this is a partnership to help prevent and control anti social behaviour in the areas where we operate.
We are clear with organisations that they must comply with data protection legislation and maintain confidentiality with regard to the personal and sensitive personal data we have provided to them. This includes how they will use, store and share personal data. We have data sharing agreements with them that set out these requirements. Where organisations we pass information to are based outside of the United Kingdom, we will check if any additional safeguards are required to be in place for data security (for example, additional security software).
Your personal information may be used by the Housing Plus Group for direct marketing purposes to keep you updated with our latest services/offers. For example, if you have indicated you are interested in shared ownership on your housing application form, we will send you details of schemes as they arise.
We will not sell, distribute or lease your personal or sensitive personal data to third parties unless we have your permission to do so.
If you provide us with an e-mail address we will assume that you are happy for us to contact you using this unless you tell us otherwise. You can change your contact preferences at any time by using the Unsubscribe option on e-mails or contacting us using the contact details below.
How we keep your information secure
We store personal and personal sensitive data both electronically and in paper form. We use a range of controls to keep the information you provide to us 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 etc).
When you contact us
When you call our Customer Services team we will ask you security questions to clarify your identify before disclosing any account related information. We do this to protect you and to make sure that other people cannot find things out about you that they are not entitled to know.
If you would like another person to talk to us about your account or relationship with us, you will need to give them your permission to do so and make us aware of this. We cannot discuss your personal situation or disclose information about you without this permission. You can explain this permission 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 on an ongoing “refresher” basis. 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 Group staff as well as internal audit.
How we keep your information upto 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 upto 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 upto date. You can ask us to correct or remove information that you think is not accurate.
We only keep your information as long as we need it (this may be a minimum time set it in legislation or specific regulatory guidance) and have detailed guidance on this based on advice issued by the National Housing Federation. At the end of the relevant retention period we dispose of your information securely.
Your rights under the Data Protection Act 1998 including access to personal information
You have a number of rights under the Data Protection Act 1998. These include rights to:
- Object to the use of your personal information that causes damage or distress and to seek correction and destruction of this information.
- Object to the use of your personal information for direct marketing.
- Know about automated decision making.
- Seek compensation through the courts.
- The right to ask for a copy of your personal information.
Requesting a copy of your information
You have a right under the Data Protection Act to request a copy of information held about you. This is called a Subject Access Request or SAR.
You will need to put your request in writing (we do have a form for this but you do not have to use this if you do not want to), provide proof of your identity and pay a £10.00 fee. Once the request, proof of identity and fee are received we will respond within the statutory time limits (currently 40 days).
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 on going investigation). If we do withhold any information we will tell you why this is.
Requesting correction(s) to information
We make every effort to ensure that the information we hold about you is accurate and up-to-date. You may ask us either to correct or remove information you think is inaccurate. Please do this in writing via the contact details below.
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Where can I get more information?
The Housing Plus Group has a range of policies covering data protection and information security. These include Data Protection, Confidentiality, Access to Personal Information, Use of Electronic Communications Systems and ICT Systems and Security. These policies are available on request.
For more information on data protection legislation and requirements you can also contact the Information Commissioners Office (ICO) at www.ico.org.uk or call 0303 123 1113. The ICO also has registration details of each Housing Plus Group’s member organisations which set out what personal and sensitive personal data they collect and why.
How can I make a complaint?
You can complain to the Information Commissioners Office (ICO) via their website at www.ico.org.uk/concerns or calling 0303 1231113.
How to contact us
Please do not hesitate to contact us if you have any questions about this statement, the information we hold about you, our overall approach to data protection across and within the Group, confidentiality or to make a Subject Access Request.
You can contact us in the following ways:
- e-mail email@example.com
- landline: 01785 312000 (please ask for the Data Controller)
- write to The Data Controller, Housing Plus Group, Acton Court, Acton Gate, Stafford, ST18 9AP
Please use the contact details above for queries or questions about all organisations in the Housing Plus Group.
Policy Last Reviewed: October 2017