Privacy

Arches Housing Privacy Information

Arches Housing respects the privacy of its residents and customers.  Your contact with us generates records including records of some personal information that is subject to the General Data Protection Regulation 2018 (GDPR). This privacy notice explains our approach to data protection.

How we collect personal information

We collect information in a variety of ways including via the website, on various forms, and contracts, and through our ongoing contact and correspondence with you, with other support agencies that relates to you, and from people associated with you such as family, friends and neighbours. We record calls to and from our office.

If you provide us with personal information relating to members of your family or your associates we will assume that you do so with their knowledge and consent. Information you give us relating to those that live with you will be retained and processed as this information is necessary for us to carry out our duties as a landlord as set out in the tenancy agreement.

It is important that you notify us of any changes to your personal information as soon as possible so that we can contact you easily. 

What information we hold

When you apply to become an Arches Housing customer, we obtain information to determine your housing needs. This includes information relating to you and your household such as their name and date of birth and contact details. We also collect information about your household’s ethnicity and religion to allow us to monitor equality and diversity. This is sensitive information which we keep safe by only allowing it to be visible to those that need to see it in our systems. We may also record information relating to any disabilities or vulnerabilities that you tell us about which we think may affect the service we provide to you.  In order to help us assess your application, we may ask you for details of your finances to ensure that any property we offer you is affordable and also take up references from other housing providers/private landlords, your mortgage lender (if you own/have owned your own home), the Police, the Probation Service, support workers, social workers, mental health workers and credit reference agencies. 

Once you become an Arches Housing customer, we will also need to record benefit and council tax information, feedback from our contractors about their appointments with you and other aspects of our routine contact with you. We will record information whenever you contact us or use our services and we will note any action taken, for example logging repairs, so that we have a record of what happened. We may also keep photographic records of you in order to help us identify tenancy fraud.

We might take photographs at events that we organise and host.  We may use the images on our website, in brochures and other publicity material (such as newsletters) and provide them to the media for publication in local or national newspapers.  We will always give you the option not to be included in a photograph.  Where group shots are to be taken there will be a sign warning that photographs are being taken and any individual photographs will only be taken with your consent in writing.

Who the personal information relates to

We collect and hold personal information about: 

Customers - This includes current, former and potential customers who live in our properties and includes members of their family and people associated with them.

Visitors - Visitors to our website and our offices.  Anyone who makes a complaint or enquiry to Arches Housing.

How we use our records

We keep records to allow us to: 

• Make allocations of accommodation
• Manage tenancies including collecting rent and service charges 
• Provide a repairs and maintenance service
• Monitoring and ensuring that our homes meet our health and safety obligations
• Ensuring that people are safe when working for us or on our behalf
• Provide home ownership products
• Offer help with debts and benefits
• Keep in touch with our customers, understand your needs and preferences and invite you to events
• Prevent and detect crime and resolve disputes
• Prevent and detect fraud and money laundering
• Promote safety and the quiet enjoyment of our neighbourhoods and communities
• Engage with customers and make improvements to our products and services
• Promote equal opportunities and fair treatment for all our customers
• Provide information (e.g. about products and services) you request from us
• Develop new products and services to meet the future needs of our communities
• Meet our legal obligations, including those owed to our funders or regulators

How long we keep your information

We only keep your information for as long as is necessary for us to provide you a service or for the length of time we need to for legal reasons. This means that if you become a customer of ours, we will keep your information for seven years after the end of your tenancy. After that time the information is anonymised. If you are not a customer but we record your information on our systems we will anonymise the information when it is no longer required, this will not be more than 2 years after your last contact with us.

Our legal basis for processing your information

The majority of our data processing is performed on the basis that it is necessary in order for us to fulfil our contract with our customers. In some cases we might be legally obliged to process information in a certain way, such as sharing information with Local Authorities in order for them to process benefit claims. In other rare occasions our legal basis for processing is legitimate interest, for example where processing data in a certain way to make sure we do not incur financial losses that we should not be liable for.

"Sensitive" personal information

Under the GDPR, certain personal information is classified as “sensitive”. Sensitive data is information relating to physical or mental health, sex life, religious or philosophical beliefs, political opinions, membership of a Trade Union, biometric information, allegations of criminal offences and criminal convictions and offences.

We minimise our holding and use of sensitive categories of personal information but, given the services we provide, there are times when we use it to understand our customers and their needs better, for example when providing accommodation for disabled persons, when resolving neighbourhood disputes involving alleged criminal activity or when helping someone to access other services. When we collect specific sensitive data we will notify you of how we will use it, including who it may be shared with, and seek your consent to this. 

Direct marketing

We would like to provide you with information about events, services and other information that we think you may find interesting. We may send you such information by post, email or contact you by telephone.  You can let us know at any time, how you prefer to be contacted or if you do not want us to contact you with this information.

We never provide your personal information to other companies for their marketing purposes. 

Sharing your information

We will keep your personal information secure and confidential. Our staff have restricted access to personal information on a “need to know” basis.  We may share information with contractors, or agencies we work with, such as Local Authorities, Social Services, Police, other social landlords when we believe it is in your, or the public’s, interest to do so.  We will also disclose information as required by law. 

In particular, please be aware: 

• We may share current or forwarding addresses with utility companies and Council Tax offices to ensure billing details are correct.
• If you default on any tenancy/licence conditions, we may provide information about you to authorised debt recovery agencies, to enable them to recover the debt. This may affect future applications for tenancies, credit and insurance.
• We will pass information about you to contractors who are working on our behalf so that they are able to contact you. We may provide these contractors with information about you or your home that we feel they need to know to ensure that they are safe in your home or to ensure they give you the best possible service.
• We may discuss your financial situation, rent payments (including any arrears) and any claims made for welfare benefits with an external debt advice agency, Welfare rights advisor, the housing benefit department or the local authorities housing advice and homeless prevention team to make sure that benefits are paid correctly.
• We may pass data about your rent payment record to credit reference agencies. This will enable them to assist other organisations to assess your financial standing if you apply for products and services. 
• We may pass your contact information to a third party to conduct surveys and research on our behalf, which allow us to gather feedback and improve the services we offer you. The third party will be bound to strict terms and conditions outlined by us and will not share your data with other organisations. Should you choose not to participate in the surveys the third party will securely destroy your data.
• We may share your National Insurance number to verify your Universal Credit application and manage these payments.
• We may also share your National Insurance number in order to prevent and investigate tenancy and right to buy applications fraud.
• We may pass information about you onto external agencies, such as Local Authorities or Environmental Services if you are suffering from Antisocial Behaviour or if we suspect that you are causing a nuisance to your neighbours. We will only do this if we believe that it is necessary in order to resolve these issues and will share only the information necessary to allow the external agency to carry out the actions that are required.
• Where the risk of fire in your home is increased by lifestyle or health issues, we may share your information and details of the increase in fire risk with the relevant Fire and Rescue service. The legal basis for sharing this information in cases where we are sharing sensitive information, such as information about your health, is that the processing is in substantial public interest in that it is in order to safeguard individuals at risk. The basis for sharing non-sensitive information is that we have judged that the processing is in the legitimate interest of ourselves, the subject and the fire and rescue service.

Using our website

We use Hotjar in order to better understand our users’ needs and to optimise this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymised user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

For further details, please see the ‘about Hotjar’ section of Hotjar’s support site at help.hotjar.com.

Your rights

You have the right to ask us in writing not to process your personal information if it is causing or likely to cause substantial damage or distress, or for direct marketing. There may also be other specific circumstances where you may wish for us to stop processing your data, such as if you agreed to take part in a survey or signed up to an optional service. However, we need to maintain certain records to enable us to provide you with the services you enjoy.

You have the right to access any personal information we hold about you.  If you would like copies of some specific information from your files, we will try to provide it as quickly as possible. Please contact our office, your Housing Officer or the Company Secretary.

If you require a substantial amount of your personal information, there is a formal process for this, under the GDPR, known as a Subject Access Request (SAR).

You also have the right to claim compensation if we fail to comply with the GDPR and you suffer damage as a result.

What you need to know about making a SAR:

• The right of subject access under the GDPR is an individual one. This means that we cannot process joint requests – they have to be treated separately.
• You can write to us to make your request and, if necessary, we will provide you with a SAR form for completion. Please write to the Company Secretary, Arches Housing Limited, 122 Burngreave Road, Sheffield, S3 9DE.
• We will require proof of your identity and address – we will let you know this when we receive your request.
• When we receive your request and have confirmed your identity to our satisfaction, we shall respond and provide your information within one month.  

Changes to our privacy notice

We will update this privacy notice to reflect changes either to the way in which we operate or changes to data protection legislation. We will bring any significant changes to your attention but to make sure that you keep up to date, we suggest that you revisit this notice from time to time at www.archeshousing.org.uk/privacy

Contacting us

We welcome any queries you may have regarding this privacy notice, or any information we hold about you. Please contact:

Company Secretary
Arches Housing Limited
122 Burngreave Road

Sheffield

S3 9DE

Other Resources 

The Information Commissioners Office (ICO) is the UK’s independent body who upholds information rights in the public interest. Arches Housing are registered as a Data Controller with the ICO. Their contact details are below:

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

Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number
Fax: 01625 524 510

Website: https://ico.org.uk/ 

last updated June 2020