Privacy

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.  It provides you with important information that we are required to give to you under the UK General Data Protection Regulation (UK GDPR).

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. Why do we need to process your personal information?

First Choice Homes Oldham is a registered co-operative and community benefit society with registration number 31138R with our registered office at First Place, 22 Union Street, Oldham, OL1 1BE.

We are a social housing provider with a vision of improving lives. Our commitment to improving lives is set out in our ‘Big Plan 2022-2025’ which is focused on four priority areas of delivering Great Services, Great Homes, Great Neighbourhoods, and being a Great Company.

We use your personal information to:

• Communicate with you about our services and your tenancy;
• allocate housing, provide housing management services, for community engagement, employment services and health and wellbeing services;
• provide associated advice and support;
• document our communications with you;
• make a tailored website and online services available to you;
• manage any registered account(s) that you hold with us such as My Account;
• verify your identity;
• address crime and fraud prevention, detection and related purposes;
• monitor, review and improve services and to carry our research;
• comply with our contractual and legal requirements;
• support and manage our employees, contractors and agents;
• enable our colleagues to interact with you when things go wrong.

2. What categories of personal information might we hold about you?

• Personal details and social circumstances such as your name, date of birth, national insurance number, identification documents, photographs, contact details and contact preferences
• Information you provide in support of an application for housing including references, pre-tenancy assessments, housing history and income details
• Next of kin details
• Details of other individuals living with you
• Details of complaints you make or complaints that are made about you or your household
• Financial details such as your bank details, benefit support, rent account details and income and expenditure assessments
• Education and employment details
• Health, safety and security details
• Visual images where we have CCTV
• Details of anti-social behaviour
• Repairs logs
• Welfare, wellbeing, employment, housing advice and support details
• Finance management, accounts and records
• Interactions with our employees, agents, and contractors
• Internal and external communications including telephone call recordings
• Enforcement activity

We may also collect the following “special categories” of personal information which is more sensitive:

• Information about your race or ethnicity, religious beliefs, sexual orientation, trade union membership and political opinions
• Information about your health including any physical and/or mental health condition and disabilities
• Information about criminal convictions, criminal offences or court proceedings.

3. How do we process your personal information?

We will only use your personal information when the law allows us to.  Most commonly, we will use your personal information according to the following lawful bases set out in the UK GDPR:

• Where we need to perform our contract with your, or take steps to enter into a contract with you;
• Where we need to comply with a legal obligation;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Where we have obtained your consent.

Where we process more sensitive “special category” personal information, our most common lawful bases set out in the UK GDPR are:

• Where we have obtained your explicit consent;
• Where we need to comply with a legal obligation; or
• Where it is needed for reasons of substantial public interest.

4. How do we manage your personal information?

Processing of your personal information will be undertaken in accordance with the principles of the UK GDPR and law in force in England. Our systems are protected to international security standards.

5. Who might we share your personal information with?

We will never sell or rent our customer’s information to other organisations for marketing purposes.

We will share information with 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.

We receive personal information from sources such as the local authority when our customers apply for housing.

In order to make certain online services available to you, we may share your personal information with some of our service partners that includes IT providers.

However, 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 below or required by law.

We may share your information with:

• Our partners who provide ‘First Choice Homes Oldham’ branded products and services (for example energy suppliers);
• credit reference agencies in particular where you are seeking to purchase a home from us;
• courts and tribunals to exercise our legal rights (for example in court cases);
• the police and other emergency services for the prevention, detection, investigation of crime or prosecution of offenders;
• external agencies for the protection of our employees and customers;
• our contractors, in order to undertake repairs, maintenance or improvement works;
• other housing associations, trusts and landlords, in connection with tenancy references and associated enquiries;
• with community partners in connection with the delivery of co-ordinated local services;
• utility companies and Council Tax Offices if they ask for your data and debt collection agencies, in connection with some housing applications or in relation to any outstanding charges;
• other statutory organisations, such as social services and health authorities, as necessary for exercising statutory functions;
• our professional advisers and consultants including insurers and solicitors;
• our regulator, the Regulator of Social Housing, to comply with our regulatory obligations;
• the Housing Ombudsman, to comply with our regulatory obligations;
• to protect the vital interests of an individual (in a life or death situation).

6. Transfers

It may sometimes be necessary to transfer personal information overseas. When this is needed information is only shared within the UK or the European Economic Area (EEA). Any transfers outside the UK or the EEA made will be in full compliance with the requirements of the UK GDPR.

7. 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. We will not normally hold any personal information for longer than 6 years after you have ceased to be a customer.

8. 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.

9. What Information Rights do you have?

Under certain circumstances, you may have one of the following rights under data protection law in relation to your own personal information:

• 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 to Processing;
• Rights related to Automated Decision making and profiling.
• Right to Withdraw Consent.

If you wish to exercise any of these rights, please contact us using the details set out below.

10. 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 October 2023.

11. What are our contact details?

If you have any questions in relation to this Privacy Notice or would like to exercise any of your data protection rights, our contact details are as follows:

First Choice Homes Oldham, First Place, 22 Union Street, Oldham, OL1 1BE

Telephone: 0161 393 7117 Email: tellus@fcho.co.uk

12. How can you make a complaint?

If you think our collection or use of personal information is unfair, misleading or inappropriate or if you have concerns about the security of your personal information, you have the right to make a complaint to the Information Commissioner’s Office (ICO). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

You can contact the ICO at the following address:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Or by visiting – 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.