The privacy of your information is important to us at Hyde and we are committed to handling your information securely, respectfully and in line with data protection law. The purpose of this notice is to tell you what to expect when Hyde processes the personal information (‘personal data’) we collect when you become one of our customers or each time you contact us.
Personal data is any information which relates to an individual who can be identified from that information. ‘Processing' includes the collection, recording, storage, use, disclosure or destruction of personal data.
Who we are and our contact details
Where we refer to 'we', 'us' or 'our' in this policy, this refers to Hyde Housing Association Ltd (“Hyde”) and its subsidiaries: Martlet Homes Ltd, Hyde Southbank Homes Ltd, Hillside Housing Trust Ltd and Hyde Vale Ltd together described in this document as “the Group”.
This privacy notice applies to the Group, its partners, and contractors acting on its behalf. Additionally, some service areas within the Group may provide additional privacy notices when you register or engage with them.
For further information, please contact our Data Protection Officer at the following address.
The Data Protection Officer
Hyde Housing Association Ltd
30 Park Street
London SE1 9EQ
The information we collect
We will make every effort only to collect the personal information we need from and about you. The type of information we collect will vary depending on the service we offer to you.
Most of the information we hold will be collected directly from you, but we may also obtain information from another person or organisation if you have given permission for them to share it with us. This could include a local authority, your previous landlord, your doctor or other health professional. In addition, we may also obtain your information from available public sources.
Types of information we collect
(a) Personal data - This is any information that can be used to identify you, for example, your name, address, date of birth, NI number, email/postal address, telephone number, credit/debit card, bank details, as well as information relating to your health or personal circumstances.
(b) Special categories of personal data - This is sensitive personal information, for example your racial or ethnic origin, religious beliefs, other beliefs, sexual orientation, health information, political opinions and so on. Hyde would only collect your sensitive personal information where there is a clear need for us to do so, such as to assess what services are relevant to you or to offer appropriate support to you. Additionally Hyde may collect racial and ethnicity data for the purposes of monitoring, but such data will be anonymised before appearing in any monitoring reports. Before collecting any sensitive personal information about you, we will always try to make it clear to you what information we are collecting, and the reason for collecting it. If you have any questions please ask us.
Why we collect your data and how it is used
The Group has a “legitimate interest” in holding and processing your personal data in order to deliver our services to you and your household members and to properly manage our business.
In some circumstances we might hold your information for other reasons – for instance because we are under a legal obligation to hold certain information about you, or because holding the data is necessary for the purposes of a contract we have with you (such as your tenancy agreement or lease). When we ask you for information, we will state clearly why we need it. We use the information we collect from or about you (as applicable) in various areas of work, including:
Assessing and processing housing applications, service eligibility and completing tenancy sign-ups
- We will need your personal information, including your name, contact details, telephone numbers and email addresses for use across the Group and by our contractors and partners.
- We will collect detailed personal information about you and other household members including age, sex, date of birth, ethnicity, National Insurance number, income and benefits details, employment status, gender identity, relationship status, any disabilities, any communication and accessibility requirements, religion, sexuality, nationality, caring responsibilities, access to financial services such as banks and credit unions, bank details, council tax, medical information and details of any unspent criminal convictions.
This information is required as we will be unable to accept an application for services without it. For example, we would need to verify your identity to ensure an application is genuine. Please speak to us if you have any concerns about this.
Information on household members is required as it is also in our legitimate interests to know who will be living in our premises, and to ensure the property offered is adequate for the needs of the household. We assume any information you provide about household members is provided with their full knowledge and you should direct your household members to this policy.
Management of properties (tenancy or lease)
- Your up-to-date contact details (telephone number and email address) are required so we can get in touch with you to discuss issues regarding your tenancy or lease, for example collection of rent or other sums, receipt of benefits, essential servicing, access for maintenance and repairs and other service delivery. We may need to provide your contact details and relevant associated information to our contractors who may be undertaking work on your property on our behalf.
- We may use your contact information to inform you of changes to the Group or to investigate and resolve complaints or any other housing management issues.
- We will ask you for supporting documents to effect changes to your tenancy, such as a copy of your marriage certificate or deed poll certificate to change your name on our records, or supporting medical evidence to reassess any change to housing requirements as a result of a medical need.
- We will hold records of all our contact with you, your contact with us, and any contact from third parties representing you or about you.
- All financial records including the amount of money you have paid us, any amount(s) outstanding and associated recovery action will be held by us and, depending on your method of payment; we may hold your bank account details.
- We may hold information about your history, for example regarding credit status or offences, if we decide this is required to help us look after our staff, business or anyone else.
- We also record information about repairs, maintenance, and servicing requirements of your home although this information will not necessarily constitute your personal data. We may need to provide this information in particular to our contractors.
This information is required as we will be unable to provide your services effectively without it. For example, we will not be able to contact you to arrange the provision of a service like essential servicing required to your home if we do not hold your contact details. Please speak to us if you have any concerns about this.
To assist with personal security and prevention and detection of crime
- We may capture your image on our CCTV systems if you visit an estate, office or community facility which is covered by this service.
This information may be required for the Group to meet legal obligations on health and safety and crime prevention.
To prevent fraud and illegal sub-letting and to confirm eligibility for housing
- We will require your proof of ID and take your photograph from time to time, for example, for Tenancy Audits, when the housing composition changes or after a reasonable period of time has passed (this applies to all household members over the age of 18).
This information is required in order for us to meet our legal obligations as we may not be able to provide services to you if we are unable to verify your identity.
To manage the legal proceedings or legal process if you apply to buy your home or want to access another home ownership route
This information is required to manage the legal process needed in preparation for entering into contractual relations.
When you engage with our additional guidance, advice and support services (Hyde Foundation)
- Our Hyde Foundation team may offer you support to help you have a successful tenancy. This could include advice to improve your financial circumstances, or help to access training or employment. We may hold information about your job history, skills, education, and experience; or if we support you to improve your financial circumstances, we may hold detailed information about your household income and expenditure.
To understand how we’re performing (call centre recordings, satisfaction surveys, complaints)
- To help us monitor our performance and improve the service we provide, we may use your contact details to carry out customer satisfaction surveys, market research and to manage and analyse complaints.
- We may record calls for training and quality monitoring purposes, when you contact our customer service centre. Call recordings will be deleted once reviewed or no later than 6 months after recording.
- We may use your information for equal opportunities monitoring and research. This information is required to help us to understand how we are performing so we can achieve our service standards to you.
Keeping in touch, understanding your needs and inviting you to events
We may wish to communicate with you and keep you up to date with events and news about the Group which we think will be of interest or use to you.
If you are an engaged resident (i.e. in contact with our Resident Engagement Team) we may use your personal information to invite you to comment on the Group’s activities, for example on our services or proposed new service offerings.
For regulatory purposes in order to meet the requirements of the Group’s regulator - Regulator of Social Housing
There may also be a legal obligation for us to process the information or to demonstrate to our regulator that we are fulfilling our regulatory and statutory obligations.
With your consent (or because you have used or been interested in similar services from us previously), we may use your information to send you communications about opportunities or other housing related services which we think will be of interest to you. Our forms have clear marketing preference questions and we include information on how you can say ‘no’ to receive such marketing.
You can let us know if you would prefer not to receive these communications at any time by calling our Customer Service team on: 0800 3282 282.
Where do we obtain your personal information from?
We typically obtain your personal data from:
- You yourself, and your household members (for instance because you have provided us with that information in the course of applying for a tenancy)
- Central or local government (for instance because they are sending us information about your entitlement to benefits)
- Our systems and processes (for instance, if we have CCTV in a communal part of the block in which you live).
Who do we share your data with and why?
We will not disclose personal information about you to other parties except where we have a legitimate interest or other good reason to do so or where you have given us your consent to disclose (if required). We will never sell your personal information to any third parties or send you marketing information if you do not wish to receive it. Information is shared across the Group to ensure that you are receiving all the services that are available to you. We may also share your information with our trusted service providers who are authorised to act on our behalf, such as our maintenance contractors, or others who provide services to you such as local authority benefit departments.
There may be additional situations where it is necessary for us to share some of your information with others. Where this is the case, we will only make such disclosures when they are in line with our powers or obligations under the General Data Protection Regulation (“GDPR”) or where they are required by law. Some of the organisations that we may share personal information with include, but are not restricted to:
- Legal advisers
- Emergency services
- Government departments including local authorities
- Welfare advisers
- Medical professionals
- Other housing associations
- Utilities providers
- Market research companies for the purposes of conducting customer satisfaction surveys on our behalf to improve our services.
We ensure the organisations above and any others we might share information with understand that the personal information provided must be used for the reasons we have specified and must be kept safe and secure. Our relationships with some of these organisations are also bound by contractual data sharing agreements.
In some cases we may be legally required to provide information to one of these other organisations – for instance, in certain circumstances we may be required to provide information about housing benefits to a local authority or central government department.
Why we share your information
- To provide you with required services
- We are required to do so by law
- For customer research purposes
We may sometimes be required by law to share information enforcement or other statutory agencies, without your consent, for the purposes of:
- Crime prevention or detection or matters of national security
- Taxation/fraud reasons (including housing fraud)
In any other instances, your personal information will not normally be shared with any other third parties, unless it is in Hyde’s interests to do so or your explicit consent has been granted.
We don’t normally send data overseas
Our business is based solely in the United Kingdom, and so we do not ordinarily send data overseas. We may sometimes make use of cloud-based systems to support the management of our business. Where this happens we will ensure that there are appropriate safeguards in place to protect your right.
How long do we keep your data?
We hold a variety of data types, which have different requirements for how long we need to keep it. We have a data retention schedule that describes the type of data we hold and their retention timescales. We follow legal requirements and best practice in this area. We will securely destroy / delete personal data when we no longer need it or no longer have a legitimate interest in keeping it.
Please contact us if you’d like any more information on this.
What are your rights regarding your data?
The Group is committed to respecting your rights in respect of your personal data. The GDPR provides the following rights for individuals:
The right to be informed
We will be open and transparent about how and why we use your personal information. We do that as far as we can through this policy, and through other documents and signage.
The right of access
You have a right to ask to see the personal information we hold about you and ordinarily the right to have a copy provided to you or someone else on your behalf. A request to see this information is known as a ‘subject access request’ (“SAR”).
SARs need to be made in writing to the Data Protection Officer using the contact details above, and we ask that your written request be accompanied by proof of your address and identity. Alternatively you can use our online form. If you require specific information, it is helpful if this is clear in your request, for example, information from a particular time period or about a specific correspondence. If someone is requesting information on your behalf, they will need written confirmation from you to show you consent for us to release this and proof of ID (both yours and theirs).
Hyde will provide a copy of the information requested free of charge. However, we can charge a ‘reasonable fee’ when a request is manifestly unfounded or excessive, particularly if it is repetitive. We may also charge a reasonable fee to comply with requests for further copies of the same information. This does not mean that we will charge for all subsequent access requests. The fee charged will be based on the administrative cost of providing the information. We will seek to provide you with the information you have asked for within one month, although in certain circumstances it may take longer to provide you with some or all of the information you have asked for and we will try to keep you updated about this as promptly as we can. The data provided to you will be a copy of the information we hold that relates to you, this will not generally include information about your property, for example, repairs logs or contractor visits, as this is unlikely to constitute your ‘personal data’. However, should you wish to receive this, please clearly state this in your request.
The right to rectification
You can ask us to correct your personal data if it is inaccurate or incomplete. Please help us to keep our records accurate by informing us if your details change.
The right to erasure
This is also known as ‘the right to be forgotten’. In some circumstances, you can ask us to consider deleting or removing personal data or to tell us that you object to our processing of your information where there is no compelling reason for this to continue. However, we will need to consider the circumstances of any such request and balance this against our need to continue processing the data. We may decide to override this request in certain circumstances. Please contact us to discuss your options.
The right to restrict processing
In some circumstances, you may ask us to restrict the processing of your personal data.
The right to data portability
This right allows you to obtain your personal data from us and reuse it for your own purposes for different services. If this situation arises, you may be able to ask us to do this.
Please contact us to discuss further.
The right to object
As we are generally relying on our 'legitimate interests' as a reason for processing your personal data you can inform us if you object to our processing of your personal data. We can override this objection in certain circumstances.
You can also object to the processing of data for the purpose of direct marketing (including profiling).
Rights in relation to automated decision making and profiling
Automated decision making and profiling - There are some occasions where automated decisions are made about you using pre-programmed criteria on our systems, for example, eligibility for mutual exchange.
You have the right to challenge the validity of any decisions made in this way and ask us to review this. You may also ask us not to process your information in this way. Please contact us at DataProtection@hyde-housing.co.uk if you would like to discuss this with us.
Changes to this Privacy Notice
This Privacy Notice will be kept under review and updated as required. We recommend that you keep up to date via this website. We will let you know if we make any major changes to this Notice. The current version was first published on 23 April 2018.
Our data sharing agreement 2018 (PDF, 169KB) is the Privacy Notice for tenants or buyers of new social housing.
Your right to lodge a complaint with a supervisory authority
If you are not satisfied with our response to any query about your personal information that you raise with us, or if you believe that we are processing your personal information in a way which is inconsistent with the law, you can complain to the Information Commissioner’s Office (“ICO”).
Please also contact the ICO if you require general advice on privacy and any data protection issues.
The Information Commissioner’s Office
Cheshire SK9 5AF
Helpline 0303 123 1113
Terms and conditions of using our website
You can access and browse our website without disclosing information about yourself.
We're very serious about protecting your privacy. If we ask for information about you, we take all possible steps to keep it safe.
If you choose to complete any of our online forms we will need some personal information to allow us to deal with your enquiry. This information will be used only for the purpose for which you provided it.
No personal information you've given us will be passed on to third parties for commercial purposes. We will treat any personal information you may have provided in accordance with the provisions of the General Data Protection Regulation 2018 (GDPR).
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© Hyde Housing Association Ltd
The Hyde Group
30 Park Street
Registered under the Co-operative and Community Benefit Societies Act 2014 No 18195R with exempt charitable status.