Privacy notice

UK General Data Protection Regulations (UK GDPR) Privacy Notice

 

What is the purpose of this document?

We are committed to protecting the privacy and security of your personal information. This privacy notice explains how we collect your information, what personal information we collect and how we use personal information about you during and after your custom with us, in accordance with the UK General Data Protection Regulations (UK GDPR).

 

Saxon Weald is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

 

About us

Saxon Weald is a charitable Housing Association (community benefit society number 7971) with a registered office at 38-42 Worthing Road, Horsham, West Sussex, RH12 1DT. Saxon Weald trades under the trading names of Saxon Weald and Weald Living.

 

For the purpose of the Data Protection Act (2018) Saxon Weald is registered as a data controller with the Information Commissioners Office with registration number ZA490750.

 

Saxon Weald has appointed an official Data Protection Officer. The contact details are as follows:

Data Protection People

C/O Saxon Weald

38-42 Worthing Road

Horsham

West Sussex

RH12 1DT

(e-mail) dataprotection@saxonweald.com

 

What personal information do we collect?

Saxon Weald will only collect the personal data we need from you to deliver our services. The type of information we collect from you depends on our relationship with you. We will have different data for people who rent homes from us, than those who use our community investment services, or our employees.

 

We collect information about you when you make an application with us, or referral is made by you for one of our services. We also collect information when you voluntarily complete customers surveys, provide feedback or through general correspondence. Website usage information is collected using cookies. Further information may be collected during a tenancy, for example photographs of properties when assessing repairs requests, or if your personal circumstances change.

 

We will collect the following information for the performance of a contract with us. This may include:

  • Details about you and your household, including:
  • Name
  • Date of birth
  • Address
  • Copies of relevant identification documents
  • Employment details
  • Details about your home, family composition, your housing needs and tenancy agreement
  • Details about your communication preferences and online behaviour
  • Rent and service charge information, including details of any arrears
  • References received about you (for example from your employer or previous landlord)

 

We have a legal obligation to collect the following information from you:

  • Financial information, including:
  • Credit checks
  • Income details
  • Bank details
  • Housing benefit information
  • Any guarantor details
  • Medical information and emergency contact details, next of kin and any advocate

 

We have a legitimate interest to collect the following information from you:

  • Photographs taken of you or your property, such as CCTV footage or photos taken for repairs assessments
  • Information about any complaints made by you, or which relate to you
  • Information about any accidents of incidents which involve you or your home
  • Equality, Diversity and Inclusion (EDI) information about yourself and household members

 

We will obtain your consent to collect the following information from you:

  • Information regarding your marketing preferences

 

For the purpose of equal opportunities monitoring, and only with your explicit consent, we may also collect information about the following:

  • Ethnicity
  • Gender
  • Sexual orientation

 

If we consider you to be a risk to our staff, we will place a "flag" against your tenancy. This is to protect our staff and contractors.

 

Why do we collect this information?

We collect the majority of the information contained on your application or referrals to provide you with housing and associated services, such as carrying out repairs and monitoring any defects. We also use information about you to tailor our services and to meet the needs of our customers.

 

Further information is also collected on the application form for the purposes of equal opportunities monitoring. Where this information is collected it is always with your explicit consent.

 

We may collect other information as part of our community investment work. This will only ever be done with your explicit consent and when you sign-up to a particular service or opportunity.

 

How will we collect this information?

Information will be collected from you personally when you enter into an agreement or contract with us, such as through a tenancy agreement. This will be in the form of applications and any other forms which may be completed to apply for one of our properties. You will also have the opportunity to provide information through questionnaires.

 

It is possible that we will receive referrals containing your information from public bodies such as local authorities, but this should be done with your consent and knowledge of why they are making the referral to our services.

 

We may generate further personal data regarding our tenants during the course of the tenancy. This could be in the form of general correspondence, or to satisfy our statutory obligations. An example of fulfilling our statutory obligations and collecting personal data would be where photographs of properties are required for the purposes of monitoring defects or for assessing any health and safety risks. We may receive information about our tenants from other support services such as TellJO Ltd; this should be done with your consent and knowledge of why they are passing this information to us. We will only use this information for the purpose it was intended.

 

We may also purchase information about you to allow us to segment our customers and shape our services accordingly.

 

How we will use it?

Saxon Weald collects, stores and processes personal data on you and your household for several purposes as follows;

  • to manage your tenancy/lease (or similar) and the property it relates to,
  • to manage compliance with the terms of your agreement/lease (or similar),
  • to allow personnel administration,
  • for financial accounting and management of payments,
  • for marketing purposes,
  • to prevent or detect fraud,
  • for equal opportunities monitoring,
  • to help us to make reasonable adjustments for any disability, as requested by you
  • to detect vulnerable customers and to identify safeguarding issues,
  • to meet any legal and regulatory requirements and show that we are meeting our obligations as your landlord (including allowing access to information when we are audited),
  • to meet our obligations to bodies involved with your care/support (such as the relevant Local Authority department, Social Services or the Care Quality Commission) and show that we are meeting our obligations as your care/support provider,
  • to provide key services including repairs, managing your tenancy, and benefit advice,
  • to set up arrangements relating to your home, such as informing the Local Authority of your tenancy arrangements for council tax and housing benefit purposes,
  • to help other people or companies to provide services or utilities to your home or to contact you. This may include where they need to contact you when you first move in, to set up payments or about any unpaid bills while you live at your home and/or after you leave your home,
  • to investigate and address complaints, accidents or incidents and prevent reoccurrences,
  • to provide information to our staff to enable them to provide services that meet your needs, and to train and protect them where necessary,
  • to deal with any medical or other emergencies and to carry out your wishes or requirements, including any religious or cultural wishes,
  • to act in someone's best interests, for example where we have concerns about a person's health or welfare and may need to involve agencies such as social services or the police,
  • to provide care/support services to you, or work alongside other organisations who provide care/support to you and to deal with any issues arising about your care/support services,
  • to provide references to third parties where we are asked to by you (such as to a new landlord),
  • to prevent and detect crime (this will include the usage of CCTV and lone working devices),
  • to help us put together statistics to give to our regulator or other government organisations,

 

We will process your Personal Data for the purposes identified above on the following bases:

  1. Our legitimate interests, which include processing your information (including EDI information) for the purposes of providing and enhancing the provision of our products, services and information;
  2. Where such processing is necessary to perform our contractual obligations with you or to take steps before entering into contractual arrangements with you; and
  3. As necessary to comply with our legal obligations such as criminal, housing or health and safety laws, resolve disputes and enforce our contractual agreements. We are also required to collect EDI data to ensure we are meeting customer needs.

 

For more information or to contact us regarding a subject access request, please email dataprotection@saxonweald.com or write to Saxon Weald House, 38-42 Worthing Road, Horsham, West Sussex, RH12 1DT. A subject access form can be found here.

You don't need to complete a form to make a request, but it will make processing your request easier.

 

Who will we share it with?

Where information is used for the reasons listed above, we may need to share the information about you and the people you live with to other organisations. This will include:

 

  • Companies which provide services or utilities to your home (such as the gas, electric or water board) and the relevant Council Tax department. This may be while you are living at your home or after you leave your home and may include providing a copy of your tenancy agreement when you move in and providing a forwarding address when you leave. This information may be provided to enable the company to set up your payment arrangements and/or to pursue any unpaid bills.
  • People who provide services on our behalf, such as a managing agent or contractors carrying out repairs etc.
  • A credit checking agency, your bank and mortgage company or other financial institutions and (where necessary) a debt collection and/or tracing agency.
  • The Housing Benefit department and other Government departments which provide funding for your housing or care/support services. In particular, we may be legally required to give information about any changes in your financial circumstances to the Housing Benefit department.
  • Resident representatives and board members involved in our complaints process.
  • A doctor, hospital, paramedic or health worker where you require medical attention and are unable to provide the information yourself.
  • Your next of kin or other people acting on your behalf in an emergency and a member of your church or religious leader, where you have requested this.
  • People or agencies who provide services to you or who work with us to provide services to you, such as your care/support provider.
  • The bodies involved with your care/support such as the relevant Local Authority departments, or Social Services and any alarm call centre.
  • Our regulator or other bodies which look at how we provide services as your landlord and other people where we are legally required to provide information to them. For example, Saxon Weald may occasionally share data such as emails to the Housing Ombudsman for the purposes of ensuring that we have handled your complaint correctly which we do on the basis of legitimate interest. We will also anonymously share EDI information with organisations such as the NHF to ensure we can demonstrate that we understand the support needs of our customers.
  • Our legal advisors, the courts and the police. This may include information about anti-social behaviour, which we may also share via a joint website accessed by landlords, the police, social services and other bodies with the aim of reducing anti-social behaviour.
  • Relevant Local Authority departments (including housing benefit, council tax, elections, adult services, fraud teams etc.)
  • To relevant people and authorities such as the police, adult and child protection and social services. This may include sharing information when we have concerns about a person's health or welfare, or where there are investigations being carried out, such as sharing information in a case conference with such bodies and other parties involved (such as teachers, nurses, etc.) or where we have concerns about possible criminal activity.
  • Companies who process information on our behalf such as an external mailing company (who send out our newsletter), our archiving company, our confidential waste disposal company and providers of our information technology services and software.
  • Companies who analyse and augment household information to provide customer insight, to allow us to shape our services.
  • Companies that provide customer survey and feedback services.
  • To another landlord or housing association where you are looking to move or exchange your property (e.g. where they request your details and/or a reference from us).

 

How long will we keep your data?

Saxon Weald will hold your personal data for the length that it is required to provide you with services. We may be required to retain some of your data after this time, for a set period, for us to meet our legal obligations including resolving any follow up issues.

 

We maintain a data retention schedule which sets out how long we keep different types of information for. This is based on guidance from our membership body, the National Housing Federation, and certain legal requirements.

 

Please contact our Data Privacy Officer if you would like further information on how long we keep certain types of Data.

 

Profiling

Saxon Weald uses profiling to gain a deeper understanding of data subjects' socio-demographic and financial circumstances by using, for example:

  • Experian's Mosaic categorisation data
  • Experian's financial vulnerability data
  • Mobysoft's Rentsense arrears prediction tool
  • Greenstone Data Solutions Customer Segmentation Services
  • Greenstone Data Solution Digital Propensity Model

 

International Transfers

Saxon Weald will not transfer your information outside of the European Economic Area without adequate safeguards. If we or our service providers transfer personal data outside of the UK or EEA, we always require that appropriate safeguards are in place to protect the information when it is processed.

 

Your rights

You have the following rights concerning your data:

 

Right of access -You have the right to obtain confirmation from Saxon Weald as to whether or not personal data concerning you is being processed and have access to that personal data.

 

Right to rectification - You have the right to ask Saxon Weald to rectify inaccurate personal data concerning you. You have the right to have incomplete personal data completed by providing a supplementary statement where appropriate. You can see what information we hold on you at mysaxonweald.com.

 

Right to erasure (right to be forgotten) -You have the right (under certain circumstances, but not all) to ask Saxon Weald to erase personal data concerning you. This will never include current tenancy details as necessary to fulfil our contractual obligations, or any information we are required to process under law.

 

Right to restriction of processing -You have the right (under certain circumstances, but not all) to ask Saxon Weald to restrict processing of your personal data. For example, you may request this if you are contesting the accuracy of personal data held about you.

 

Right to data portability -You have the right (under certain circumstances, but not all) to ask Saxon Weald to provide you with the personal data about you which you have provided to Saxon Weald in a structured, commonly used and machine-readable format.

You also have the right to oblige Saxon Weald to transmit those data to another controller.

 

Right to withdraw consent -If the lawful basis for processing is consent, you have the right to withdraw that consent. If you wish to withdraw your consent, contact us immediately.

 

Right to object to direct marketing -Where your personal data is processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for marketing, which includes profiling that relates to such direct marketing.

 

Rights in relation to automated decision making and profiling -Saxon Weald does not perform any automated decision-making based on personal data that produces legal effects or similarly significantly affects you. Saxon Weald performs customer profiling to allow us to shape our services.

 

If you would like to exercise any of the above rights, please email dataprotection@saxonweald.com.

 

For more information about any of your rights, please visit:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

 

Your right to lodge a complaint with a supervisory authority

If you wish to exercise any of your rights concerning your personal data, you should contact Saxon Weald's Data Privacy Officer at the address shown above. If you are not satisfied with the response you receive you have the right to lodge a complaint with the supervisory authority. In the United Kingdom this is:

 

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 0303 123 1113

Email: casework@ico.org.uk

 

v.0003.00

 

Call recording

We record all calls to and from our customer support team. When a call is recorded, we collect:

  • a recording of the conversation
  • your phone number

 

Calls that are transferred from the contact centre to another member of staff within the organisation will only be recorded up to the point of transfer. Saxon Weald do not record internal calls or calls that have been passed from the contact centre to other personnel.

 

Please note: to make a payment over the telephone you are required to use your telephone key-pad to provide your payment details therefore, no payment information is recorded.

 

How recordings are used

Call recordings will be used:

  • to assist in quality monitoring and training of staff
  • to investigate and resolve a complaint
  • as evidence in tenancy management issues including verbal abuse of our staff
  • for the detection, investigation and prevention of crime (including fraud)

Call recordings will be kept for 8 weeks as standard but may be held longer where required for training purposes or as evidence.

 

Our legal basis for recording calls

Recording of calls is necessary to protect the interests of you, our staff or both.

It's also in our legitimate interests, unless those interests are overridden by you by asking for your call not to be recorded. You may request that your call isn't recorded. In this situation, you'll normally be advised to contact us either in writing or by email.

 

In exceptional circumstances you may be transferred to a non-recorded phone. This decision will be made by a customer service manager, for example when he or she determines that not doing so could cause harm or distress to the caller. The team manager will, in these exceptional circumstances, ensure the caller is transferred to a phone which isn't registered for call recording.

 

Sharing data

We may be required or permitted, under Data Protection legislation, to share a call recording with other organisations without your explicit consent, for example if we have a legal obligation to do so, such as for:

  • law enforcement
  • fraud investigations
  • regulation and licensing
  • criminal prosecutions
  • court proceedings