From time to time we may share personal and sensitive personal data with other organisations. We may share information with members of Housing Plus Group to enable effective delivery of services, to deal with queries or to answer customer questions. For example, a complaint from a Care Plus customer may need investigation by Care Plus because they are a service provider and SSHA because they are the landlord and this 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.
We share information where there is a lawful basis to do so. Lawful basis is one or more of the following:
- Where we have to meet contractual obligations (this is usually to meet the requirements of any tenancy, lease or other legal agreement you have with us)
- Where there is a legal requirement to do so
- When it protects the vital interests of an individual
- When it is to carry out or perform a task in the public interest or to exercise official authority
- When it is in our or a third party’s legitimate interests
- Where we have consent
If we need to obtain your consent to share information we will do so in a number of different ways. This is usually via a signed agreement which sets out the details of the consent (for example, a housing application form or tenancy agreement).
Wherever possible we will inform you when we intend to share your information.
If you provide us with an email address, we will contact you using this unless you tell us otherwise. You can change your contact preferences at any time by using the unsubscribe option on emails or by contacting us.
Requests to withdraw consent to share information
You have the right to request that we do not share your details or that your details are only used for certain purposes. This may affect the level of service you receive and/or mean that you cannot access some services.
We will consider all requests carefully and let you know if we do not agree to the request and the reasons why.
Sharing information without consent
There are some occasions when do not need your consent to share your information with other organisations. We may pass on personal and sensitive personal data to other organisations such as Government Departments, local authorities, the courts or the emergency services, particularly the police. We do this when it is requested or we have a legal requirement to do so.
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 including Universal Credit
- As part of a report of, or investigation into, benefit fraud
- In response to an emergency situation when required by the emergency services or local authority
There are some occasions when we do not need your specific consent to share information with other organisations. We may pass your contact details to other organisations to enable them to deliver services for us, usually to meet the requirements of any tenancy, lease or other legal agreement you have with us.. Details may include name, address, telephone number, email address and any known specific communication or access needs.
Some examples of this are where we:
- Provide contact details to contractors, surveyors, maintenance providers, or tradespeople engaged by the Group so that they can contact you to visit your property to carry out repairs, maintenance or improvement works, safety checks and any audit or property survey work
- Provide forwarding addresses and/or other contact information and confirmation of tenancy start and end dates to utility companies, other service providers and/or their agents (such as debt collection agencies) who approach us about debt(s) you have accrued with them during your tenancy with us.
- Provide contact details and other relevant information (such as specific communication needs and any no lone working or other similar information) to organisations which provide out of hours call handling and emergency response services for us.
- Ask a research company to undertake a survey for us
- Pass your contact details to a mailing house or similar distribution organisation to send out information, such as newsletters or mailshots, on our behalf.
- Discuss and share information regarding individual property sales with relevant organisations such as Government departments (for Right to Buy, Right to Acquire and any other statutory schemes), financial advisors or other agents.
We may enter into an individual or multi-agency partnership with other organisations such as other housing providers, local authorities and the police. An example of this is a partnership with the Police and local authority to help prevent anti-social behaviour in an area where we operate.
We are clear with all organisations we share data with that they must comply with data protection legislation and regulations with regard to the personal and sensitive personal data we have provided to them. This includes how they will process, store and share this data.
We expect that all organisations we share data with will agree either:
- A contract, service level or other binding agreement which includes data protection clause(s) we are happy with; or,
- A specific data sharing agreement; or,
- Compliance with the Group’s Data Sharing Standards.
Data protection legislation and regulations include specific requirements to ensure the safety and security of data transferred outside of the European Economic Area (EEA). The Group does not routinely use organisations based outside of the EEA but recognises that some contractors, suppliers etc may and that the nature of “cloud computing” means that data may be shared more widely that the EEA.
Where we are aware of data transfers outside of the EEA we will check if any additional safeguards are required to be in place for data security, for example, additional security software. We will place reliance on relevant international regulations, such as the EU-US Privacy Shield.
Your personal information may be used by Housing Plus Group for direct marketing purposes to keep you updated with our latest services and offers if you have given us your consent for this. For example, if you have indicated you are interested in shared ownership on your housing application form, we will send you details of properties as they become available.
We will not sell, distribute or lease your personal or sensitive personal data to third parties unless we have your permission to do so.