Highstone Housing Association is committed to protecting the privacy and security of your personal information. Our aim is to only use and hold your personal data in ways that you would reasonably expect us to. We recognise our obligations under UK General Data Protection Regulation (“UK GDPR“) and we are committed to keeping your personal data safe and secure.
This Privacy Notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the UK GDPR. It applies to:
- All current and former tenants and residents, their households and their visitors;
- Applicants for housing; and
- Recipients of goods or services under a contract with a third party organisation that we fulfil on the third party’s behalf.
We reserve the right to amend this Privacy Notice from time to time. If we do, we will make you aware of this via updates posted on our website.
This Privacy Notice explains what happens with any personal data we gather from you in relation to:
- your use of our website;
- your application for a tenancy agreement with us;
- your tenancy agreement with us;
- your occupation of one of our properties;
- the provision of support by us to you;
- maintenance carried out by us in relation to our properties;
- any enquiries you submit to us; and
- dealing with any complaints you raise (including in respect of disrepair and anti-social behaviour).
It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using that information and what your rights are under the data protection legislation.
Who we are
We are Highstone Housing Association Limited (registered company number 08305529), based at 6 Churchfield Court, Barnsley, S70 2JT.
Highstone Housing Association is a ‘controller’, and is responsible for your personal data (collectively referred to as “Highstone“, “we“, “us” or “our” in this privacy policy). We are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this Privacy Notice.
Our registration number with the Information Commissioner’s Office is ZA161627.
We have appointed a Data Protection Representative to be responsible for overseeing questions in relation to this policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact our Data Protection Representative using the details set out below:
Telephone: 03330 388410
Email: GDPR@highstoneha.co.uk
Post: Highstone Housing Association Limited, 6 Churchfield Court, Barnsley, S70 2JT.
If you feel that our handling of your personal data under this notice and/ or your right to privacy has been compromised, you should contact us using the above contact details
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO“), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website 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 data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Data Protection Principles
We will comply with data protection law, which says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes. Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
What personal data do we gather about you?
“Personal data” is any information about an individual from which that individual can be identified. It does not include data from which an individual cannot be identified, for example anonymised data.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
| (a) Identity Data | includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, national insurance number, information about previous housing circumstances, current housing needs. |
| (b) Behaviour Data | includes a record of your compliance with your tenancy with us, information on your behaviour from partner agencies such as local authorities, policing bodies and other housing providers, and surveillance such as CCTV footage and noise nuisance. |
| (c) Contact Data | includes billing address, delivery address, email address, telephone numbers. Also including next of kin details, appointee contact details, support workers, power of attorney details or someone else authorised to communicate with us on your behalf. |
| (d) Financial Data | includes the amount of money you have paid us, any outstanding rent arrears and associated recovery action. Depending on your chosen method of payment, this could include back account details, welfare benefits payments information, earnings, income and expenditure (affordability) details, employment details, income and benefits, rents and service charge information |
| (e) Transaction Data | includes details about payments to and from you and other details of products and services you have purchased from us. |
| (f) Profile Data | includes who lives in our properties, purchases or orders made by you, your interests, preferences, feedback and survey responses |
| (g) Technical Data | includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. |
| (h) Usage Data | includes information about how you use our website, products and services. |
| (i) Communications Data | includes your communication preferences |
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We may collect more sensitive personal data which require a higher level of protection, as shown in the table below (``Special Category Data``).
| Special Category Data |
health, medical, disability and carer details race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data, criminal history, convictions and offences |
How do we collect your personal data?
We use different methods to collect data from and about you including through direct interactions, automated technologies and interactions, third parties and publicly available sources.Direct interactions
You may share data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you or someone acting on your behalf:
- Apply for our services.
- Subscribe to our service or publications;
- Request information to be sent to you;
- Enter a competition, promotion or take part in a survey; or
- Give us feedback or contact us.
Automated technologies and interactions
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Our cookies policy can be accessed here: https://www.highstoneha.co.uk/about-highstone-housing/cookies/
Third parties and publicly available sources
We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers, advertising networks and search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers or aggregator.
- Identity and Contact Data from publicly available sources.
How do we store your personal data and keep it secure?
We use reasonable and up-to-date security methods to:
- keep your data secure;
- prevent unauthorised or unlawful access to your personal data;
- prevent the accidental loss of or damage to your personal data.
All personal data is stored on our secure servers and in secure filing systems.
We have in place policies, procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction including procedures to deal with a security breach.
We will ensure your personal data is only accessible by those who need to see it for their specific role.
We will only transfer your personal data to a third party if that third party agrees to comply with our procedures and policies or if they have put in place equivalent policies and procedures of their own.
How and why WILL WE use your personal data?
We need all types of information to allow us to perform our contract with you and to enable us to comply with our legal obligations.
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform a contract we have entered into with you, or are about to enter into with you (for example, your tenancy agreement).
- 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 need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your, or someone else’s, interests (for example in a medical emergency).
- Where it is needed in the public interest or for official purposes.
We have set out at the link below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Who will have access to the data we hold?
Our personnel who need to access your personal data will view it in order that we can provide our services to you.
All of our personnel have received data protection training and understand the need to keep your personal data confidential and to use it only for legitimate purposes.
WHO MIGHT WE SHARE YOUR PERSONAL DATA 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. We also receive some personal information from other agencies that may be involved in providing care or support to you or someone who has authority to act on your behalf, such as the local authority, or power of attorney
Such information sharing is, necessary to comply with a legal obligation, necessary to protect the vital interests of yourself or another person, necessary for our legitimate interests and to allow us to perform or contract with you.
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 support services to you in line with the relevant Service Level Agreement.
- 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 if we are under a duty to disclose. 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), or to ensure your statutory health and social care needs are being met;
- our insurers and legal advisers, in relation to any claim, or in order to exercise our legal rights (for example in court cases);
- 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.
We may also disclose your personal information to third parties:
- if we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if we or substantially all of our assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets; and
We carry out due diligence on our service providers / group companies / other third parties and make sure we have a contract with them which satisfies the requirements of data protection legislation. 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.
If your personal data is provided to any third parties you are entitled to request details of the recipients of your personal data or the categories of recipients of your personal data.
Apart from the situations referred to above, we will not disclose your personal data to a third party without your consent unless we are satisfied that they are legally entitled to access your personal data.
How we keep your personal data accurate?
We will keep the personal data we store about you accurate and up-to-date. We will take every reasonable step to erase or rectify inaccurate data without delay.
Please tell us if your personal details change or if you become aware of any inaccuracies in the personal data we hold about you.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
How long will we keep your personal data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
If you have any queries regarding the retention periods for different aspects of your personal data, please contact our Data Protection Representative by email at GDPR@highstoneha.co.uk or by telephone on 01484 609189.
What rights do you have in respect of your personal data?
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
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- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, you must contact our Data Protection Representative by email at GDPR@highstoneha.co.uk or by telephone on 01484 609189.
Automated decision-making
We do not conduct automated decision making in connection with your personal data.
We do employ some profiling technologies that help to provide us with statistical analyses of our tenants and properties. We use these analyses to assist with the management of our properties and the running of our business. Whilst the analyses derived from the profiling are automatically produced, the results of the profiling are always reviewed by a human and any actions arising from the profiling are always determined by a human.
Transferring your data outside of the UK or the European Economic Area (“EEA”)
We generally do not transfer your data outside of the UK or the European Economic Area (EEA). However we do use cloud storage technologies or software with servers located outside the UK. If an international transfer of your data is required, we will ensure that such transfer is compliant with data protection legislation.
This means that we will not transfer any of your personal data outside of the UK or EEA unless the other country or international organisation ensures an adequate level of protection for your personal data.
Cookies
Our website uses cookies to distinguish you from other users of our website. These cookies sometimes process personal data. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website.
For detailed information on the cookies we use and the purposes for which we use them, please refer to our Cookie Policy https://www.highstoneha.co.uk/about-highstone-housing/cookies/
