PRIVACY NOTICE (ALL CITIZEN HOUSING AND CITIZEN NEW HOMES CUSTOMERS)
Here at Citizen Housing Group Ltd/Citizen New Homes Limited (Citizen), we take your privacy seriously. Below, we detail what information we collect, why we collect it, who we share it with and how we safeguard it. We will use your personal information to administer your tenancy/purchase and to provide appropriate support and advice, and place you in contact with organisations of your choice, that will offer support that you control, however, we will share it with appropriate third parties where there is a legal justification. The Purposes for which we collect your personal data include the following:
- Regulatory purposes – e.g. requirements of the Regulator for Social Housing research;
- Management of homes;
- Collection of rents, other sums and receipt of benefits;
- Money/debt advice and employment;
- Maintenance and repair of homes;
- Legal Proceedings;
- Health & Safety requirements for tenants and staff;
- Prevention and reduction of crime including fraud;
- Equal Opportunities monitoring; and
- Marketing, research, monitoring and survey.
For some information, we do not need to seek your consent to hold or process it as it is part of our performance of a contract. We obtain your personal identifiable information in order to conduct our normal business operations as a Registered Social Housing Provider.
We wish to provide you with updates about events, services and other information that we believe are helpful to you in relation to the services that we provide. We may communicate such information to you by post, telephone or email (unless you have registered with the appropriate Preference Service or have indicated to us that you do not require certain forms of communication). In the event that we perform monitoring, research and survey services we may use an external service company to contact you on our behalf. In such circumstances we ensure that legal obligations of confidentiality and information security are placed upon our service providers. If at any time you wish that your information is not used for direct marketing please contact our Customer Service Centre on 0300 790 6555.
Citizen Housing Group Ltd will never sell your information to third parties. For the purpose of this privacy notice we are the “controller” of your personal identifiable information as we determine the purposes and content of this information and the methods of processing. As a Registered Social Housing Provider, we are regulated by the Regulator of Social Housing (RSH).
- Date of birth
- Previous address
- IP (Internal Protocol) address
- Telephone numbers
- Email address
Your tenancy agreement is a contract between you, any other person in your household (should you hold a joint tenancy and or multiple occupancy) and Citizen.
This data is used to set up and maintain your tenancy account with us.
Life of tenancy + 6 years after tenancy ends
Special category data
- Sexual orientation
- Physical and mental health wellbeing
Fairness in the provision of social housing services, including health and safety purposes & for analysis purposes, as required by our regulator.
Life of tenancy + 6 years after tenancy ends and in some cases indefinitely
- National insurance number
- Financial information including employment history and employment status
- Identification including photographic proof of identity
To assess your benefit entitlement and council tax. To assure ourselves you can sustain a tenancy and that you have the right to rent under Immigration Act 2014 and regulatory compliance, as laid down by regulation. To give money and/or debt advice, if you agree, to help you maximise your income, prioritise spending and optional help in seeking employment.
NI number & identification – life of tenancy/ Financial information 6 months
- unspent convictions
- criminal offences attracting a custodial sentence/on a register/person of interest
- Identification including photographic proof of identity
We use unspent conviction information to house you appropriately and to make prosecutions in the event of subletting or other forms of criminal a
Life of tenancy but regularly reviewed. If no issues when conviction spent data will be deleted after 1 year following suspension
- Details of any support needs you have
- Details of those people providing additional support
- Next of kin details/emergency contacts
- Disability information
As required by our regulator and to provide information on extra services we provide – such as tenancy support.
Life of tenancy but regularly reviewed
- Authority to Act or Power of attorney
We use this information to ensure we deal with the most appropriate person dealing with your affairs
Life of tenancy but regularly reviewed
- Audio and visual images of you, such as photographs, films and audio recordings
We use this to publicise the work we do.
We may retain this permanently
- Call Line Identification
Your number is displayed on our telephones unless suppressed by yourself on your device. We hold a log of the phone number, date, time, duration of call and recording of conversation.
1 month from date of telephone call
- Marketing, survey, monitoring and research
Activities associated with improving service delivery and the customer experience
Life of tenancy
- Former tenant arrears (bad debtors list)
Obligation as a registered social housing landlord to maximise the collection of income and minimise any outstanding debts
As long as the debt remains unpaid
Types of Legal Basis
- A – Consent
- B – Contract
- C – Legal obligation
- D – Vital interests
- E – Public task
- F – Legitimate interest
Where someone sharing a home with you is over 14 years of age, and where you provide next of kin information we require you to inform them that we hold their information. We have a contractual requirement to collect and process this information, as part of the provision of service to you.
Who do we share your data with?
Some data, such as your name, address, move-in date and national insurance number will be shared with local authorities to assess your benefit entitlement and council tax. We also share information relating to the protection of vital interests such as safeguarding, domestic violence, criminalactivity & emergency services. Please see attached full list https://www.citizenhousing.org.uk/privacy
The organisation takes the security of your data seriously. The organisation has internal policies and controls in place to safeguard that your data is not lost, accidently destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties. Where the organisation engages contracted third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
How we obtain your data
We obtain personal identifiable information by various means, this can be face to face, by email, by telephone, correspondence or by receiving information from others, for example local elected members who are representing you, police, health or social care agencies and benefit agencies. For a full list please see https://www.citizenhousing.org.uk/privacy
Where we share information with third parties, we do so safely and via secure networks. This may be encrypted emails, or via secure portals into our network.
Under the General Data Protection Regulations (GDPR), you have the right to be informed about how we use any data you provide: what data we collect, why, who has access to it, how long it’s kept, and the legal basis we have for doing so. In certain circumstances we may need to request your consent to collect and use your data, but in those cases, you have the right to object and withdraw that consent just as easily as it is given. Should you not wish to provide your consent, any services directly related to this data cannot be provided.
You have the right to have your personal data removed where there is no legal basis for us to hold it, as well as the right to request your data is transferred to a third-party (data portability). Any automated decision making, based on your data, can be challenged and a human decision made. Additionally, you have a right of access and can request a copy of any personal data provided, and subsequently the right of rectification of any incorrect data identified. Visit the data protection page on our website to see more information about your rights. To exercise any of the above rights please contact Citizens Data Protection Officer (Mr Shane Murphy) on the address below. Overall responsibility for management of your data resides with Citizens senior information risk owner (Mr Ian Tinsley) at Citizen Housing Group Ltd, 4040, Solihull Parkway, Birmingham Business Park, Birmingham, B37 7YN or firstname.lastname@example.org
Complaints can be lodged with the supervising authority at The Information Commissioner’s Office: https://ico.org.uk/concerns or 0303 123 1113.
Our data policy
We take your information very seriously.
Legislation gives you certain rights regarding your data:
The right to be informed
You have the right to be informed about the collection and use of your personal data. When we collect data from you we provide you with Privacy notices which details:
- The purposes for processing your personal data
- Our retention periods for that personal data
- Who it will be shared with
The right of access
You have the right to access your personal data and supplementary information. This right allows you to be aware of and verify the lawfulness of the processing. For more information about this subject download the Subject Access Request Form to allow you to see your personal data.
Right of rectification
The GDPR includes a right for individuals to have inaccurate personal data rectified, or completed if it is incomplete.
In certain circumstances we may refuse a request for rectification.
Right to erasure
The GDPR introduces a right for individuals to have personal data erased. It is known as “the right to be forgotten”.
The right is not absolute and only applies in certain circumstances.
Right to restrict processing
You have the right to request the restriction or suppression of your personal data. This is not an absolute right and only applies in certain circumstances.
If we agree to your request to restrict processing we will store your personal data, but not use it, however this may impact on the services we can provide to you.
Right to data portability
This right allows you to obtain and reuse your personal data for your own purposes across different services. It allows you to move copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability.
Right to object
You have the right to object to:
- Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling)
- Direct marketing (including profiling)
- Processing for purposes of scientific/historical research and statistics
If you think the data we hold is inaccurate or incomplete, or you want to exercise any of these rights, you can make a request verbally or in writing, and we will respond within a month of receiving the request.
Links to other websites
The Citizen Privacy Notices do not apply for links to other websites. Therefore, Citizen strongly recommend that you read the Privacy Notices, policies and statements on the other websites you visit before providing any personal data, or entering into any form of agreement.