Customer Privacy Policy (DP05)

Raven Housing Trust (Raven) needs to process personal information in order to deliver our services to you:

  • To provide, manage and develop affordable housing
  • To provide property management & property maintenance services
  • In the provision and management of support services
  • To market, sell and manage shared ownership homes
  • To deliver on our vision of ‘building homes, changing lives’

 

This privacy notice tells you what to expect when Raven processes your personal information. It applies to information about housing applicants, residents and other service users including visitors to our website.  It is important for you to read this policy in full to understand what information we hold about you, how we may use it and your rights in relation to your data.

Personal data is any information that relates to an individual who can be identified from that information. ‘Processing' includes the collection, recording, storage, use, disclosure or destruction of personal data.

The privacy of your information is important to us at Raven and we are committed to handling your information securely, respectfully and in line with data protection law.

Raven’s group structure includes the parent company Raven Housing Trust and subsidiary organisations such as Raven Repairs Limited and Raven Development Homes Limited.

We keep our privacy notice under regular review and we will make any updates available to you on our website.

 

Further information and contact details

For further information, you can contact Raven’s Data Protection Officer at:

The Data Protection Officer

Raven House,

29 Linkfield Lane,

Redhill,

Surrey,

RH1 1SS

DataProtectionOfficer@ravenht.org.uk

 

For independent advice about data protection, privacy, e-privacy and data sharing issues, you can contact the Information Commissioner.  (Lots of useful information is accessible on their website):

Information Commissioner,

Wycliffe House, Water Lane,

Wilmslow,

Cheshire  SK9 5AF

Phone: 0303 123 1113

Email: casework@ico.org.uk

Website: www.ico.org.uk

 

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.

We will collect most of the information 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.

The types of information we collect include:

  1. 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, copies of relevant identification documents, employment details, details about your home, your housing needs and tenancy agreement, rent and service charge information (including arrears details), financial information (including credit checks, income details, housing benefit information), any guarantor details, references received about you (e.g. from your previous landlord or your employer), information about any complaints by or about you, 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. We will ask for your specific informed consent at the time of collecting this type of data.  We will apply additional security and confidentiality measures when processing your sensitive personal information.  Raven 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 Raven may collect racial and ethnicity data for the purposes of monitoring equality, diversity and inclusion, 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.

Where you provide consent for us to process sensitive personal information, you have the right to withdraw this consent at any time.

We may also process confidential data about you including bank account information and property access codes.

 

Why we collect your personal information and how it is used

Raven has a “legitimate interest” in holding and processing your personal information 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.

 

  • We require this information 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.

 

  • We require information about household members because it is 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 including anti-social behaviour.
  • 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.

 

We require this information 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.

 

We require this information so that Raven can meet its legal obligations regarding health and safety compliance 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).
  • We require this information in order 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

  • Provision of information requested for this purpose is required in preparation for entering into ‘contractual relations’.  Without this information, we will be unable to manage this legal process.
  •  

When you engage with our additional guidance, advice and support services (Community Investment and Parashoot)

  • Our Community Investment or Parashoot teams 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 (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 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

  • It is in our legitimate interests to communicate with you about the services we provide to you and keep you up to date with events and news about the Group that we think will be of interest or use to you.  This kind of communication helps us to keep you informed and supports our objectives around social inclusion and building communities.

 

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.

 

Direct Marketing

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 receiving such marketing.

You can let us know if you would prefer not to receive these communications at any time by contacting our Customer Service team on 0300 123 3399 or at Raven@ravenht.org.uk.

 

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.  This should be done with your consent and knowledge of why they are making the referral to our services. External bodies such as the local councils are responsible for providing you with information pertaining to your rights, so please review their privacy policies for further information.
  • Our systems and processes (for instance, if we have CCTV in a communal part of the block in which you live, in line with our legitimate interests regarding crime prevention and health and safety requirements).

 

Who might we share your information with and why?

Sometimes we need to share personal information we hold about you with other organisations that we work with or who provide services on our behalf.  When sharing information we will comply with all aspects of data protection law.  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 Raven 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.  For instance, in certain circumstances we may be required to provide information about housing benefits to a local authority or central government department.

Some of the organisations that we may share personal information with include, but are not restricted to:

  • Our contractors to facilitate repairs, maintenance or improvement works.
  • Debt and money management advisers.
  • Local authority teams such as housing, social services, environmental health and benefit agencies.
  • Utility companies (and their representatives) and Council Tax Departments to ensure billing details are correct.
  • To another landlord or housing association where you are looking to move or exchange your property (e.g. where they request your details and/or a reference from us).
  • Independent mortgage advisers and solicitors.
  • Credit checking agencies, your bank and mortgage company or other financial institutions.
  • Third parties providing services on our behalf. For example a mailing company distributing our newsletter; a research company carrying out a customer satisfaction survey, or a debt collection agency pursuing former tenant arrears.
  • Resident representatives and board members involved in our complaints process.
  • A doctor, hospital, paramedic or health worker where you require medical attention and are unable to provide the information yourself.
  • Your next of kin or other people acting on your behalf in an emergency and a member of your church or religious leader, where you have requested this.
  • People or agencies who provide services to you or who work with us to provide services to you, such as your care/support provider.
  • Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative. More information can be found on the work undertaken by the Cabinet Office at: https://www.gov.uk/government/collections/national-fraud-initiative
  • The Housing Benefit department and other Government departments which provide funding for your housing or care/support services. In particular, we may be legally required to give information about any changes in your financial circumstances to the Housing Benefit department.
  • Our legal advisors, the courts and the police. This may include information about antisocial behaviour, which we may also share via a joint website accessed by landlords, the police, Social Services and other bodies with the aim of reducing anti-social behaviour.
  • Our legal advisers, the courts, the police and other relevant authorities (e.g. Department of Work & Pensions, Probation Service, HM Revenue and Customs) in relation to the prevention and detection of crime including anti-social behaviour, the apprehension of offenders or the collection of tax or duty.
  • Other statutory organisations e.g. social services, health authorities, Homes England, the Greater London Authority (GLA), the National Housing Federation, as necessary for exercising statutory functions.

 

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.

 

We don’t normally send data overseas

Raven’s business is conducted solely in the United Kingdom, so we do not normally transfer 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 appropriate safeguards are in place to protect your rights.  The only personal data that Raven transfers internationally is handled by SurveyMonkey and Mailchimp, which are both covered by the E.U-U.S Privacy Shield.

 

How long do we keep your data?

We hold a variety of data types, which each have different requirements for how long we need to keep them. 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 would like more information about this.

 

Security

We have appropriate security measures in place to prevent personal information from being accidentally destroyed or lost, or misused, disclosed or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know.

When we need to share personal data with our contractors, third party suppliers and business partners, our relationships are governed by our contracts with them, which include strict data sharing and confidentiality protocols.

To help us ensure confidentiality of your personal information we will ask you (and any of your representatives) security questions to confirm your identity when you call us and as may be necessary when we call you.

If a personal data breach occurs that affects you then we’ll inform you, without undue delay and no later than 72 hours of discovering the breach. In cases where there is a high risk to the rights and freedoms of individuals, Raven will be required, as per its legal obligations, to report a personal data breach to the Information Commissioners Office.

 

Website privacy and cookies

When you use our website, we will collect:

·Information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type, referral source, length of visit and number of page views);

·Information relating to any transactions carried out between you and us on or in relation to this website, including information relating to any purchases you make of our goods or services;

·Information that you provide to us for the purpose of registering with us including name, address, email, telephone number and the type of property you are looking for;

·Information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters including name, email address and telephone number;

·Any other information that you choose to send to us.

 

We will use this to:

·administer the website and improve your browsing experience by personalising the website;

·provide relevant website services, for example, raising a request for us to contact you, to report a complaint and to make payments;

·produce anonymous statistical information about our website users.

 

If at any time you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the permission you grant to us.

 

Raven is not responsible for the privacy policies or practices of third party websites accessed through links on our site.

 

Cookies are small text files that are sent by websites that you visit to recognise who you are when you return there. The files are stored on your computer’s hard drive, and are read by your web browser.

 

There are a number of options available so that you do not have to store any cookies at all. You can either set your browser so that it will not accept and store any cookies, or if you have a little more time and knowledge you are able to allow only certain ‘trusted’ sites to store cookies on your computer.  For further information visit: www.allaboutcookies.org.

 

What are your rights regarding your data?

Raven is committed to respecting your rights in respect of your personal data. The GDPR provides the following rights for individuals:

Right available

Description of right

The right in practice

Right of access

You have the right to obtain confirmation from Raven as to whether or not personal data concerning you are being processed, and, where that is the case, access to that personal data.

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. 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).

Raven 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.

Right to rectification

You have the right to oblige Raven to rectify inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed by providing a supplementary statement.

This will only apply to inaccurate personal data; information contained on your application form or any flags placed on your record. This will not lead to any personal data which you disagree with being rectified, merely personal data which is inaccurate or requires updating.

Please help us to keep our records accurate by informing us if your details change.

Right to erasure (also known as the “right to be forgotten”)

In some circumstances, you can ask Raven to consider deleting or removing personal data concerning you or to tell us that you object to our processing of your information where there is no compelling reason for it to continue. This will not include current tenancy details as necessary to fulfil our contractual obligations, or any information we are required to process under law.

The right to be forgotten only applies:

  • Where the personal data is no longer necessary
  • If you withdraw consent
  • If we unlawfully held your personal data
  • If you successfully object to our processing
  • If we have to follow a legal obligation to delete.

Right to restriction of processing

You have the right (under certain circumstances, but not all) to oblige Raven to restrict processing of your personal data. For example, you may request this if you are contesting the accuracy of personal data held about you.

This right only applies:

  • Where you contend the accuracy of any personal data until it has been made accurate
  • Where you have objected to any processing whilst we present our evidence
  • If we are processing anything unlawfully and you do not wish for it to be erased
  • If we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.
  • Where there are no legal obligations binding Raven.

Right to data portability

You have the right (under certain circumstances, but not all) to oblige Raven to provide you with the personal data about you which you have provided to in a structured, commonly used and machine-readable format.

You also have the right to oblige Raven to transmit those data to another controller.

This right only applies to data collected by automated means. As Raven does not currently undertake processing which is automated, we do not currently foresee any circumstances in which we would have to comply with this right. For a copy of your personal data, please carry out a subject access request instead.

Right to withdraw consent

If the lawful basis for processing is consent, you have the right to withdraw that consent. If you wish to withdraw your consent, contact us immediately.

 

 

Processing based on consent is likely to be limited to photographs at events, marketing information and in certain cases ethnicity or sexual orientation information.

Withdrawing consent will not affect the legality of any processing carried where consent were given i.e. leaflets distributed will not be recalled. 

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).

This right will apply instantaneously in most instances. If you would still like to receive marketing in one particular medium, please let us know. Raven still reserves the right to contact you regarding important matters unrelated to marketing i.e. chasing rent arrears or other important service updates.

Rights in relation to automated decision making and profiling

Raven does not perform any automated decision-making based on personal data that produces legal effects or similarly significantly affects you.

Unlikely to occur in practice; Raven does not carry out any automated decision making based on profiling. Where profiling is carried out without automated decision making, we will inform you where it crosses a certain threshold.

 

For more information about any of your rights, please visit:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

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

Wycliffe House

Water Lane

Wilmslow

Cheshire SK9 5AF

Helpline 0303 123 1113

www.ico.org.uk