Habinteg Housing Association Privacy Policy

Habinteg Housing Association is a controller of personal information for the purposes of the General Data Protection Regulation (GDPR).  Our contact details for data protection purposes are as follows:

Head of Governance, Habinteg Housing Association, Holyer House, 20-21 Red Lion Court, London, EC4A 3EB 

Purpose of Privacy Policy

This Privacy Policy tells you what to expect when Habinteg Housing Association processes personal information.  It applies to personal information about applicants, tenants and other customers. It tells you the purposes for which we may process your personal information and the legal basis for the processing (‘processing’ includes us just keeping your personal information)

How we use your data – Tenants and Housing Applicants

Why do we collect and store personal information?

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

We use your personal information for providing services in line with tenancy agreements and to respond to your enquiries and managing our relationship with you. We will also use the information to:

  • Check our services are fair and equal
  • Assist residents who have told us about particular needs
  • Improve the services we provide to you.

Your rights under the GDPR – Restriction on processing

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

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

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

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

How we manage your personal information

We process your personal information in accordance with the principles of the General Data Protection Regulation (‘GDPR’).

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

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

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

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

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

Periods for which we will store your personal information

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

Sharing your Personal Information

In delivering our services to tenants we will be required to share your personal information to our partner repairs and maintenance suppliers.  There may be times when we will share relevant information with third parties, including to meet legal requirements, for purposes as follows: 

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

  • to comply with the law (e.g. the police, Inland Revenue, Council Tax Registration Officer, Social Security Fraud Act) or a court order
  • where there is a clear health or safety risk to an individual or members of the public, evidence of fraud against Habinteg, other irregular behaviour or a matter Habinteg is investigating
  • in connection with court proceedings or statutory action to enforce compliance with tenancy conditions (e.g. applications for possession or for payment of Housing Benefit direct)
  • where Habinteg has entered into a formal protocol with the police or a local authority department
  • providing the name, address and contact number of a resident to contractors or other agents providing services on Habinteg’s behalf
  • providing the name of a resident and the date of occupancy to gas, electricity and water companies
  • providing information anonymously for bona fide statistical or research purposes, provided it is not possible to identify the individuals to whom the information relates
  • giving the name, address and stated local connection of applicants for housing to parish councils who are partners in exceptions planning agreements for housing which gives priority to people with a local connection
  • where the names and addresses of tenants are disclosed to payment system providers for the purposes of collecting rent. 
  • information required by the Regulator of Social Housing when monitoring Habinteg’s activities in its capacity as the regulator of housing associations.
  • to protect the vital interests of an individual (in a life or death situation)
  • If your household has entered a new social housing tenancy after 1989, social housing providers are required to share your personal information with the Government for research and statistical purposes. You can read more about this in the following guidance:  core-privacy-notice.pdf [pdf] 167KB.

When sharing personal information, we will comply with all aspects of the GDPR.

How we use your data – customers who order Habinteg Publications

Publications such as the Wheelchair Housing Design Guide can be ordered via our website. 

To place an order we will collect information necessary to fulfil the order, this will include address, email and phone details and may involve third-parties used to process your payment (ie Paypal) to whom we would pass your details for that purpose only who are contractually required to safeguard your data.

Data provided to us will not be used for any other purpose. 

How we use your data – updates on influencing work & joining campaigns

Those who sign-up to receive toolkit updates are asked to provide consent and will only receive email communications from us in relation to the toolkit or campaign you have expressed an interest in. 

Your rights under the GDPR - Access to personal information

You have a number of rights under the GDPR.

Under the GDPR, you have a right to ask us what personal information we hold about you, and to request a copy of your information. This is known as a ‘subject access request’ (SAR).

SARs need to be made in writing (we have a subject access form you can use for this purpose), to the Risk and Compliance Manager and we ask that your written request is accompanied by proof of your identify.

We have one calendar month within which to provide you with the information you’ve asked for (although we will try to provide this to you as promptly as possible).

Information will be provided free of charge, excessive or unreasonable requests may be asked to pay for the costs of providing the information.  

Your rights under the GDPR – Rectification 

If you need us to correct any mistakes contained in the information we hold about you, you can let us know by contacting the Risk and Compliance Manager at the London Office. 

Your rights under the GDPR – Erasure (‘right to be forgotten’)

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

  • the information is no longer necessary in relation to the purpose for which we originally collected/processed it
  • where you withdraw consent
  • where you object to the processing and there is no overriding legitimate interest for us continuing the processing
  • where we unlawfully processed the information
  • the personal information has to be erased in order to comply with a legal obligation
  • we can refuse to erase your personal information where the personal information is processed for the following reasons:
  • to exercise the right of freedom of expression and information;
  • to enable functions designed to protect the public to be achieved eg government or regulatory functions;
  • to comply with a legal obligation or for the performance of a public interest task or exercise of official authority;
  • for public health purposes in the public interest;
  • archiving purposes in the public interest, scientific research historical research or statistical purposes;
  • the exercise or defence of legal claims; or
  • where we have an overriding legitimate interest for continuing with the processing.

Your rights under the GDPR – Restriction on processing

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

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

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

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

Your rights under the GDPR –  Objection to processing

You have the right to object to processing where we say it is in our legitimate business interests.

We must stop using the information unless we can show there is a compelling legitimate reason for the processing, which override your interests and rights or the processing is necessary for us or someone else to bring or defend legal claims.

Your rights under the GDPR –  Withdrawal of consent

You have the right to withdraw your consent to us processing your information at any time.

If the basis on which we are using your personal information is your consent, then we must stop using the information. We can refuse if we can rely on another reason to process the information such as our legitimate interests.

Your rights under the GDPR –  Right to data portability

The right to data portability allows you to obtain and reuse their personal data for your own purposes across different services. It allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way.

The right only applies to personal data you have provided to us for the performance of a contract or information we have consent. It also only applies when processing is carried out by us using automated means.        

Your rights under the GDPR –  Protecting Personal Information

Personal information held by Habinteg is held securely in accordance with our data protection, confidentiality and information security policies and procedures.    

Telephone enquiries

For all tenant telephone enquiries, tenant identification will be verified using questions about the tenancies and date of birth.  Written permission wiIl be required if a tenant would like someone else to contact us on their behalf.

Online services

An online tenant portal may be used to access our services or make rental payments.  Online tenant accounts are secured using a Username and Password.

How Habinteg uses the information collected by cookies

Habinteg is committed to protecting your personal information.

This page answers some important questions about how we use cookies and how this protects your personal details.

How does Habinteg use cookies?

Cookies are small text files placed on a site visitor’s computer, which identify it to our server.

Cookies don’t usually identify individual users and are widely used in order to make websites work, or work more efficiently, as well as to provide analytical information to the owners of the site which is used to improve user experience.

You may delete and block most cookies from this site. Most web browsers allow some control of cookies through the browser settings.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

Please be aware that restricting cookies may impact on the functionality of this site.

Cookies used by VerseOne CMS

Our VerseOne Content Mangement System (CMS) - the software that powers this website - uses a "session" cookie at all times. The purpose of this cookie is to maintain the state of the site in the effect of a user's selected behaviours for the site as they navigate through it. Examples of these behaviours might be:

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This cookie also ensures that if the site is hosted in a load-balanced environment, the visitor’s browsing session stays on the same server throughout their use of the site.

This cookie does not store any personal information about the site visitor, their computer, their visit, or their browsing history. No personal information is collected by VerseOne through the use of this cookie.

After the end of the visitor’s session (the browser tab or window is closed, or after an inactivity timeout which is configurable in VerseOne CMS), the cookie’s validity is destroyed and the browser removes the cookie from the visitor’s computer.

Google Analytics

This site uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate your use of our site.

These cookies are used in aggregate form to improve the performance and user experience on our site. Google Analytics uses only first party cookies and collects no personally identifiable information.

Google stores the information collected by the cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.

Google will not associate your IP address with any other data held by Google. By accepting cookies from this site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

How to reject or delete the Google Analytics cookies

http://www.google.com/intl/en/privacypolicy.html

Read our Privacy Policy