Privacy notice

We are guardians of our customer and employee information and we take the privacy and the security of it very seriously. This notice sets out our approach to safeguarding the privacy of the personal information we hold. 

Housing Plus Group is responsible for collecting, processing and storing your information as well as keeping it secure. We manage personal information in accordance with the Data Protection Act 1998 and any subsequent legislation. We are registered as data controllers with the Information Commissioner’s Office (ICO), registration number Z1210914. ​

Who are we?

Housing Plus Group is a housing provider registered with Homes England, reference L4491 and is a Community Benefit Society, reference 30224R. Housing Plus Group was created on 1 October 2016 by a merger between Severnside Housing and Housing Plus. 

Housing Plus Group consists of:

  • South Staffordshire Housing Association which is a housing provider registered with the Homes England (reference LH4121) and a Charitable Community Benefit Society (reference 28312R).
  • Severnside Housing; a housing provider registered with Homes England, reference LH4325 and a Registered Charity,reference 1166317.
  • Care Plus; a provider of care and support services for older people and those with disabilities or health conditions. Care Plus is registered with the Care Quality Commission (CQC), reference 2000032662 and is a Charitable Community Benefit Society, reference 30948R.
  • Property Plus; a specialist service delivering repairs and maintenance across the Group including maintaining communal areas and undertaking disabled adaptations.
  • AWE Contractors; a registered company, reference 8331962.
  • 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 notice applies to all personal information collected by Housing Plus Group, our members and contractors acting on our behalf. Members and contractors will be registered individually with the ICO.

Where do we operate?

The Group operates in Staffordshire, Shropshire, Telford and Wrekin and Dudley. 

What is our privacy policy?

During the course of their work, all members of 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. Protecting your information and complying with data protection legislation is taken 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 email address) and photographs or CCTV images.

Sensitive personal data (also known as special category data) is information about a characteristic of an individual. Examples include, but are not limited to, gender, race or ethnic origin, religious or similar beliefs, sexuality, membership of a union or society and details of any convictions, proceedings and criminal acts.

This notice sets out what data we collect and why. It covers:

  • How we collect, store and use the information that you provide to us including:
    • why we use the information
    • when we will pass information to third parties
    • what we expect of organisations we pass information to
  • How we comply with the requirements of data protection legislation and regulation
  • How we comply with the rights you have, including letting you know what information we have about you, how you can access this and make other requests such as correcting any inaccurate data
  • How we can be contacted for more information and how you can make a complaint

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. This can be:

  • When you apply for a rented property with us. Information will be collected on application forms and in supporting documentation which can 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. Contact details, information relating to welfare benefits and your income and savings will be collected as well as 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, questionnaires, feedback forms contact preferences and other profiling data
  • When you participate in any competitions and provide contact details and other information as part of this
  • When you request a repair or report other issues such as nuisance or anti-social behaviour
  • At the end of a tenancy, for example, you may leave us with a 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
  • 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 into the Group for training and 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, car parks, estates 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 notice.

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.
  • Monitor performance
  • Keep and administer internal records
  • Undertake market research and profiling for example, building up a picture of an area by gathering specific information on people who live there
  • Send information to you electronically and in writing for example, customer newsletters and formal legal notices
  • Contact you by telephone, text, email or social media
  • Customise communications with you. This can be via the website or in the form of written letters which meet individual contact or communication needs

We are required to deliver services to you which are set out either in legislation or a contract, 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 purpose to use this information. Therefore once you supply your contact details you do so knowing we will use these for operational purposes.

Profiling and segmentation

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.

Markers and flags

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 apply markers or flags 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 about someone’s safety or behaviour. When applying these warning flags we will take into account regulatory advice and our own internal procedures regarding risk assessment, informing the individual concerned and reviewing any such situations.

How does the Group protect data?

The Group takes the security of your data very seriously. We have internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed and is not accessed except by employees in the performance of their duties. Access to data is protected by unique profiles for data use depending upon the need of the individual and is secure through password entry. The password entry systems are compliant with the Group’s security processes. 

Where the Group engages third parties to process personal data on our behalf, the companies do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data. Such third parties will also be required to enter into an appropriate data sharing agreement. 

Who can we pass your information to?

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 
  • 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 

Consent

If we need to obtain your consent to share information we can do so in a number of different ways. We will inform you by letter, website, forms and/or newsletters where we intend to obtain, use and share your information. 

Sharing information without consent 

We may pass on personal and sensitive personal data to other organisations such as local authorities, the courts or 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 
  • 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 

In these circumstances, we do not require your permission to pass on information. 

We may pass your contact details to other organisations to enable them to deliver services for us. Details include name, address, telephone number, email address and any known specific communication or access needs. We may: 

  • Ask a research company to undertake a survey for us 
  • 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 
  • Pass your contact details to a mailing house or similar distribution organisation to send out information, such as newsletters, on our behalf. 
  • Provide contact details to maintenance providers, tradespeople or contractors 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 to utility companies pursuing debt after the end of a tenancy 
  • Discuss and share information regarding individual property sales with relevant organisations such as financial advisors or other agents 

In these circumstances, we do not require your permission to pass on information. You do have the right to request that we do not share your details or that they are only used for certain purposes. We will consider all requests carefully and let you know if we do not agree to the request and the reasons why.

Partnership arrangements 

We may enter into a partnership with other organisations such as other housing providers, local authorities and the police. An example of this is a partnership to help prevent anti-social behaviour in an area 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 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. 

Direct marketing 

Your personal information may be used by Housing Plus Group for direct marketing purposes to keep you updated with our latest services and offers. 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. 

If you provide us with an email 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 emails or by contacting us. 

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. 

When you contact us 

When you call our customer service team we will ask you security questions to clarify your identity before disclosing any account-related information. We do this to protect you and to make sure that other people cannot obtain information about you that they are not entitled to know. 

If you would like another person to talk to us about your account, you will need to give them your permission to do so and make us aware of this, otherwise, we cannot discuss your personal situation or disclose information about you. You can explain this arrangement 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.7 

Staff training and support 

Staff receive data protection awareness training as part of their induction and undertake scheduled refreshers. 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 formal internal audits. 

How we keep your information up-to-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 up-to-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 up-to-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 in legislation or specific regulatory guidance and we have detailed information on this based on advice issued by the National Housing Federation (NHF). At the end of the relevant retention period, we dispose of your information securely. 

Your rights

You have a number of rights under data protection legislation and regulation. These are: 

  • The right to be informed about what data is collected and how it is used. This notice helps comply with this right 
  • The right to request access to your data and other information held about you 
  • The right to have any mistakes or inaccuracies in your data put right 
  • The right to request the deletion or removal of data where there is no compelling reason for its continued use 
  • The right to restrict the processing of data where it is inaccurate or consideration of the lawful basis or legitimate interest is ongoing 
  • The right to portability, which ensures data is provided in a readily useable format 
  • The right to object to processing in certain circumstances, such as direct marketing, profiling or scientific research 
  • The right to be informed about and object to data being used for some automated decision making, such as profiling 

Requesting a copy of your information 

You have a right to request a copy of information held about you. This is called a subject access request. 

You will need to put your request in writing and provide proof of your identity. Once these are received, we will respond within one calendar month. 

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 ongoing investigation. If we do withhold any information we will tell you why this is. 

We reserve the right to refuse subject access requests where these are repeated requests, where information has already been provided or the request is troublesome. If we consider this the case, we will tell you why this is. 

Requesting rights 

If you wish to request information about any of your rights, please contact us.

Cookies

A cookie is a small file which is automatically placed on your computer’s hard drive. Once this file is added, the cookie helps analyse web traffic or allows web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. 

Please note that we do use cookies within all Group websites. You can set your browser to not accept cookies however this means that some website features may not work correctly or at all. 

You can find out more information about cookies and how they affect you here

Other Websites

The websites of Housing Plus Group and its members contain links to other sites. The Housing Plus Group privacy notice only applies to our websites and when you access others you should check their own privacy notices. 

Where can I get more information?

Housing Plus Group has a range of policies covering data protection and information 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 by calling 0303 123 1113. The ICO has registration details of Housing Plus Group and each of its members which set out what personal and sensitive personal data they collect and why. 

How can I make a complaint?

If you feel we have not complied with this privacy notice or other Housing Plus Group policies or you are unhappy with the service provided to you, you can make a complaint using the Group’s complaints procedure. Please contact feedback@ housingplusgroup.co.uk or call 01785 312000

You can also make a complaint to the Information Commissioners Office (ICO) via their website at www.ico.org.uk/concerns or by calling 0303 123 1113.

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: 

Please use the contact details above for data protection queries or questions about all organisations in Housing Plus Group.

Policy Last Reviewed: March 2018

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