Our Privacy Notice describes the categories of personal data we process and for what purposes. We are committed to collecting and using such data fairly and in accordance with the requirements of the General Data Protection Regulation (GDPR).
1 - Introduction
1.1 We take your privacy seriously. In this notice, you can find out more about your privacy rights and how we collect, use, share and secure your personal identifiable information. This includes the personal identifiable information we already hold about you now, and the further personal identifiable information we might collect about you. This can be collected either from you or from a third party. How we use your personal identifiable information will depend on the products and services we provide to you.
1.3 Our Mandatory Data Protection Officer (MDPO) provides help and guidance to make sure we apply the law to the processing and protection of your personal identifiable information. Our MDPO, Diane Raphael, can be reached by email at firstname.lastname@example.org or by post at Leverett House, Gilbert Drive, Endeavour Park, Boston, Lincs. PE21 7TQ if you have any questions about how we use your personal identifiable information.
1.4 See section 3 for more information about your rights and how our MDPO can help you.
1.5 This privacy notice provides up-to-date information about how we use your personal identifiable information and now updates any previous information we have published/supplied about using your personal identifiable information. If we make any significant changes affecting how we use your personal identifiable information, we will make changes to this privacy notice, and we will contact you to inform you of these changes.
1.6 This notice will apply from 25 May 2018.
2- Who we are
2.1 Where we refer to ‘we’ or ‘us’ in this Privacy Notice, we are referring to Longhurst Group.
2.2 Longhurst Group is the 'data controller' of your personal identifiable information because we determine the use of this information. As a registered social housing provider, we are regulated by the HCA’s regulation directorate, the Regulator of Social Housing.
2.3 Longhurst Group are a 'Group' of companies. In this Privacy Notice, when we refer to ‘Group’, we mean other members of our ‘Group’ of companies, including holding and subsidiary companies. View our group of companies and their ICO References here:
- Longhurst Group - Z5282684
- Keystone Developments (LG) Limited - Z7833811
3 - Your privacy rights
3.1 From the 25 May 2018, you will have eight rights relating to the use and storage of your personal identifiable information. These are:
- The right to be informed.
- The right of access.
- The right to rectification.
- The right to erasure.
- The right to restrict processing.
- The right to data portability.
- The right to object.
- Rights in relation to automated decision making and profiling.
3.2 In brief, you have the right to be informed who is obtaining and using your personal identifiable information, how this information will be retained, shared and secured and what lawful grounds will be used to obtain and use your personal identifiable information. You have the right to object to how we use your personal identifiable information in certain circumstances. You also have the right to obtain a copy of the personal identifiable information we hold about you.
3.3 In addition, you can ask Longhurst Group to correct inaccuracies, delete or restrict personal identifiable information or to ask for some of your personal identifiable information to be provided to someone else. You can make a complaint if you feel Longhurst Group is using your personal identifiable information unlawfully and/or holding inaccurate, inadequate or irrelevant personal identifiable information, which if used, may have a detrimental impact on you and/or has an impact on your rights.
To request information about yourself, please download the Personal Information Access Request Form
3.4 You can also make a complaint to the data protection supervisory authority. In the UK, this is the Information Commissioner's Office, at ico.org.uk. You can view other supervisory authorities and details of countries where your personal identifiable information is held and processed by Longhurst Group. See section 10.
3.5 To make enquires for further information about exercising any of your rights in this Privacy Notice, please contact our Mandatory Data Protection Officer, Diane Raphael by e-mail at email@example.com or by post at Leverett House, Gilbert Drive, Endeavour Park, Boston, Lincs. PE21 7TQ
4 - What kind of information do we use
4.1 We use a variety of personal identifiable information depending on the services we deliver to you.
4.2 Personal Information
- Contact details - name, address, email, home, work and mobile telephone numbers;
- Age – date of birth;
- Identification - information to allow us to check your identity;
- Credit information – information about your credit history;
- Photographs – information to record your identity;
- Online computer identification (IP address) – information recorded when you engage with us by email, use our website or My Account (online portal);
- National Insurance numbers – information to carry out functions such as universal credit and/or supporting people contracts;
- Information about your family, lifestyle and social circumstances
- Details about your behaviour
- Details about your employment status
- CCTV recordings – for anyone on our premises;
- Telephone recordings - for anyone calling us;
- Audio recordings – in an emergency situation where a member of staff is at risk of harm or abuse.
We may also collect the following information for occupants of your property (i.e those people who may live with you, but who have not applied or who do not receive for our services directly)
- Date of Birth
- Relationship to those receiving or applying directly for our services.
We also collect details of your representatives and/ or next of kin. (You should always seek their consent before providing us with this information.)
- Contact details – address, phone numbers, e-mail address
- Relationship to those receiving or applying directly for our service.
4.3 Special Information
- Health - to support our housing, care and support functions and vulnerable customers;
- Race – optional , and solely to support our equality monitoring purposes;
- Ethnic origin – optional, and solely to support our equality monitoring purposes;
- Religion – optional, and solely to support our equality monitoring purposes;
- Sexual life or sexual orientation – optional, and solely to support our equality monitoring purposes;
- Convictions – to prevent and detect crime, fraud, anti-money laundering and to aid in the prosecution and rehabilitation of offenders, and for your safety, and the safety of residents and staff.
There are other types of special information which we do not collect but are deemed important under the law:
- trade union membership;
- biometrics (where used for ID purposes.
For more information about the kinds of personal information we use for different services, see section 6.
4.4 Sometimes where we ask for your personal identifiable information to enter into a contract/agreement with you (for example: tenancy agreement, lease, housing application, support and/or care plan agreement) or to meet our legal or regulatory duties (for example: to process housing applications, council tax benefit, equality monitoring and/or government or housing regulator reports), we will not be able to provide some of our housing, support or products or services without this information.
5 - How we gather your personal information
5.1 We obtain personal identifiable information by various means. This can be by face to face, by email, telephone, correspondence and/or by receiving this information from others, for example: a local elected member who is representing you, police, health or social care agencies, benefit agencies. We can also receive information about you from other people who know you and/ or are linked to you, for example: relative, person nominated to act on your behalf or your legal representative.
5.2 Some further examples of how we may gather your personal identifiable information are set out below:
- Directly from you, for example: when you fill out a form either in hard copy or online. For example an application, transfer or mutual exchange form or as part of your right to buy application;
- by observing how you use our housing, support, products and services, or those of other members of our Group for example: from the transactions and operation of your accounts and on-line services;
- from other organisations such as former housing and support providers, health and social care agencies, law enforcement agencies, debt collectors, energy or utility companies, benefit agencies and/or credit reference and fraud prevention agencies;
- from other people who know you, including joint account holders and people who are linked to you or live in the same community as you with regard to reports of anti-social behaviour;
- from monitoring or recording calls as part of quality and complaints monitoring. We record these calls for training and to ensure the safety of our staff. We will not record any payment card details as part of our accounts and payments operations;
- from our CCTV systems for the prevention and detection of crime or to detect damage/vandalism to our properties and to ensure the safety and security of our staff and individuals obtaining services from us;
- from audio recordings from lone working devices where a member of staff feels they may be at risk of harm, or abuse.
6 - How we lawfully use your personal information
6.1 To provide you with our housing services we have a legal duty to confirm a person(s) has the right to reside in the country. We will need to obtain your name, contact details, date of birth, your current and previous countries of residence/citizenship, and a copy of identification documents (such as passport, home office residence papers and driving license).
6.2 We also need to collect proof of your immigration status and your identity for the government’s Right to Rent legislation.
6.3 We might also need health and social care information (such as physical, social or mental health information or medication) to help support our customers who have a vulnerability and/or receive a support or care service from us.
6.4 We sometimes need to gather, use and share your personal identifiable information for particular reasons, which are set out in more detail below.
To operate and administer our housing, support, care and repair products and services, including managing and responding to complaints:
- a) Contact details, household information, accommodation history, conduct of previous tenancies or similar agreements, benefits and income details , health, lifestyle to assess your eligibility for housing and /or to meet any care or support needs/ or assisting you in applying for disabled facilities grants or care and repair services.
- b) We use your name and contact information with third parties who help us deliver our repairs, support, care and housing services. For example, our repairs contractors and their appointed sub-contractors.
- c) Your contact details, health information and next of kin or representative details, for the provision of emergency alarms and monitoring services, and assistive technology services.
- d) Information about your health, wellbeing and lifestyle choices and preferences, to be able to provide management, care and support to you or refer you for appropriate support.
- e) Equality and diversity information to monitor access to and take up of our services.
- f) With your consent, Next of kin, or representative details to be able to contact them in an emergency such as where you are taken ill or where we need to contain someone because we need to enter your accommodation to carry out emergency repairs.
- g) Information about your complaints which we may be required to share with an MP, Councillor or recognised Complaints Panel acting on your behalf, as well as with the Housing Ombudsman or Social Housing Regulator.
- h) Information about the behaviour and criminal behaviour, or activity of you, your household, or visitors to be able to manage, support or tackle the victim(s) or perpetrators (s) of anti-social, behavior and provide our housing management services. We may share information with the police and other law enforcement agencies for the purpose of the prevention and detection of crime. We use CCTV and lone working audio recordings to detect and prevent crime.Contact details, income and health information to assist you in applying for disabled facilities grants and care and repair services.
We use your personal identifiable information in this way because it is necessary to meet the conditions set out in the contract/agreement with you and/or to meet our legal or regulatory obligations or because we have your consent.
- your contact details;
- your location data for fraud prevention and, if you have consented to it, mobile location services; and
- your IP address to identify you for security reasons.
We might share all of the information we use for this purpose with third parties who help us to verify your contact details and deliver our products and services, such as our subcontractors and our own service providers for ATMs and cash management, payment processing, other banks and regulators. We use your information in this way because it is necessary to perform our contract with you and to meet our legal obligations.
To administer payments to and from your accounts, and/ or in relation to payments owed to or due from other agencies (e.g. benefits agency and utility companies):
- a) Contact, household information and accommodation details, with benefit agencies and financial advisors who as agencies or financial organisations help us to process payments to your account(s).
- b) We may supply our appointed financial advisors with information to carry out home ownership affordability tests to advise on the suitability of a mortgage.
- c) To prevent financial crime, including money laundering, benefit or tax fraud or illegal subletting. This includes notifying local authorities, DWP where we believe a household is no longer entitled to benefit, or where we have suspicion of benefit fraud.
- d) Your contact details, address and agreement details to ensure that council tax and utility bills are paid by you or us. We will share your occupation details with utility companies and council tax, where you have not notified the relevant organisation of your occupation start or end dates.
We use your personal identifiable information in this way because it is necessary to meet the conditions set out in the contract/agreement with you and/or to meet our legal and regulatory obligations and/or where it is fair for us to do so.
To carry out our duties under health and safety and to support our vulnerable people and promote safe communities:
- a) Vulnerability indicators with contractors and sub-contractors to ensure services are tailored to meet your needs.
- b) Concerned / Warning / Lone Working indicators with contractors and sub-contractors to ensure health and safety measures are in place. We would have informed you of this indicator and when it will be applied and for how long, for example: A warning marker will be applied when an incident has occurred which results in a threat being made by you to a member of staff or contractor team.
- c) Criminal convictions such as sexual offences, violence or arson, which may mean you are at risk of harm, or that, you pose a threat to staff, residents or other communities if housed in certain types of accommodation or areas.
- d) CCTV and Lone working recordings to protect communities and staff
We use your personal and special identifiable information in this way because it is necessary to meet the conditions set out to meet our legal and regulatory obligations in relation to health and safety, and in the public interest, and/or for the prevention or detection of crime and/ or where it is fair for us to do so.
To report or share information with agencies where it is believed you or another person’s vital interests are at risk:
- a) Where you or another person is at risk of physical, mental or sexual harm or damage. Information may be shared with a health professional, social worker, emergency services or local agencies with a responsibility for Safeguarding.
- b) Where you or another person is in need of being protected as a vulnerable person from significant harm or serious exploitation.
We use your personal and special identifiable information in this way because it is necessary to meet our legal and regulatory obligations and to protect yours and others’ vital interests.
To carry out our lettings and home ownership affordability assessments, for grant purposes and former debt decisions about you:
- a) Information you give to us about your former addresses will be used to carry out a credit history check with approved suppliers (e.g. Experian). No credit ‘footprint’ will be left as part of this process.
- b) Information about those you are linked with in the proposed agreement or contract with us, for example, a joint tenant or owner.
- c) Information about how you or the person linked to you has former debts owing to us or other landlords which may prevent you form obtaining accommodation with us or limit your ability to pay your rent, management fees and or service charges.
- d) Information about your current earnings and outgoings to assess your ability to pay your rent or purchase a home, or as part of a grant application.
- e) We may also use credit agencies such as Experian to trace you, if you leave us owing a debt.
For these purposes, we share and receive information with and from banks, building societies, credit reference and fraud prevention agencies. The credit or fraud prevention agency might add details of our search to the records they hold about you, whether or not your engagement with us proceeds. The use of your information is based on our legal obligations or where it is fair for us to do so.
See a list of credit reference and fraud prevention agencies with which we engage in Appendix 1.
To carry out market research and analysis to develop and improve our housing, support, care and products and services;
- a) Contact and household information, including profiling information about those who have direct services from us such as age, gender, sexual orientation, ethnicity, religion, and disability. This information may be shared with third party contractors who carry out research or surveys on our behalf. This information is used to help us ensure we achieve results, which are representative of our customer base.
To promote the goods and services of the Longhurst Group and its member companies;
- a) Photographs and testimonials may be used with your consent in marketing and publication materials
- b) Where we have your permission, we will use your contact details to contact you about our goods, services or competitions.
To facilitate and undertake the work of our training academy;
- a) Your contact details so we can facilitate training and guidance
- b) Details of your educational achievements or attendance and / or employment status to help us provide training and guidance to you
We use your personal identifiable information in this way because it is necessary to meet the conditions set out in the contract/agreement with you.
6.5 Please see Appendix 2 to see a full list of our categories of suppliers.
7 - Automatic decision-making
7.1 Sometimes we use your personal identifiable information in automated processes to make decisions about you, such as credit scoring. We might also use automated processes to create a profile of you. We do this to help ensure decisions are made accurately, fairly and efficiently and to offer you services tailored to you.
7.2 We will inform you where your information is forwarded to Experian as part of the ‘Rent Exchange Scheme’ and we share information as follows:
Information about you to Experian as part of the ‘Rent Exchange Scheme’ including details of your rent payment history, your tenancy start and end date, your tenancy reference, your rent, and your rent balance, including any arrears.
8 - Our legal basis for using your personal identifiable information
8.1 We only use your personal identifiable information where that is permitted by the laws that protect your privacy rights. This will be where:
- we need to use the information to comply with our legal obligations;
- we need to use the information to perform a contract with you; and/or
- it is fair to use the personal identifiable information either in our interests or someone else's interests, where there is no disadvantage to you – this can include where it is in our interests to contact you about products or services, market to you, or collaborate with others to improve our services;
- where we need to seek your consent (if consent is needed).
8.2 Where we have your consent, you have the right to withdraw it. We will let you know how to do that at the time we gather your consent. See section 12, clause 12.2 for details about how to withdraw your consent to marketing.
8.3 Special protection is given to certain kinds of personal information that is particularly sensitive. This is information about your health status, racial or ethnic origin, political views, religious or similar beliefs, sex life or sexual orientation, genetic or biometric identifiers, trade union membership or criminal convictions or allegations. We will only use this kind of personal information where:
- we have a legal obligation to do so (for example to protect vulnerable people);
- it is necessary for us to do so to protect your vital interests (for example if you have a severe and immediate medical need whilst on our premises);
- it is in the substantial public interest;
- it is necessary for the prevention or detection of crime;
- it is necessary for insurance purposes; or
- you have specifically given us ‘affirmative’ consent to use the information.
9 - Sharing your personal identifiable information with, or getting your personal identifiable information for others.
9.1 We will share personal identifiable information within our Group and with others outside Longhurst Group where we needed so that we can make products and services available to you, market products and services to you, meet or enforce a legal obligation or right, or where it is fair and reasonable for us to do so. See section 6, How we use your personal identifiable information for more information.
9.2 Who we share your personal identifiable information with depends on the products and services we provide to you and the purposes for which we use your personal identifiable information. For most products and services, we will share your personal identifiable information with our own service providers such as our IT Suppliers, with credit reference agencies, repair contractors and agents, emergency care line providers, CCTV and lone working contractors who monitor visual and audio recordings, and fraud prevention agencies. See section 6, How we use your personal information for more information on who we share your personal identifiable information with and why.
9.3 Most of the time the personal identifiable information we have about you is information you have given to us, or gathered by us in the course of providing products and services to you. We also sometimes gather personal information from and send personal information to third parties where necessary for credit checking and fraud detection and prevention or marketing purposes. For example so you can receive the best offers from us and our partners. See section 6, How we use your personal information for more information on who we get your personal information from and why.
10 - Transfers outside the UK
10.1 We may need to transfer your information outside the UK to the USA and to companies, service providers, agents, subcontractors and regulatory authorities in countries where data protection laws may not provide the same level of protection as those in the European Economic Area, such as the USA.
For more information about how we transfer your data outside of the UK, see Appendix 4.
11 - How long we keep your personal information for
11.1 How long we keep your personal information for depends on the services we deliver to you.
11.2 To see how long we keep your data for, view our Retention List. See Appendix 3.
12 - Keeping your up-to-date
12.1 We will communicate with you about products and services we are delivering using any contact details you have given us - for example by post, email, text message, social media, and notifications on our app or website.
12.2 Where you have given us consent to receive marketing, you can withdraw consent, and update your marketing preferences by contacting us directly. Please contact us at firstname.lastname@example.org
13 - Your online activities
We share Information with the following for credit referencing and scoring:
We share information with the following for fraud prevention:
Local Authorities – Housing benefit and council tax departments.
Appendix 2 -& 3 List of Categories of Our Suppliers
List of Categories:
- Emergency alarm and telecare monitoring services
- Health and Safety Services
- Information technology infrastructure and software services
- Insurance Services
- Legal Services
- Lone working monitoring services
- Marketing Campaigns and Services
- Out of hours emergency response services
- Payment Systems and Services
- Professional Services
- Regulatory Monitoring and Services
- Credit Reference Agencies
- Repairs and maintenance services
- Sales Services
- Unsuccessful Applicants - Up to 12 months
- Existing customers- Whilst you receive our services
- Former Customers* - For up to seven years after the services from us has ended.
* For former customers whose service ended with us before 25th May 2018 the retention period may exceed 7 years. Our computers systems are under review so that we can delete or psuedonimise personal information.
Transfers Outside of the UK
We will only transfer your information outside of the European Economic Area (EEA) where the organisation processing your data has certified that it reaches the standards set out under the Privacy Shield. The Privacy Shield is a recognised set of security standards and assurances designed to protect your data. Although we only use product protected by Privacy Shield for limited amounts of your personal information, you should be aware that Privacy Shield does not provide the same level of privacy rights as that provided for by the General Data Protection Regulation 2016, or the Data Protection Act 2018. For more information about Privacy Shield click here.
Where we transfer your data outside of the EEA we will obtain your affirmative consent to do so if it is for marketing purposes. Some of your information is accessible to the software companies, and in some limited circumstances, law enforcement agencies outside of the EEA. In our case in the USA. We currently transfer some limited amounts of your personal information such as your name, email address and survey responses when we collect your feedback through software called Survey Monkey and set up email distribution lists and campaigns in software called MailChimp.