Privacy Policy

ORWELL HOUSING ASSOCIATION LIMITED

Privacy Notice

How we use your personal information

Identity and contact details of Controller

Orwell Housing Association Limited (‘Orwell’) is a controller of personal information for the purposes of the Data Protection Act 2018 and UK General Data Protection Regulation (UK GDPR) 2018. Our contact details for data protection purposes are as follows:

Data Protection Officer
Orwell Housing Association
Crane Hill Lodge
325 London Road
Ipswich
IP2 0BE
0345 60 100 30
 DPO@orwell-housing.co.uk

Purpose of this Privacy Notice

This Privacy Notice tells you what to expect when Orwell processes personal information. It applies to information about applicants, customers, residents, former residents and other service users. It tells you the purposes for which we may process your personal information and the legal basis for the processing (‘processing’ includes us just keeping your personal information).

Why do we collect and store personal information?

Orwell needs to collect, process and store personal information about you and other household members (when you provide information about household members we assume that you do so with their full knowledge and consent) to operate as a registered provider of housing and deliver efficient and effective services. 

Legal basis for processing

We often have more than one legal basis for processing personal data. Firstly, where it is necessary for the purposes of the legitimate interests pursued by Orwell or by a third party to process your information. We can do that so long as we do not interfere with your fundamental rights or freedoms. Secondly, where we are under a legal obligation or an obligation under a contract (such as your tenancy agreement) to process/disclose the information.

The other reasons we can rely upon to process your personal information under UK GDPR is as follows: 

  • Where we need to protect the vital interests (i.e. the health and safety) of you or another person.
  • Some personal information is treated as more sensitive (for example information about health, sexuality, ethnic background. The legal basis for processing these special categories of personal information is more limited. To lawfully process special categories of personal data, we must identify a lawful basis for the processing and meet a separate condition for the processing. The basis we can use are: 
  • With your consent;
  • Where we need to protect the vital interests (i.e. the health and safety) of you or another person;
  • Where you have already made your personal information public; 
  • Where we or another person needs to bring or defend legal claims; and/or
  • Substantial public interest grounds

We class special category data as 

  • racial or ethnic origin, 
  • political opinions, 
  • religious or philosophical beliefs, 
  • trade union membership, 
  • processing of genetic data, 
  • biometric data for the purpose of uniquely identifying a natural person, 
  • data concerning health 
  • data concerning a person's sex life or sexual orientation

To process personal data about criminal convictions or offences, we must have both a lawful basis for the processing and either legal authority or official authority for the processing.

Information we may hold about you and how we use it

The information we hold on our records concerns our relationship with you.  For example:

  • We hold names & dates of birth, photographic ID and information about your previous housing circumstances to assess housing applications and help prevent tenancy fraud. 
  • We hold contact details for you, so we can communicate with you by your preferred means, and keep you informed about services we offer which may be useful to you.
  • We record information about your needs (for example if you have a carer or social worker; if you need adaptations in your home; if you need large print or translated text) to ensure that we take account of any support needs in our dealings with you, and to improve our communications with you.  
  • We record information to enable us to provide housing management services. For example, we record reports of anti-social behaviour; complaints; change in circumstances (for example when your employment status changes etc.) and information about housing options (e.g. if you have a medical need which means you need to move).
  • We keep financial records about the amount of money you have paid us; any amount(s) outstanding, and action taken to recover money you owe.
  • We may hold information about you if you are engaged with any additional guidance and support services. For example, in connection with access to training and employment we may hold information about your job history and skills and experience, or if we support you to improve your financial circumstances, we may hold information about your household income and expenditure. 
  • We record calls to and from our main office telephone number and other designated telephone numbers for training and monitoring purposes, where necessary for legitimate business reasons. Call monitoring is processed using Artificial Intelligence which analyses and transcribes calls to help us improve the service we provide to you. Call transcriptions are retained on your customer record.  Any call recordings will be held in accordance with our retention policy before being securely erased.
  • We may capture your image on our CCTV systems if you visit a property, office or community facility. Any CCTV recordings will be held in accordance with our corporate retention policy before being erased. 
  • We record the findings of surveys and other research to help us improve our service to customers. The information you provide will be anonymous unless you agree that we can use your details.
  • We hold special category and sensitive personal data in order to understand our customers and their needs better, to inform the services we provide in the public interest and comply with our regulatory and legal obligations.  

This list is not exhaustive, as we hold records of most contacts we have with you, or about you, and we process this information, so we can deliver services to you. Generally, the information we hold will have been provided by you (on application or enquiry forms or when we communicate with you), but we may also hold information provided by third parties where this is relevant to your housing circumstances e.g. from social workers and health professionals (such as doctors and occupational therapists).

We will only ask for personal information that is appropriate to enable us to deliver our services. In some cases, you can refuse to provide your details if you deem a request to be inappropriate. However, you should note that this may impact our ability to provide some services to you if you refuse to provide information that stops us from doing so.

Data relating specifically to children

As an organisation we will collect information about household members relating to a tenancy which may include details of any children in that household.  This data is used to ensure we hold the correct details of the tenancy and to help assess and allocate appropriate housing, data will not be used for any other purpose than relating to the tenancy, housing application or to inform the services we provide in the public interest and comply with our regulatory and legal obligations. 

We may collect and store data relating to children where we are dealing with welfare or safeguarding issues encountered within our housing management processes or within our temporary supported housing and domestic abuse services. This information is not shared for any other purposes but for the support for the childs welfare. Data will not be used for any direct marketing. We will use this data to ensure we can provide necessary support to individuals and/or families and to keep children safe.  

The purposes for which we would share this data, would be in relation to safeguarding a child, in relation to contractual obligations within service contracts, and if required in relation to referrals for move on accommodation.

How we manage your personal information

We process your personal information in accordance with the principles of UK GDPR. 

We will treat your personal information fairly and lawfully and we will ensure that information is:

  • Processed for limited purposes;
  • Kept up-to-date, accurate, relevant and not excessive;
  • Not kept longer than is necessary;
  • Kept secure.

Access to personal information is restricted to authorised individuals on a strictly need to know basis. 

We are committed to keeping your personal details up to date, and we encourage you to inform us about any changes needed to ensure your details are accurate. 

To help us to ensure confidentiality of your personal information we may ask you security questions to confirm your identity when you call us. We will not discuss your personal information with anyone other than you, unless you have given us prior written authorisation to do so. If you request copies of your information, we will also ask you to confirm your identity.

Periods for which we will store your personal information

We will only hold your records during the period of our relationship with you and for a set period afterwards to allow us to meet our legal obligations including resolving any follow up issues between us.

Sharing your personal information

We will share relevant information with third parties for the purposes as outlined, or where we are legally required to do so. When sharing personal information, we will comply with all aspects of the UK GDPR. Special categories of personal data about health, sexual life, race, religion and criminal activity for example is subject to particularly stringent security and confidentiality measures.

Where necessary or required, we may share information as follows:

  • to comply with the law (e.g. the police, Inland Revenue, Council Tax Registration Officer, Social Security Fraud Act) or a court order
  • where there is a clear health or safety risk to an individual or members of the public, evidence of fraud against Orwell, other irregular behaviour or a matter Orwell is investigating
  • in connection with court proceedings or statutory action to enforce compliance with tenancy conditions (e.g. applications for possession or for payment of Housing Benefit direct)
  • where Orwell has entered into a formal protocol with the police, a local authority department or the Care Quality Commission
  • providing the name, address and contact number of a resident to contractors or other agents providing services on Orwell’s behalf
  • providing the name of a resident and the date of occupancy to gas, electricity and water companies
  • providing forwarding addresses to debt collection agencies 
  • providing information anonymously for bona fide statistical or research purposes, provided it is not possible to identify the individuals to whom the information relates 
  • information required by the Regulator of Social Housing when monitoring Orwell’s activities in its capacity as the regulator of housing associations.
  • information on lettings and sales to The Ministry for Housing, Communities and Local Government via CORE (COntinuous REcording of social housing and sales) for statistical purposes
  • To protect the vital interests of an individual (in a life or death situation)

Your rights under the UK GDPR

You have a number of rights under the UK GDPR:

 Access to personal information

Under the UK GDPR, you have a right to ask us what personal information we hold about you, and to request a copy of your information.  This is known as a ‘subject access request’ (SAR).  SARs need to be made in writing and we ask that your written request is accompanied by proof of your identity.  We have one calendar month within which to provide you with the information you’ve asked for (although we will try to provide this to you as promptly as possible). We will ask you to prove your identity before we respond to the SAR.

Following your SAR, we will provide you with a copy of the information we hold that relates to you.  

Rectification

If you need us to correct any mistakes contained in the information we hold about you, you can let us know by contacting our Customer services team on 0345 60 100 30.

Erasure (‘right to be forgotten’)

You have the right to ask us to delete personal information we hold about you.   You can do this where:

  • the information is no longer necessary in relation to the purpose for which we originally collected/processed it
  • where you withdraw consent
  • where you object to the processing and there is no overriding legitimate interest for us continuing the processing
  • where we unlawfully processed the information
  • the personal information must be erased in order to comply with a legal obligation

We can refuse to erase your personal information where the personal information is processed for the following reasons:

  • to exercise the right of freedom of expression and information;
  • to enable functions designed to protect the public to be achieved e.g. government or regulatory functions
  • to comply with a legal obligation or for the performance of a public interest task or exercise of official authority;
  • for public health purposes in the public interest;
  • archiving purposes in the public interest, scientific research historical research or statistical purposes; 
  • the exercise or defense of legal claims; or

Restriction on processing

You have the right to require us to stop processing your personal information. When processing is restricted, we can store the information, but not do anything with it. You can do this where:

  • You challenge the accuracy of the information (we must restrict processing until we have verified its accuracy)
  • You challenge whether we have a legitimate interest in using the information
  • If the processing is a breach of the UK GDPR or otherwise unlawful
  • If we no longer need the personal data but you need the information to establish, exercise or defend a legal claim.

If we have disclosed your personal information to third parties, we must inform them about the restriction on processing, unless it is impossible or involves disproportionate effort to do so.

We must inform you when we decide to remove the restriction giving the reasons why.

Objection to processing

You have the right to object to processing where we say it is in our legitimate business interests. We must stop using the information unless we can show there is a compelling legitimate reason for the processing, which override your interests and rights, or the processing is necessary for us or someone else to bring or defend legal claims.

Withdrawal of consent

You have the right to withdraw your consent to us processing your information at any time. If the basis on which we are using your personal information is your consent, then we must stop using the information. We can refuse if we can rely on another reason to process the information such as our legitimate interests.    

Right to data portability

The right to data portability allows us to obtain and reuse your personal data across different services. It allows us to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way. The right only applies to personal data you have provided to us where the reason we are relying on to use the information is either your consent or for the performance of a contract. It also only applies when processing is carried out by us using automated means.

Changes to this Privacy Notice

We keep our privacy notice under regular review and will place any updates on our website; you will be notified of any major changes to this policy.   

Further information

For further information on how to request your personal information and how and why we process your information, you can contact us using the details below.

Data Protection Officer
Orwell Housing Association
Crane Hill Lodge
325 London Road
Ipswich
IP2 0BE
0345 60 100 30
 DPO@orwell-housing.co.uk

The Information Commissioner (ICO) is also a source of further information about your data protection rights. The ICO is an independent official body, and one of their primary functions is to administer the provisions of the UK GDPR.

You have the right to complain to the ICO if you think we have breached the UK GDPR. You can contact the ICO at:

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

0303 123 1113 /  http://www.ico.org.uk/