Customer Privacy Notice
We ask that you read this notice carefully as it contains important messages about the personal information we collect about you, what we do with your information and who your information might be shared with.
We ask that you keep your personal information accurate and up to date. If you cannot do this using one of our online services you can ask us to make changes to your personal information.
1. Who we are and how to contact us
First Choice Homes Oldham Limited (referred to as "us" and "we" in this notice) is a not for profit housing association.
We are a Co-operative and Community Benefit Society, registered with the Financial Conduct Authority as a Mutual Society under company number 31138R. We are also regulated by the Regulator for Social Housing under registered number 4582.
We are a 'data controller'. This means that we determine the purposes for which and/or the means of processing the personal information we collect from you.
If you would like to contact us about the way we use your personal information, any queries or requests should be directed to us via the following details: telephone: 0161 393 7117 or email: email@example.com
2. Why do we need to process your personal information?
We are a social housing provider with a vision of Improving Lives in Oldham. Our objectives are to build new homes, provide excellent landlord and support services, and creating thriving communities.
To meet our objectives we need to collect and utilise personal information from our applicants for housing, tenants and other occupants in order to effectively set up and manage tenancies. We may also use the data provided to build statistical information about the need and demand for social housing. This information will be anonymised and will not describe individual cases or list individual re-housing applicants.
We use your personal information:
- to determine eligibility and qualification for an allocation of housing;
- to set up a customer account;
- for our finance management, maintaining our accounts and records
- to provide housing management services;
- to provide coordination of services for vulnerable people;
- for community engagement;
- for employment and health and wellbeing services;
- to make a tailored website and online services available to you;
- to manage any registered account(s) that you hold with us such as My Account;
- processing rent payments;
- managing repairs and maintenance;
- to verify your identity;
- to address crime and fraud prevention, detection and related purposes;
- to monitor, review and improve services and to carry out research;
- to comply with our contractual and legal requirements;
- to enable our colleagues to communicate with you as necessary in relation to your property and tenancy.
- to enforce our rights and your obligations under our contract with you
3. What categories of personal information might we collect and hold about you?
- your contact details such as your name, address, telephone number and email address;
- details of your previous landlord and previous address(es);
- contact details for your next of kin, support worker or someone else authorised to communicate with us on your behalf;
- your date of birth;
- education and employment details concerning your current and previous employer;
- names and contact details of family members and other occupants, including any children who may be living with you;
- details of your social circumstances, including financial information, which may include bank details, salary and details of any employment and earnings;
- details of the health or social care needs of you or any other occupant;
- details of your race and sexual identity, for monitoring and statistical purposes, to promote equality and diversity;
- complaints you may make about the service we provide;
- Any medical and risk/safety information that is applicable, which may be held on other systems such as MyMove/Locata and Northgate;
- visual images of you, taken from those communal areas where we have CCTV;
- any of your personal information held on a housing waiting list;
- welfare, wellbeing, housing advice and support details;
- your interactions with our employees, agents, and contractors;
- internal and external communications including recorded telephone calls and any other notes/updates recorded following our contact with you.
4. How we comply with the law
We will only use your personal information in accordance with the General Data Protection Regulation and the Data Protection Act 2018 and any new law adopted by the UK following its departure from the EU (data protection law). The purposes for which we process your information are lawful based upon the following main grounds:
- In order to perform the contract between us, by discharging our obligations as a social landlord, or to take steps at your request prior to entering into a contract (for example when processing your application);
- In order to enforce our rights as a landlord under the tenancy, including but not limited to the pursuit of rent arrears;
- To comply with any legal obligations;
- To perform a task in the public interest in our capacity as a registered social landlord, by providing and managing social housing;
- In some cases, to pursue our legitimate interests to:
- Ensure that we are able to contact and communicate with you quickly and efficiently, in relation to the management of your property;
- Check your connection with the area, when you are making an application for housing;
- Check your credit-worthiness and financial standing;
- In order to understand whether you or any other occupants have needs for health and/or social care support, we need to collect some sensitive information about your health. This is necessary in order to provide you with social housing which is appropriate and suited to your needs, for reasons which are in the public interest, and in the exercise of our rights and obligations in social protection law, as a registered provider of social housing.
We may also ask you to provide us with information about your race or ethnicity, your religion and/or your sexual orientation. This is for the purpose of ensuring that your application is processed fairly and treated equally. Where this information is requested, your response is optional and we will only collect and process this information with your consent, which may be withdrawn at any time, by making a request to staff or by completing a 'change of circumstances' form. In the event that you do not wish to disclose this information at all, you have the option to select "do not want to disclose" on the application form.
Less commonly, we may have to process your personal information urgently and without notice to you, in order to protect your vital interests, or those of someone else (for example, in order to contact the emergency services to provide urgent medical or social care).
5. How do we manage your personal information?
Our systems are protected to international security standards. We ensure that your personal information is only accessed on a 'need to know' basis, and our staff are required to comply with our Data Protection Policy, when processing personal information.
We are Cyber Essentials Plus Certified. Cyber Essentials Plus is a Government-backed, industry-supported scheme to help organisations protect themselves against common online threats and to ensure that key technical controls are in effective operation in order to protect the personal information we process.
Access to our IT systems is strictly controlled and all of our staff who handle personal information undertake mandatory data protection training.
6. Who might we share your personal information with?
We will never sell or rent our customers' information to other organisations for marketing purposes.
Most of the personal information we collect is requested from you directly, when you complete a housing application. However, we also receive some personal information from other agencies that may be involved in providing care or support, such as the local authority, when customers apply for housing.
We will share personal information with the following types of third parties:
- our suppliers and service providers so that we can provide you with excellent services and maintain our contractual obligations to you, for example obligations under a tenancy agreement to repair your home;
- our partners who provide ‘First Choice Homes’ branded products and services (for example energy suppliers);
- our service partners, including IT providers, in order to make certain online services available to you;
- other contractors in order to carry out repairs, maintenance or improvement works;
- the local authority and the emergency services. For example this may mean providing the Police with information for the prevention, detection, investigation of crime or prosecution of offenders; and for the protection of our employees and customers, or to protect the vital interests of an individual (in a life or death situation);
- our insurers and legal advisers, in relation to any claim, or in order to exercise our legal rights (for example in court cases);
- credit reference agencies, in particular where you are seeking to rent or purchase a home from us, in order to carry out reference checks;
- other housing associations, trusts and landlords, in order to carry out tenancy reference checks and associated enquiries;
- community partners in connection with the delivery of co-ordinated local services;
- with utility companies and Council Tax Offices if you have left one of our properties and they ask for your data and debt collection agencies, in connection with some housing applications and in relation to any outstanding charges;
- with other statutory organisations, such as social services and health authorities, as necessary for exercising statutory functions; and
- with our regulator, the Regulator of Social Housing, to comply with our regulatory obligations.
When we share your information, we require our contractors to ensure they have appropriate data protection and security controls. We also impose contractual obligations on our contractors so that we can take action against them if things go wrong.
Aside from our contractors and service providers, we will not disclose your personal information to any third party, except as set out above or required by law.
Your personal information will be processed within the United Kingdom. Any transfers of data will be in full compliance with the data protection law currently in force and any new UK law adopted following the UK's departure from the EU. Should it be necessary to transfer your information outside of the EU, we will keep you informed, and will ensure that sufficient safeguards are in place to keep it secure.
8. Automated Decisions
Most of the decisions we make about you involve human intervention. We may make automated decisions about you in respect of awarding priority for housing in certain circumstances which is based on the information you provide on your online application form. Our document Your Information Rights outlines the procedure to ask us for an automated decision to be reviewed by an appropriate officer. This can be found at www.fcho.co.uk/your-information-rights
9. How long do we keep your information?
We will not retain your personal information for longer than necessary for the purposes set out in this Notice. Different retention periods apply for different types of information and the lawful basis for which we are processing it. We will not normally hold any personal information for longer than 6 years after you have ceased to be a customer.
10. What Information Rights do you have?
You have the following Rights that are detailed in our Information Rights documents on our website:
- The right of access to information that we hold about you (Right of Access)
- The right to have your information rectified, if it is inaccurate or incomplete (Right to Rectification)
- The right to request the deletion or removal of your information where there is no compelling reason for its continued use (Right to Erasure)
- The right in some cases, to restrict our use of your personal information (i.e. permitting its storage but nothing further) (Right to Restrict Processing)
- The right in some cases to request that we transfer your information directly to a new landlord or other third party (Right to Data Portability)
- The Right to Object to Processing
- Rights not to be subject to decisions made automatically through the use of technology and without human consideration, where this produces a legal or similar effect upon you (Automated Decision making and profiling)
If you would like to exercise any of these rights, please contact us via the following details: telephone: 0161 393 7117 Email: firstname.lastname@example.org
We may sometimes process your data for specific purposes which require your consent. If we do this we will always ask for your written consent. Where we are processing your personal data based on your consent, you have the right to withdraw that consent at any time. This may affect the services that we can make available to you but this will be explained at the time we ask for your consent.
11. Keeping this notice under review
We keep our Privacy Notice under regular review and we will place any updates on our website.
This Privacy Notice was last updated in March 2019.
12. What are our contact details?
Contact details for feedback, any questions in relation to this Notice or your rights in connection with it are as follows:
First Choice Homes Oldham, First Place, 22 Union Street, Oldham, OL1 1BE
Telephone: 0161 393 7117 Email: email@example.com
We would like the opportunity to address any complaints you have in the first instance about the way in which we have handled your personal information – please contact us via the details above. You do however have the right to complain at any time to the Information Commissioner's Office (ICO), Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF 0303 123 1113 / www.ico.org.uk
13. Can we explain the jargon?
Personal information is information about a living individual, which is capable of identifying that individual. This is sometimes called personal data.
Processing is anything done with/to personal information, including storing it.
The data subject is the person about whom personal information is processed.
The data controller is the person or organisation who determines the how and why of data processing.