The ForHousing privacy notice tells you what to expect when we process your personal data. Any personal data provided to us is managed in accordance with the Data Protection Act 2018 (DPA 2018) and the UK General Data Protection Regulation 2018. Where data is processed in the EU, we also comply with the General Data Protection Regulation (2016/679 the GDPR).
We may make changes to this policy; any updates will be on this page. If you would like to know more, or have any questions about your personal data, do not hesitate to contact us via email at email@example.com
Who we are:
ForHousing is the data controller as defined in the DPA 2018 and is registered with the Information Commissioners Office (ICO) under registration number Z1517732.
As a landlord ForHousing have some standard processing activities that your personal data is used for, for example:
- Provision of housing
- Tenancy management
- Property maintenance and repair
- Shared Ownership/Leasehold
- Purchase/Provision of private rental services
There are some additional services that we provide in which your personal data may be used:
- Organising community events
- Opportunities for consultation (scrutiny panels etc)
How do we collect personal data?
ForHousing collect personal data in a variety of ways, for example:
- Completion of forms (e.g. tenancy sign-up, taking part in feedback or surveys)
- Correspondence with us (e.g. phone, email, chatbot or through our customer service teams)
- At certain sites we operate CCTV to record public areas.
- We will record personal data that you provide to us concerning members of your family and friends and we will assume that this is done with their knowledge and consent.
What personal data do we collect?
This privacy notice is applicable to customers, including current, former and potential customers who are engaged with or wish to access our services, as well as visitors to our website, offices and social media sites.
We only collect personal data that is relevant. Some data may be used for several different reasons, and the personal data we collect will vary depending on your relationship with us. We will collect data directly from you for several reasons, below is a list of the type of information that we may collect:
- Name, address, contact details, age, sex, date of birth, ethnicity, health information, relationship status, care responsibility or requirements, national insurance number, income, benefit receipt, employment status, bank details, unspent criminal convictions.
Most of the personal data that we process about you will be collected directly from you, but if there are additional requirements, then we may also collect information from third parties, for example:
- Local authorities
- Health professionals
- Solicitors or legal representatives
- Financial advisors
- The list above is non exhaustive, but it illustrates the variety of personal data that ForHousing may process.
How do we use your personal data?
To provide context for why this information is collected, and how it is used, we have provided some examples below:
Some of the information provided to us will be processed as part of a contractual requirement. This information allows us to provide you with services, and without which an application for housing could not be accepted. For example:
- Personal identification is required so that we can guarantee that the application is genuine and there is no fraudulent activity taking place.
- Contact details such as your telephone number, allow us to keep in touch with you. They provide a mean by which we can discuss matters that may have arisen during your tenancy. E.g. servicing and maintenance or the installation of improvements such as a new kitchen.
- Contact details also allow us to provide you with administrative information, such as changes to the complaints process.
- If we are to provide the best possible service, then the details surrounding your health are of vital importance. The information allows us to provide you with a property best suited to your needs and makes our staff aware of any additional requirements you may have.
- A complete history of your contact with us and contact of your representatives such as a next of kin. This allows us to appropriately manage your tenancy, for example by tracking on-going repairs or maintenance.
- Financial information enables us to track your preferred method of payment and determine if any outstanding payments exist.
- Your personal history allows us to look after our staff, business and any third parties that we may be engaging to provide you with services.
We have legal obligations under which we are obliged to provide personal data. For example:
- To aid a constabulary investigating the detection and prevention of crime. This may involve providing a name or address as well as CCTV imagery.
- We may also need to provide CCTV footage to solicitors or insurers who are seeking compensation for claims where the incident has taken place on ForHousing property.
- Demonstrating to our regulators that we are fulfilling our obligations in relation to anti-discrimination law.
ForHousing have several areas of business in which our legitimate Interests results in us processing personal data. For example:
- ForHousing need to know who in addition to the primary tenant is living at the address. This allows us to provide additional services where required and helps with the prevention of sub-letting and other fraudulent activity.
- We monitor and record calls for training and quality monitoring.
- We use contact details to send out customer satisfaction surveys. This provides us with quality data to assess our performance.
- Monitoring emails to improve communication and response times.
- Demographic information such as age, ethnicity, occupation, gender, household composition will be used to help us target improvements to our services.
- Demographic information may also be shared with specific third parties for the completion of Tenant Satisfaction Measures. The Tenant Satisfaction Measures allow us to monitor compliance with legislation and develop a score to better understand of where ForHousing sits amongst our peers.
From time to time, we will ask for your consent to process certain data sets e.g., when we support you with contacting third parties for employment support.
We may also ask for your consent if you are involved in some activities with us to enable us to capture your image or share your attendance at say an Streets.
There are activities where we will collect special category data. Special category data is classified as: race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data (for identification purposes), health data, sexual orientation, criminal convictions (including cautions).
Please be aware that there will be times when asking your consent to share personal data will not be necessary, and we are permitted by law to do so, for example with competent authorities who are discharging a statutory law enforcement function.
If we are sharing criminal offence data, we need a lawful basis to do so, and either official authority or legal authority.
We use this information to provide services appropriately, for example when processing health data concerning a tenant. The data is also used to monitor diversity, inclusion, and equality metrics.
CCTV and Photographs
Some of our sites have CCTV. As such you may be recorded when you visit. Our CCTV systems are used for the protection of our communities and staff. They are only viewed when it is necessary, and the footage that is captured is held for specific period before it is recorded over.
When ForHousing runs events at our properties or within our communities, we may take photographs that are used in for marketing, internal promotions and social media. These photographs will only ever be used with your consent, which is held within our Communications Team (include their contact details?).
Who will we share data with?
Data sharing may be necessary with third parties to ensure that you are getting the best possible service or under a legal obligation such as to assist with the detection of crime. When we share data, we do so within the guidelines identified within data protection law.
We may share data under a legal obligation to a variety of organisations such as:
- Social services
- National Housing Federation
- HM Revenue and Customs
- Department for Work and Pensions
If we have a legitimate interest or contractual obligation to share data with:
- Repairs, and maintenance contractors
- Water and gas companies
- Credit reference agencies
- Environmental health
- Regulator of Social Housing
- Survey companies to monitor your satisfaction with our services
Whenever ForHousing shares personal data, we only provide the data that is necessary for the delivery of the specified duty, or the purpose of the contract that we have engaged them for. We make sure that your privacy is paramount, and that once their services are no longer being used, that your data is returned, deleted, or anonymised.
How do we protect your data?
We have in place appropriate technical and organisational measures that govern the protection of data. For the most part, your personal data is stored and maintained within a variety of IT systems that have a high level of security and confidentiality. Where paper records are held, they are done so at secure sites where personnel have limited access.
The level of access that a member of staff has to your personal data is dependent on their role, and all staff require two factor authentication to access ForHousing systems.
ForHousing staff complete mandatory information security training, and at set intervals thereafter to ensure that they understand their responsibilities and are kept up to date with potential threats.
When data is shared with third parties such as local authorities, data is encrypted, and password protected. When we solicit third party contractors to provide a service, we have contracts in place that dictate the terms under which information can be processed.
ForHousing are based in the UK, and we store our data within the UK, EU or EEA. If we ever engage with a service that sends your personal data outside of the EU and EEA, we will ensure that there are equivalent safeguards in place.
If it is necessary for you to contact us, then we will ask security questions of you or your representative to confirm your identity.
How long will we keep your data?
ForHousing uses a retention schedule based on the National Housing Federation guidance, legal requirement and best practice.
A copy of our retention schedule can be provided in full if required. Please contact firstname.lastname@example.org with your enquiries.
What are your rights?
ForHousing is committed to enabling your individual rights.
Right to be informed: Informed about the collection and use of personal data.
Right of Access: To view and request copies of personal data.
Right to Rectification: Request outdated or inaccurate information be corrected.
Right to Erasure: Request that personal data be deleted. This is not an absolute right, and there may be exemptions.
Right to Restrict Processing: Restriction or suppression of processing of personal data.
Right to Data Portability: Ask that personal data be transferred from one controller to another. Data must be in a machine-readable format.
Right to Object: Object to processing personal data and be subject to automated decision making or profiling.
Childrens Personal Data
All of ForHousing tenants are adults, and predominately process children’s data if they are a resident in one of our properties. This allows us to more accurately manage our properties and address any issues that may arise where the age of residents is required, or any concerns regarding overcrowding.
We may also receive children’s data if there are issues surrounding welfare cases or safeguarding issues that involve external partners such as the Local Authority or Police.
Concerns or Complaints
If you have any questions about how your personal data is being used or wish to raise a complaint, please do not hesitate to contact us directly.
You also have the right to raise any issues with the Information Commissioners Office (ICO). They can be contact via post, telephone and email at the details below.
Information Commissioners Office
Phone: 0303 123 1113