Privacy Notice

Radcliffe Housing Society Ltd is a Registered Social Landlord and is registered with the Information Commissioner’s Office as a Data Controller under the General Data Protection Regulations 2018.

We take privacy seriously

Radcliffe Housing Society (RHS) complies with the General Data Protection Regulation (GDPR) 2018 in relation to personal information that you give us to ensure that it is not misused. The regulation defines a set of rules and guidelines we must follow when handling your information.

Why do we collect and store personal information?

RHS needs to collect, process and store personal information about you and other household members (when you provide information about household members we assume that you do so with their full knowledge and consent). This is in order to operate as a registered provider of housing and deliver efficient and effective services.

Basis for processing your personal information

Our main legal basis for processing personal data is where it is necessary for the purposes of the legitimate interests pursued by RHS or by a third party to process your information. We can do that so long as we do not interfere with your fundamental rights or freedoms.

Information we may hold about you and how we use it

The information we hold on our records concerns our relationship with you. For example:

• We hold names and dates of birth, photographic ID and information about your previous housing circumstances to assess housing applications and to help prevent tenancy fraud.
• We require up to date contact details (telephone number and email address) which are required so we can get in touch with you to discuss issues regarding your tenancy or lease agreement. For example, for the purposes of rent collection or other sums, receipt of benefits, essential compliance and servicing, access for maintenance and repairs and other service delivery. We may need to provide your contact details and relevant associated information to our contractors who may be undertaking work on your property on our behalf. We hold contact details for you so we can communicate with you by your preferred means and facilitate repairs to your home.
• We record information about your needs (for example, if you have a carer or social worker; if you need adaptations in your home) to ensure that we take account or to identify any support needs, and to improve out communications with you.
• We record information to enable us to provide a variety of housing management services. For example we record reports of anti social behaviour; complaints; change in circumstances (for example when your employment status changes) and information about housing options (eg if you have a medical need which means you need to move).
• We keep financial records about the amount of money you have paid us, any amount(s) outstanding and actions taken to recover money you owe.
• We may hold information about you if you are engaged with any additional guidance and support services.
• We reserve the right to record your telephone calls to our office for training and monitoring purposes to ensure we are delivering a good service or to improve our services.
• We may capture your image on our CCTV systems if you live at or visit a property covered by this facility. Any CCTV records will be held safely and securely before being erased.
• We record the findings of surveys and other research to help us improve our service to customers. The information you provide will be anonymous, unless you agree that we can use your details.
• We keep details of complaints received to help us monitor responses and resolutions to any issues raised. The information you provide may need to be passed to third parties such as our repairs and maintenance contractors.
• In promoting our beneficial services including financial inclusion or wellbeing courses. We will combine information from tenants to analyse trends so we can keep up with demand for our products and services, and to develop relevant new products and services. You have the right to ask us not to process your personal data for direct marketing purposes by opting out at any time.

Some of the organisations that we may share personal information with include, but are not restricted to:

• Legal advisers
• Emergency services
• Government departments including local authorities
• Welfare advisers
• Medical professionals
• Other housing associations
• Utility providers

This list is not exhaustive.

Generally, the information we hold will have been provided by you (on application or when we communicate with you), but we may also hold information provided by third parties where this is relevant to your housing circumstances eg from social workers and health professionals (such as doctors and occupational therapists).

We will only ask for personal information that is appropriate to enable us to deliver our services. In some cases you can refuse to provide your details if you deem a request to be inappropriate. However, you should note that this may impact on our ability to provide some services to you, if you refuse to provide information that stops us from doing so.

How we manage your personal information

We will process your personal information in accordance with the principles of GDPR.  We will treat your personal information fairly and lawfully and we will ensure that information is:

• Processed for limited purposes
• Kept up to date, accurate, relevant and not excessive
• Not kept longer than is necessary
• Kept secure

We are committed to keeping your personal details up to date and encourage you to inform us about any changes needed to ensure your details are accurate. To help us ensure confidentiality of your personal information, we will ask you security questions to confirm your identity when you call us.

Right to be forgotten

We hold a variety of data types which have different requirements for how long we need to keep it. We have a data retention schedule that describes the type of data we hold and their retention timescales. We follow legal requirements and best practice in this area. We will securely destroy / delete personal data when we no longer need it, or no longer have a legitimate interest in keeping it.

The right of access

You have the right to ask to see the personal information we hold about you and ordinarily the right to have a copy provided to you or someone else on your behalf. A request to see this information is known as a “subject access request” (“SAR”).

Our preference would be for SARs to be made in writing to our offices. However, the UK GDPR does not set out formal requirements for a valid request. We will ask for your written request to be accompanied by proof of your address and identity. This enables us to prevent data being sent to another, either accidentally or as a result of deception. We must be satisfied the SAR request made, is identifiable to the requestor.  If you require specific information, it is helpful if this is clear in your request, for example, information from a particular time period or about a specific correspondence.

We will provide a copy of the information requested free of charge, but we can charge a “reasonable fee” if a request is manifestly unfounded or excessive, particularly if it is repetitive.

The right to rectification

You can ask us to correct your personal data if it is inaccurate or incomplete. Please help us to keep our records accurate by informing us if your details change.

The right to object

As we are generally relying on our “legitimate interests” as a reason for processing your personal data you can inform us if you object to our processing of your personal data. We can override this object in certain circumstances.

Rights in relation to automated decision making and profiling

There are some occasions where automated decisions are made about you using pre-programmed criteria on our systems, for example, eligibility for mutual exchange. You have the right to challenge the validity of any decisions made in this way and ask us to review this. You may also ask us not to process your information in this way.

Changes to this Privacy Notice

This privacy notice will be kept under review and updated as required. We recommend that you keep up to date via our website and tenant portal. We will let you know if we make any major changes to this Notice. This version is published August 2024.

Your right to lodge a complaint with a supervisory authority

If you are not satisfied with our response to any query about your personal information that you raise with us, or if you believe that we are processing your personal information in a way which is inconsistent with the law, you can complain to the Information Commissioner’s Office (“ICO”).

Please also contact the ICO if you require general advice on privacy and any data protection issues.

Address:

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

Website: https://ico.org.uk/

Tel: 0303 123 1113