Hyde privacy notice

Below are the entities/subsidiaries within the Hyde Group who process personal data and their ICO registered number.

Registration Numbers

Z547722X   Hyde Housing Association Ltd

Z788316X   Partners For Improvement in Islington Limited

Z5258353   Martlet Homes Ltd

Z9383537   Hillside Housing Trust Ltd

Z9400659   Hyde Charitable Trust

ZA191353   Hyde Vale Limited

Z7283806   Hyde Southbank Homes Limited

ZA753301   Brent Co-Efficient Ltd

ZA753345   Hyde New Build Limited

ZB459920   Halesworth Limited (TBC – Now Hyde Halesworth Ltd)

The type of personal data that we collect /obtain

As a social housing provider, landlord, and employer, we will collect and process the following information: 

• Personal identifiers such as full name and any reference numbers we assign you (i.e., tenancy or payment reference.)  
• Residential history 
• Data that confirms your identity including photo id   
• Date of birth 
• National Insurance number 
• Details of anyone authorised to act on your behalf if applicable. 
• Banking and payment card details if you make payment to us. 
• Benefit and Council tax information; 
• Proof of housing eligibility; 
• Your concerns, feedback, or dissatisfaction on your neighbours, our services, or our staff members.  
• Employment status and history if you are seeking to work with us or using one of our training  and employment schemes.  
• Technical information including IP address, and mouse/pointer activity on our pages in the form of heat maps, to help us see which parts of the webpage is most used.

Other personal information may be collected in order to help us resolve breaches of tenancy, alleged anti-social behaviour or suspected fraud. 

We may also hold:  

• Disabilities or vulnerabilities – We use this information to tailor our service to better meet your needs. We may also use this information for safeguarding of staff. 
• Health information – when we require this to support funding for adaptations made to the property you are living in. More specific details are provided if you use this service. 
• Financial information –In order to ensure that arrears payments are settled quickly, we may collect additional information to help us to work out a payment plan with you. In addition, to provide welfare, benefits and debt advice as a free service to help you budget, pay your bills, or to apply for funding on your behalf. 
• Identification – Photo ID, bank statements, payslips or income details may be used during the processing of a house sale or purchase. 
• CCTV– We use CCTV in some of our locations and premises for protection of visitors and communities. When using CCTV, we comply with ICO’s CCTV Code of Practice and put notices up to inform when they are in use.  
• Photographs - We may take photographs at our events, at our properties and in our communities to use for general marketing and publicity. However, photographs of individuals will only be used for those purposes with your consent, which is held within our Communications Team. 

We will record information whenever you contact us or use our services and we will note any action taken, for example logging repairs, and feedback from our contractors about appointments with you, so that we have a record of what happened and of our contact with you.

Sensitive/special category personal data  

Under the data protection legislation certain personal information is classified as “sensitive” or "special category" personal data. This includes information relating to racial or ethnic origin, physical or mental health, sex life or sexual orientation, religious or philosophical beliefs, political opinions, membership of a Trade Union, allegations of criminal offences and criminal convictions and offences, along with biometric data such as fingerprints.

We minimise our holding and use of sensitive categories of personal information but, given the services we provide, there are times when we use it to understand our customers and their needs better, for example when providing accommodation for disabled persons or those with problems around substance abuse, when resolving neighbourhood disputes involving alleged criminal activity or when helping someone to access care services. We will usually be processing this information to allow us to comply with our legal obligations, act in the substantial public interest in relation to the services we provide, to provide you with social care, or to deal with any legal action. There may be times where we need to ask you for your consent to use this type of personal information, in which case we will always notify you and make this clear.

We collect most of our information directly from you, including when you apply for one of our properties or services, complete one of our forms, when you write, email, use our resident’s or job seekers’ portals, or meet with us, or respond to a survey. We may also process information that you post on social media about us if it relates to a situation that we need to be aware of and/or take action on.

We also collect information from other third parties, but only where is it relevant to our relationship with you. For example:

• Organisations that we have contract with to provide services on our behalf (our data processors), for example, maintenance and repairs, customer surveys etc. 
• Local authorities (councils), health and social care professionals, previous care providers – for information about your health, care and support needs, and those of your household (including your children) 
• Central government departments such as Her Majesty's Revenue and Customs (HMRC) - for taxation and/or fraud prevention, Home Office, local authorities – for information about your immigration status, or the Department of Work and Pensions (DWP) – for information about your benefits. 
• Former landlords for your rental history and references eg, rent arrears, evictions etc. 
• Credit reference agencies – for credit checks and information about your financial status/history when you apply for any Hyde Group property, for debt recovery purposes, and fraud investigations/data matching checks. For commercial tenants, we may carry out ongoing risk assessments on commercial viability using credit reference data. 
• Police forces and other public bodies such as fraud departments, enforcement authorities – eg, crime prevention, fraud prevention etc. 
• Other residents – if we receive information in relation to complaints about behaviour eg, noise nuisance, anti-social behaviour (ASB), safeguarding concerns etc.
• Relevant utility providers – where your heat/energy bills are included in your rent/service charge, we receive information about your energy usage.
• Managing agents – where they manage properties on our behalf.

1. To assess your property application and manage our contract with you
   We use the information we hold about you to manage your tenancy or leasehold. We need this to deliver our services to you. We collect most of this information because it is necessary in the performance of a contract. You will not be able to opt-out of providing this type of information.
   
   
2. To provide appropriate properties and services
   We process information that relates to your health and social care, to help us make any reasonable changes to our properties and services, to make them fit for purpose and accessible for everyone. We also use this type of information to make sure we are protecting vulnerable individuals in our communities.
   We do this to meet our legal and regulatory obligations, for example, the Equality Act 2010, and because there is a substantial public interest for us to do so.
   
   
3. To promote community safety and a peaceful community environment, and to safeguard individuals
   We process personal data to promote a peaceful and safe community environment; this can include information about anti-social behaviour, criminal activity/convictions. We process this information to prevent/detect unlawful acts, because it is necessary for the performance of a task carried out in the public interest, and/or for reasons of substantial public interest.
   We process information about safeguarding individuals, to fulfil our legal obligations and because there is a substantial public interest for us to do so.
   
   
4. To contact you about your property
   We use your contact details (including telephone numbers and email addresses) to get in touch with you about issues relating to your tenancy or leasehold and to deal with any legal matters arising from it. This includes repairs and maintenance, rent collection, complaints, and housing management issues, in the event of an emergency, or to enforce the terms of your tenancy or lease.
   We may pass on your details to contractors that provide services on our behalf, so that they can contact you to carry out essential services related to your property. We do this because it is necessary for the performance of a contract. It is not possible to opt-out of this type of data processing. Where we do not have the appropriate contact details for you, we may also try and source these externally from other third parties or public sources of information.
   
   
5. To contact you about other services
   We also use your contact details to keep you updated about our events or other services which do not form part of our contractual landlord service, but which may be of interest to you. Where contact for promoting these services is made via email, text, or any other form of direct electronic communications with you, we will seek your consent before sending you anything.
   
   
6. To investigate claims and complaints
   We will use your information to detect, establish and defend any legal claims we raise or is raised against us. We will also use your information including any contact made with us through email, portal, or phone calls to carry out investigations linked to complaints raised by you or another as part of our legitimate interest and legal obligations.
   
   
7. To prevent and detect fraud (Including illegal subletting and money laundering)
   We process some personal data to guard against fraud and illegal subletting, for example, proof of identity, data matching. Failure to provide any information we require in relation to this could put your application or tenancy at risk.
   We process this type of information to fulfil our legal obligations and to prevent and detect unlawful acts. In most instances, you are unable to object to this type of processing.
   
   
8. To monitor equality, diversity and inclusion
   We may ask you to provide us with your diversity data (ethnicity, religion, disability, sexual orientation). This information is not always used to inform any decisions we make about you individually but is gathered for statistical purposes to help us understand who is living in our communities. It helps us to ensure fairness and equality in the services we provide and allows us to fulfil our legal and regulatory obligations. You do not have to provide this information, (and there will always be an option of ‘prefer not to say’), but it helps us if you choose to do so.
   
   
9. Profiling
   We use some of your personal data to create a profile of you so that we can identify relevant services that might be of interest or helpful to you. For example, if information suggests that you might be having some difficulties with managing your finances, or we think you might encounter difficulties in the future, we can direct you to our welfare benefits and money advice team. Alternatively, if our information suggests that you might be a vulnerable tenant because of age, or ill health, we may offer you an enhanced service including welfare check calls.
   We use automated decision making to identify communication action and casework for arrears related matters as part of our legitimate interest of debt management.
   
   
10. Application for service or employment opportunity
    Where you have applied for a service or an employment opportunity, we will process the necessary amount of information to satisfy the entry to that process and fulfil services upon appointment as part of performance of that contract. (i.e., job seekers recruitment and interview selection etc).

1. To assess your property application and manage our contract with you by ensuring we:

• meet the needs of our customers when delivering our services to our residents,
• can contact residents in the event of emergencies and to carry out essential repairs,
• communicate with residents to meet our business objectives, encourage social inclusion, and help build communities,
• work with authorities and the police to support safer communities,
• remain commercially viable and protect our commercial and social assets,
• have effective procedures for preventing, and managing, outstanding debt for example from unpaid rents, service charges etc,
• make the most efficient use of our resources, and we understand how we are performing. This includes automating processes where appropriate to do so,
• understand our residents’ experiences and views so that we can effectively influence and contribute to debates on future housing strategies.

2. Provide you with services and benefits in both our legitimate interests:

• We will process your data to enable us to make informed decisions about proper management of our contract with you, and to provide you with the appropriate level of support in accordance with your needs by:  
• Offering help with debts and benefits advice.
• Assisting you in the management of account charges, payments, and arrears, including through our online portal.
• Providing support services to help customers achieve their goals. 
• Keeping in touch with customers to understand your needs and preferences and invite you to events. 
• Engaging with customers to make improvements to our products and services. 
• Through desired channel of choice where support services are available.
• Working with our partners including charities and local organisations to provide independent advice and advocacy services to support you.

3. Mergers, acquisitions, or reorganisation of business

We also have a legitimate interest in processing your data in connection with any mergers, acquisitions, or reorganisation of our business. Consequently, we may share some of your data with a prospective target organisation but only so far as is strictly necessary.

4. Customer Feedback

We work with residents by obtaining feedback on their experiences with us through the use of surveys. These surveys are carried out by contractors who are specialists in customer feedback. In such cases, we pass on your contact details to them so you that they can contact you and ask about our performance. It is in our legitimate interests to use your contact details this way, however, you may opt-out of further contact by letting the person requesting feedback know that you do not wish to take part in future.

5. Transparency of service charge costs

If you pay a service charge, we will contact you to inform you of the apportionment costs on the property. To demonstrate proportionality, transparency, and reasonableness in how we are recovering service charge costs, we may share your property address in the service charge statement with other relevant leaseholders. The lawful basis for this is that there is a legitimate interest in making this information available.

6. To contact you about other services 

We also use your contact details to keep you updated about our events or other services which do not form part of our contractual landlord service, but which may be of interest to you. Where this contact is made via post, we rely on legitimate interest, and you can opt out of further contact by contacting us.  

7. To support research and analysis 

We may use your personal data to carry out internal research and analysis. We do this to develop and improve our services and to help us understand trends within the housing sector. We process information based on our legitimate interests for these purposes.

8. Internal training, testing and operational improvements

We may use your records as part of testing new functions within systems, upgrades, or new ways of working. When doing so we rely on legitimate interest and we ensure only the minimum amount of data is used, and we have appropriate safeguards around its use.

9. Ensuring the security of our infrastructure and data.

We’ll hold your personal data on our systems for as long as it is necessary for the relevant activity or service we provide to you, or as required by law. We follow the data retention schedules set by National Housing Federation Guidance as best practice. Personal data forming part of your customer record is usually retained for six years after you are no longer a Hyde customer.

Where there are no defined retention periods set by legalisation or industry best practice, we will only hold your personal data for the purposes we originally stated. Once those purposes are met, we will either anonymise, or delete the personal data. We will only anonymise data (remove all data that can be used to identify you) when we believe there is an organisational value of that associated data, i.e., statistical data/ generic feedback data on repairs, complaints, and occupancy figures.

At times we might keep your data for longer, this is valuable to us in making good decisions now and in the future. We perform analysis, reporting and research in a way which ensures there’s no risk to you, and we continue to comply with our legal obligations. We take steps to de-identify your data, so it's anonymised or pseudonymised to ensure your confidentiality and we’re only keeping what is necessary.

Pseudonymised is a data process which enables scrambling or removal of key identifiers and replacement with generic reference numbers/text.

While we hold your personal data, we want to make sure it is accurate, up to date and well protected and that you understand how we use it. You can view and update your personal data using MyAccount.

Our subsidiaries 

Where needed, we share information with our subsidiaries, to make sure that you receive all the services available to you. This is done on our legitimate interest, and personal data does not leave the Hyde Group’s infrastructure.

Data Processors (suppliers/contractors)

We share some information with our data processors, which are organisations such as suppliers and contractors that carry out a service on our behalf. This includes repairs and maintenance, managing agents, gas servicing, pest control, out of hours support, customer feedback surveyors, credit reference agencies etc. We only share the information which is necessary for them to carry out the service they have been contracted to provide. All our contractors operate under the terms and conditions of a legally enforceable contract and will not use your information for anything other than carrying out a service on our behalf.
 
In most instances, we do this because it is necessary for the performance of a contract, ie, your tenancy or leasehold agreement. Where that does not apply, we process this information based on our legitimate interests.

Managing Agents/ Freeholders 

Where managing agents are acting on our behalf, we may share any information with them that is necessary for the effective management of the buildings, including any health and safety issues. Where other landlords (or managing agents acting on their behalf) are involved in the joint management of properties, we may also share the same information. 

We do this because it is necessary for the performance of a contract or in order to fulfil our legal obligations. Where this does not apply, we do this on the basis of our legitimate interests.

Ministry of Housing, Communities & Local Government (MHCLG)

We share information about social housing lettings data with the MHCLG as part of our CORE submissions (Continuous recording of lettings and sales in social housing in England). It is a regulatory requirement for all registered providers to supply this data as per the Tenancy Standard. The Tenancy Standard is a non-statutory code of guidance which we are obliged to follow.

The data sets we share include information on lettings, type of tenancy, rents and charges, demographic information about tenants (including special category data and criminal convictions) and financial information. The data set does not include names or addresses but does include the unique property reference and the full postcode.

This information is used for research and statistical purposes to allow the MHCLG to exercise their role in providing adequate social housing. The information cannot be used for any other purposes, such as making decisions in relation to specific individuals.

We share this information because it is necessary for the performance of a task carried out in the public interest and/or for reasons of substantial public interest. Individuals are not able to opt-out of this processing.

MHCLG have more information at Social housing lettings - GOV.UK about the process and who to contact if you have any concerns - CORE privacy notice.

Data matching organisations

We share some of our resident’s personal data with Experian, a consumer credit reporting agency. This is to help us prevent and detect fraud and illegal subletting. We also receive information about you from Experian for the same purposes. We process this information to fulfil our legal obligations and to prevent/detect unlawful acts. 

We occasionally participate in the National Fraud Initiative (NFI) data matching exercise carried out by the Cabinet Office. Our participation in NFI assists in the prevention and detection of fraud against Hyde and organisations within the public sector.  

The use of data by the Cabinet Office in a data matching exercise is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned. Data matching by the Cabinet Office is subject to a Code of Practice. 

Further information on the NFI is detailed in the Cabinet Office’s fair processing notice.

Other organisations  

Other organisations we may share your information with include:

• Local councils and government departments (including the Ministry of Housing, Communities & Local Government (MHCLG))
• Health and care services 
• Police and other law enforcement agencies 
• Electricity, water, and gas companies
• Fire services
• Regulator of Social Housing
• MPs and councillors acting on your behalf.

As Hyde Group is located within the UK, most of your personal data is processed within the UK and European Economic Area. Occasionally, we may need to transfer your personal data outside of the UK to other subcontractors or agents. For example, if we were to use an IT service whose servers are situated abroad. Where this is the case, we will take the appropriate steps to ensure that we only contract with organisations that have the appropriate security measures in place.

When procuring systems or services outside the UK and EEA, we will always look to use companies that have been granted adequacy decisions, and where required carry out an appropriate risk assessment to accompany any standard contract clauses we may adopt.

Access to Emails

When you contact Hyde either directly to a named individual or a shared mailbox, Hyde function on a need-to-know basis and that means anyone who needs access to a contact to carry out their role will be given it.

We also have admins and a EAs who manage senior management mailboxes.

Recording telephone calls

We may record your telephone calls to our Customer Contact Centres, for training and monitoring purposes and to make sure we’re delivering a good service.

We will also use these calls recordings, where we have them, as part of investigation of complaints or to support staff disciplinary matters.

We do not record all calls. We process data in this way because it is in our legitimate interests to do so.

Some of our locations and offices have CCTV and you may be recorded when you visit them. CCTV is used to provide security and to protect both our visitors and communities. CCTV will only be viewed when necessary (e.g., to detect or prevent crime) and footage is stored for a set period of time after which it is recorded over. The Hyde Group complies with the ICO’s CCTV Code of Practice, and we put up notices, so you know when CCTV is used.

We may take photographs at our events, at our properties and in our communities to use for general marketing and publicity. However, photographs of individuals will only be used for those purposes with your consent, which is held within our Communications Team.

You have several rights which allow you to choose and control how we use your data. These rights are explained below. If you would like to exercise these rights, please see Section 9: Who to contact.

Transparency

You have the right to be informed about how we are using your data. This Privacy Notice gives a general overview of the use of your data in Hyde and clear information about how your data is used whenever you interact with one of our platforms. More specific information about use of your personal data will be provided when we collect this from you and could be in the form of a notice of a portal/website or a statement on a form.

Access

You have the right to ask us what personal information we hold about you, in the form of a Data Subject Access Request (DSAR). You can make a request using the DSAR Webform to help ensure your request goes to the right team.

We manage our DSAR requests through an EU based third-party portal. We will provide all responses via this portal in an electronic format unless you request otherwise.

Please note, if we consider that the request is manifestly unfounded, excessive, or repetitive, we can charge a reasonable fee. This fee will be based on the administrative cost of providing the information. This right only relates to your personal data and so in most cases we will not provide any personal data of any third-party including contractors, other residents, or staff.

Rectification

If you think that the personal data, we hold about you is inaccurate or incomplete, you have a right to request that it be rectified. Remember, you can also update and check your personal data we hold anytime using MyAccount.

Erasure 

You can ask us to delete your personal data where it is no longer necessary for us to use it, where you have withdrawn consent (if we process based on consent), or where we have no lawful basis for keeping it.

Restriction

You can ask us to restrict the personal data we use about you where you have asked for it to be erased or where you have objected to our use of it.

Data portability

You can ask us to provide you, or a third party (if possible), with some of the personal data you have provided us over the course of your relationship with Hyde in a structured, commonly used, electronic form so that it can be easily transferred.

Objection

You can object to the processing of your personal data including when it is used for direct marketing.

You should note that this right does not apply in all circumstances, for example, where we are processing information because it is necessary in the performance of a contract we have with you, we will not be able to stop processing this information.

Automated decision making and profiling

We always take steps to ensure automated decision making and profiling at Hyde is done in a fair way but you can ask us to review any decisions that are determined by automated means. You can also object to our use of your personal data for profiling. These systems are used at Hyde to assist to identify data patterns for financial and welfare support.

The above rights, in most cases will be actioned within one calendar month, free of charge, and are subject to eligibility criteria. Where a request is complex, or you have submitted more than one type of requests at the same time, we may extend the response date by a further two months, but we will keep you updated if this happens.

You have rights which allow you to choose and control how we use your personal data. A full summary of these rights is outlined on the Information Commissioner’s Office (ICO) website.

We collect very limited personal data about our commercial tenants, as most of the information we collect is about your business. However, some personal data is collected about individual sole traders and individual shareholders and/or Directors of companies.

We collect most of our information directly from you when you apply, either directly to us or through our managing agent, to rent/lease a property for commercial business. We may also collect information about you, your shareholders and/or Directors from public sources using credit reference agencies.

We use the information we hold about you, your shareholders and/or Directors to manage your tenancy or leasehold. We collect this information because it is necessary in the performance of a contract. We also process some of your data because it is in our legitimate interests to do so. You can object to this processing if you think that your legitimate interests outweigh ours.

We do not usually gather information directly from children as part of our core landlord service. We may process information relating to children in our households where it has been provided to us during our relationship with you.

We process information relating to children for our community programmes/events where we have the consent of parents/guardians to do so.

There will be some occasions where we process your personal data for specific purposes which require your consent. If we do this, we will always ask for your consent. Where we are processing your personal data based on your consent, you have the right to withdraw that consent at any time. This may affect the services that we can make available to you, but this will be explained in the provided consent form for that processing.

Cookies are small text files which are transferred to your computer or mobile phone when you visit a website or app. Necessary cookies are used on this website which enable core functionality such as page navigation and access to secure areas. The website can’t function properly without these cookies and can only be disabled by changing your browser preferences.

Some cookies are used to make our website work better for you by adding accessibility features, such as the ability to increase or decrease font size, and the Google translate. We use others to anonymously track visitor behaviour so we can understand how the website is used to make improvements.

At any time, you can control the cookies you’re using with our cookie tool, which is accessed by clicking the small icon in the bottom right corner of the screen.

Please remember, this Privacy Notice only covers this website and the overall approach to how Hyde processes personal data. Any other services will have their own Privacy Notices and inform you of how your personal data is processed.

Hyde take the processing of your data seriously and will also take steps to protect and secure this information. It’s important to remember that even with all the good measures in place sometimes things can happen in error or outside of our control. In these cases, the InfoGov Team will ensure these incidents are fully investigated and steps are taken to resolve any issues and ensure there is no recurrence of the issue.

If you’re not satisfied with the way we’ve dealt with your personal data or have any questions, please let us know and we’ll try and resolve your concerns. You can contact us with a general enquiry or if you’re not satisfied with the outcome, you can make a formal complaint. Alternatively, you can contact:

• Data Protection Officer
  Zoe Ollerearnshaw, Group Company Secretary
  [email protected]

If you’re still not happy with our response, you have the right to appeal directly to the regulator – the Information Commissioner’s Office.

Should you wish to further exercise your Right of Access, please make a request using our Data Subject Access Request (DSAR) webform.

If you’d like a hard copy of this Privacy Notice or have any other questions regarding how to view this page, please refer to our Accessibility section.

The ASB team will be piloting an artificial intelligence tool called ‘Magic Notes’ for a period a 12 months, to help the team record accurate notes of conversations held in person or over the phone. They will ask for your consent before recording and then reaffirm your consent when recording has started, you will be provided with details of the processing including retention periods when you engage with them.

We also use machine learning modules for identifying patterns with arrears and to manage debt; to enable quick verifications of rent to Department of Works and Pension to ensure your housing costs are paid correctly, to aid in our internal data management practices, to help identify cases of potential housing fraud, and to support the security of our IT infrastructure.