Privacy Notice

Summary

This privacy notice will help you understand how we collect, use and protect your personal information. If you have any queries about this privacy notice or how we process your personal information, please contact our Data Protection Officer:  DPO@Homegroup.org.uk or get in touch with us by one of the other methods set out at the end of this notice.

Who we are

The organisation responsible for processing your personal information is Home Group Limited, charitable registered society no. 22981R, of 2 Gosforth Park way, Gosforth Business Park, Newcastle upon Tyne, NE12 8ET.  This means that we are a data controller under the General Data Protection Regulation (also known as GDPR) and the Data Protection Act 2018.

This privacy notice also covers our subsidiary companies Home in Scotland Ltd, Live Smart @ Home Ltd, and Home Group Developments Ltd and our property sales brand - Persona.

  • What information we collect about you

    • The personal information you have provided, we have collected from you or we have received about you from third parties may include:

      -  name, address and address history, date of birth, and gender (and proof of your identity/photo ID)
         your National Insurance Number
      -  contact details, including telephone number and/or email address
      -  financial information, including pay slips, bank details and credit/debit card details (although we do not retain complete payment card information)
      -  details about your family and dependents (e.g. your marital status and number of children) and anyone authorised to act on your behalf if applicable
      -  proof of housing eligibility, any interest or equity in other property
      -  information about your living circumstances (e.g. your employment details, income details and home ownership)
      -  Profile data including your preferences (for example when you are applying to buy a property from us), feedback and survey responses
      -  criminal convictions, information about alleged anti-social behaviour or fraud
      -  health details and medical history
      -  information about disabilities or vulnerabilities
      -  details about your race, ethnicity, religious beliefs, sex life, sexual orientation, political opinions,
      -  other personal information required to enable us to provide you with the service or support you have requested
      -  aggregated data such as statistical or demographic data which does not identify you individually
  • How we collect information about you

    • We may collect information about you in the following ways:

      -  when you apply for one of our properties or services or a job by completing an application form either manually or on-line
      -  when you register to receive information from us
      -  when you call, write, email, text or meet with us or respond to a survey or enter a competition
      -  when you log a repair request or pay your rent
      -  when you set up a direct debit
      -  automated technologies or interactions – when you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this  personal  information from you by using cookies and other similar technologies
      -  when you contact us on social media or use our LiveChat service
      -  when you make a complaint or provide feedback
      -  when you contact our Customer Contact Centre
      -  when we operate CCTV/sound recording systems for the detection and prevention of crime and to capture evidence of breach of tenancy or anti-social behaviour (appropriate notices will be displayed -  in locations with recording equipment in operation)
      -  when we take photographs at our events, at our properties and in our communities for general publicity use (we will only use photographs in which you can be identified if you have given us your written consent)
      -  when we receive information about you from third parties including local authorities, housing benefits offices, the police, welfare or support organisations, financial institutions, credit agencies, councillors, MPs or other representatives acting on your behalf 

      Phone calls to our Customer Contact Centre (CSC) are recorded for training and monitoring purposes and our recordings are usually kept for a period of six months.

  • What we use your information for and the legal basis for processing

    • We process information about you in order to understand, deliver and improve the service you require for example to manage your tenancy, to provide you with care and support, to sell you one of our properties or to manage your job application.

      The legal basis for processing your information is usually that the processing is necessary for a contract we have with you (e.g your tenancy or support agreement) or in relation to discussions before entering into that contract.

      We also sometimes need to process your information in order to comply with the law for example when we need to inform the relevant authorities about a benefits fraud.  

      In other instances, we may have a legitimate interest to process your information for our internal business and administrative functions. Other types of legitimate interest we might have in processing or sharing your personal information may include preventing loss of revenue and fraud prevention. For example we may pass your details to a debt collection agency if you have not paid your rent (in pursuit of our legitimate interest in preventing loss of revenue).

      The table below sets out the broad categories of information we process and the legal basis for processing it.

      Type of personal information

      Reason for processing this information

      Legal basis for processing

      Contact details e.g. name, address, telephone number and email address

      In order to contact you and for our contractors to contact you. We may also appoint a research company to carry out research on our tenants or communities in order to improve the Home Group

      Performance or preparation to perform a contract with you and legitimate interests

      Proof of Identity e.g. photo ID, NI number

      Proof of housing eligibility e.g. right to rent

      Legal obligation

      Financial information e.g. proof of income, bank account, credit/debit card details

      To assess your eligibility for housing or support etc. and enable you to pay your rent and set up a direct debit

      Performance or preparation to perform a contract with you and legitimate interests

      Information about your family, marital status, children, employment details etc. 

      To assess your eligibility for housing or support

      Performance or preparation to perform a contract with you and legitimate interests

      Criminal convictions

      To assess your eligibility for housing, for support or for a job etc.

      Legitimate interests, legal obligation (including for the prevention of crime and protection of individuals)

      Details of your preferences when you are applying for a property with us e.g. how many bedrooms etc.

      To tailor the search to your requirements

      Performance or preparation to perform a contract with you

      Information about your race, ethnic origin, religion, sex life or sexual orientation

      For monitoring purposes and to comply with employment law

      Legal obligation and to carry out obligations and exercise rights in the specific field of employment , social security and social protection law or explicit consent

      Information about your health and medical history

      To assess your needs or working capacity

      Performance or preparation to perform a contract with you and to assess the working capacity of the employee, to provide and manage health and social care services or pursuant to a contract with a health professional

      Information about potential anti-social behaviour and/or violence

      To safeguard our staff and contractors

      Legal obligation and legitimate interests       

      Information about disabilities or vulnerabilities

      To assess your needs or working capacity or to safeguard staff

      Legal obligation, performance or preparation to perform a contract with you and to assess the working capacity of the employee, to provide and manage health and social care services or pursuant to a contract with a health professional 

      Marketing and communications

      To keep our records updated and to study how you use our products and services

      Legitimate interests


  • Using your personal information for automated decision making and profiling

    • We use your rental payment history when we participate in the Rental Exchange project with Experian. Rental payment history is used to build a credit score to enable you to gain access to more affordable finance should you so wish.

      The information is held by Experian in a secure database which can be accessed by lenders and other service providers when you apply for a loan or service that requires a credit check or proof of identity.

      Rented and Shared Ownership customers’ rental payment history will be shared with Experian unless you ask us not to do so.

      You can request that we stop sharing your rental payment history with Experian by emailing DPO@Homegroup.org.uk.

  • Who we share your personal information with

    • Where relevant, given the nature of the services provided to you, we may also share your information with the following categories of third parties:

      -  our contractors and sub-contractors and other organisations acting on our behalf, including our maintenance contractors, social and health care professionals, our out of office telephone service contractor, our market research contractors, customer communication platform providers (such as Sendgrid and Twilio), on-line payment solution providers (such as Allpay and Capita), our mass mailing partners (such as Critiqom)
      -  we may appoint a research company to carry out research on our tenants or communities in order to improve a Home Group service, know more about our tenants/communities or establish if there are any gaps in what we are doing, on these occasions if contacted individuals can refuse to participate in the research without prejudice.
      -  managing agents
      -  local authorities, Choice Based Lettings (CBL) organisations
      -  social services
      -  the police
      -  government agencies and departments and regulatory bodies
      - COntinuous REcording of Lettings and Sales in Social Housing in England (CORE) – we are obliged to share tenancy data with the Ministry of Housing, Communities & Local Government via their CORE website. Please see their own Privacy notice for how they use your data.
      -  Experian (in relation to the Rental Exchange)
      -  utility companies
      -  mortgage brokers, financial advisors, surveyors and valuers relating to a property sale
      -  auditors
      -  commissioners
      -  tracing agents, debt collection companies and credit reference agencies
      -  other bodies for the prevention or detection of fraud

      We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We only permit our third party service providers to process your personal information for specified purposes and in accordance with our instructions.

  • Security of your information

    • We are committed to ensuring that your information is kept secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and operational procedures to safeguard and secure the information we collect online.

      When you make a payment online, for example when you pay your rent, we use a third party on-line payment solution provider such as Allpay or Capita to process the payment. These companies use an SSL (Secure Socket Layer) technology to protect your personal information. SSL is currently the preferred method to securely transfer credit card and other sensitive information over the internet. This encryption ensures that information sent during any transaction is protected against any unauthorised interception.

      We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  • Processing your information outside of the EEA

    • We will not transfer or store your personal information outside of the European Economic Area (EEA) unless:

      -  the country that we send the information to is approved by the European Commission as providing an adequate level of protection for personal information; or
      -  the recipient has agreed with us standard contractual clauses approved by the European Commission, obliging the recipient to safeguard the personal information; or
      another situation exists where the transfer is permitted under applicable data protection legislation. 
  • If you choose not to give personal information

    • We may need to collect certain personal information by law, or under the terms of a contract we have with you.

      If you choose not to give us this personal information, it may in certain limited circumstances delay or prevent us from meeting our obligations to you. It may also mean that we cannot perform the services you have asked for. In some circumstances, it could mean that we will need to terminate our relationship with you.

      We will always tell you at the time we try to collect such personal data, if your refusal to provide that data may impact on our ability to provide services to you.

  • Using your personal information for marketing

    • We may use your personal information to tell you about relevant products and services. This is what we mean when we talk about ‘marketing’.

      The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.

      We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

      We will only send you electronic marketing messages if we have your consent to do so and you can ask us to stop sending these marketing messages by following the unsubscribe link in any marketing email you receive.

      Whatever you choose in relation to marketing, we may still need to contact you for other reasons to enable us to provide the products and services you have asked for and to tell you about changes to your existing contract with us.

      We may ask you to confirm or update your marketing and contact choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.

      If you change your mind about your marketing contact preferences you can update your choices at any time by following the unsubscribe link in any marketing email you receive.

  • How long your personal information is kept

    • We will only keep your information for as long as necessary to fulfil the purpose we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements and in accordance with our retention and disposal guidelines.

      Please contact DPO@Homegroup.org.uk to request a copy of our Retention Guidance.

  • Your rights

    • Under the legislation you have the following rights in respect of your personal information:

      -  to obtain access to, and copies of, the personal information we hold about you i.e. to make a Subject Access Request (SAR) 
      -  to require that we cease processing your personal information if the processing is causing you damage or distress
      -  where we rely on your consent to process your personal information, you can withdraw your consent at any time by contacting our DPO at DPO@Homegroup.org.uk
      -  to require us not to send you marketing communications
      -  to require us to erase your personal information
      -  to require us to restrict or for you to object to our data processing activities
      -  to receive from us the personal information we hold about you which you have provided to us in a reasonable format specified by you, including for the purposes of you transmitting that personal information to another data controller (right to data portability)
      -  to require us to correct the personal information we hold about you if it is incorrect

      Please note that these rights may be limited by the legislation and we may be entitled to refuse requests where exceptions apply. You can find out more about your rights from the Information Commissioner’s Office:  www.ico.org.uk.

      Should you wish to exercise any of your rights, please contact our DPO by email DPO@Homegroup.org.uk or by using the contact details below.

  • Visitors to our websites

    • All of our websites use cookies. To find out more about how we use cookies, please see our cookie policy.

      Our websites may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave one of our websites, we encourage you to read the privacy notice of every website you visit.

      Our websites are not intended for children and we do not knowingly collect information relating to children.

      If you take a specific product from us, we have additional privacy information about those products. You can find out more by clicking the relevant links below.

      • Customers using our Persona website

      -  Persona is the sales brand and registered trade mark of Home Group Limited.

      -  By using the Persona website to access our services, including making an enquiry about or reserving one of our properties, you will be required to provide us with your personal information, including your name, address and contact details.

      -  If you provide any personal information relating to a third party (for example a joint purchaser or person living with you), you confirm that you have their consent to provide to us their personal information.

             

      • Customers using My Home Account

      -  When you create a My Home Account, we collect personal information about you to enable you to do things on-line such as pay your rent, report a repair, request help, set up and manage direct debits, manage your account, make a complaint or compliment, apply to rent a home or buy a home.

      -  The type of information we collect about you and what we need it for is covered in our overarching privacy notice.

      -  Within your My Home Account you are able to choose which services you wish to receive from us – such as payment reminders and helpful tips. We will also contact you about missed payments, account creation, tenancy allocation and repairs. All information we have collected will be available for you to review within your account.

      -  When you give us personal information, we take steps to ensure that it is treated securely. Any sensitive information, such as credit/debit card details is encrypted and protected with the following software – 128 Bit encryption on SSL. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.

      -  Where we have given you a password or you have chosen one yourself, to enable access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

        

      • Customers who contact us via social media

      When you contact us via social media such as Facebook, Twitter and Hotjar for example, we use a third party system called Conversocial to manage your queries. The system keeps a record of the conversation so that we can effectively manage customer service. 

      • Customers using our LiveChat service

      -  When you use our Live Chat facility, we collect information about the type of device you are using eg IOS or android etc.

      -  We also capture the IP address. During the course of the chat conversation, we may obtain personal information from you such as name, address, date of birth to help provide a resolution to your query.

      -  This information is then transferred to our primary housing management system OpenDoor to assist with raising repairs, obtaining information etc.

      -  A record of the chat is recorded within Zendesk (the livechat system) for training and quality purposes recoding a verbatim copy of the chat conversation. 


  • How to complain

    • We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about how we use your personal information very seriously. We encourage you to contact us with any concerns about how we collect and use your personal information. We would also welcome any suggestions for improving our procedures and policies.

      This privacy notice does not provide exhaustive detail of all aspects of our collection and use of personal information. We are happy to provide any additional information or explanation needed.

      Any requests for additional information should be sent to DPO@Homegroup.org.uk or to the address below.

      Any complaints will be dealt with in accordance with our complaints policy. You also have the right to make a complaint to the Information Commissioner’s Office at any time: www.ico.org.uk.

  • Changes to this privacy notice

    • We keep this privacy notice under regular review. This privacy notice was last updated on 24th May 2018.


  • How to contact us

    • If you want to request information about our privacy notice or exercise any of your data protection rights, please contact us in any of the following ways:

      Email our Data Protection Officer: DPO@Homegroup.org.uk

      Email our customer contact centre (non-urgent enquiries) using the enquiry form here.

      Telephone our customer contact centre (urgent enquiries): 0345 141 4663

      Write to our Data Protection Officer at:

      Home Group

      2 Gosforth Park Way

      Gosforth Business Park

      Newcastle upon Tyne

      NE12 8ET