Personal information is any information that can be used to identify a living person. For example we collect names, addresses etc. about applicants in order to assess their suitability for our accommodation. In addition, we may also request sensitive personal information such as information about physical or mental health conditions.

As well as personal information such as your name, address and date of birth, we may collect sensitive personal information. Personal information is regarded as sensitive if it includes any of the following types of information for example:-

• Racial or ethnic origin
• Religious or philosophical beliefs
• Sexual orientation
• Trade union membership 
• Physical/mental health or condition
• Sexual life or sexual orientation 

We will only process sensitive personal information to ensure services are delivered appropriately and to monitor equality, diversity and inclusion. We will ask for your specific informed consent at the time of collecting sensitive information. Where you provide consent for us to process sensitive personal information, you have the right to withdraw this consent at any time.  We may also process confidential data about you including bank account information. 

Processing personal information includes the collection, editing, keeping, storing, disclosing or sharing of information. It also includes the deletion, destruction, viewing, listening to and archiving of personal information.

We can only process your personal information if it satisfies one of following conditions:

Consent: You have consented to your personal information being processed.  

Contractual: It is necessary for us to process your information to perform a contract or to take steps to enter into a contract. An example of this is processing your information in order to enter into a tenancy agreement with you. 

Legal obligation: It is necessary for us to process your information in order to comply with a legal obligation. 

Vital interests: It is necessary for us to process your information to protect your vital interests for example a medical emergency.

Public tasks: It is necessary for us to process your information to perform a task carried out in the public interest or in the exercise of official authority.

Legitimate interests: It is necessary for us to process your information to see how we are performing so that we we can meet our mission statement and objectives. Or in the prevention of fraud and reporting possible criminal acts or threats to a competent authority.

We will only process your personal information for the purposes of:-  

• Providing, managing and developing affordable housing
• Providing property management and property maintenance services
• Providing and managing support services

We may also process information from you for the following reasons:-  

To prioritise and assess housing applications and complete tenancy sign-ups 

We will need your name and contact details (including telephone numbers, email addresses and details of anyone you may choose to represent you) for use across the organisation by our contractors, suppliers and partners.

We will collect detailed personal information about you and other household members, including age, sex, date of birth, ethnicity, income, National Insurance number, income and benefits details, employment status, gender identity, relationship status, any disabilities, any communication and accessibility requirements, religion, sexuality, nationality, caring responsibilities, access to financial services such as banks and credit unions, bank details, council tax, medical information, details of any unspent criminal convictions.

When you provide information about household members we assume that you do so with their full knowledge and consent. Provision of some of the information requested by us is part of a ‘contractual requirement’.  Without this information, we will be unable to accept an application for accommodation or services. For example, we cannot see if you are eligible for a tenancy or check that an application is not fraudulent without being able to verify your identity. Where enquiries relate to household members, it is in our legitimate interests to know who will be living in our premises. This is to check that accommodation offered is adequate. 

To manage your tenancy

We will ask for up to date contact details so we can reach you when we need to discuss issues pertaining to your tenancy, e.g. income collection, essential servicing of appliances, access for maintenance and improvements. We may also need this information if we need to arrange a home visit or to contact you in the event of an emergency or to enforce the terms of your tenancy.

We will also use your contact information to tell you about changes to Chislehurst and Sidcup Housing Association, for example our organisational structure and governance arrangements, and to resolve or investigate complaints or housing management issues such as antisocial behaviour.
We will ask for details of any change in circumstances for example, if you have a medical need that means your housing requirements need to be re-assessed we will ask you for supporting information about your change in health needs; or to effect any changes to your tenancy. If you want to change your name on our records we will ask you for a copy of your marriage or deed poll certificate.

We may hold records of all our contact with you, your contact with us, and any contact from third parties representing you or about you. This may include call recordings. 

Financial records about the amount of money you have paid us, any amount(s) outstanding and associated recovery action. Depending on your method of payment, we may hold your bank account details. 

We may hold information about your history, for example regarding credit status or offences, if we need it to look after our staff, business or anyone else.

We may hold information relating to the repair, maintenance and servicing requirements of your home.  Although this information will not necessarily constitute your personal information.

Providing this type of the information is a ‘contractual requirement’; without it we may be unable to manage your services. For example, we cannot consult with you about changes to your service if we do not hold your contact details. 

Where enquiries relate to household members, it is in our legitimate interests to know who is living in the premises, to check that accommodation remains adequate for current and near future needs and to  check that household members’ needs are being met. 

To meet your needs in our service delivery 

To ensure our services are accessible and that we take account of any support needs in our dealings with you and to improve our communications with you. For example, if you are involved with a carer, social worker or other advocate, if there are considerations we need to apply when we visit you at home.
When profiling you for services and to target our resources.

When processing information about you or your household members, we may have a legal or contractual obligation to process this information for example to provide inclusive services. 
 
To prevent fraud and illegal sub-letting and to confirm eligibility for housing 

We will ask for proof of identity and take your photograph from time to time, e.g. Tenancy Sign-ups or subsequent Tenancy Audits, when the housing composition changes or a reasonable period of time has passed, this applies to all household members over the age of 18 years.

Processing of personal information for the purpose of fraud prevention is required in order to meet our legal obligations. Therefore if we are unable to verify your identity we may not be able to provide services to you.

To assist with personal security and prevention and detection of crime 

We may capture your image on our CCTV systems if you visit a scheme or our offices which are covered by this facility.

Processing of this information may be required to meet Chislehurst and Sidcup Housing Association’s legal obligations and our legitimate business interests around health and safety and crime prevention.

When you engage with our additional guidance, advice and support services  

We may hold information about your education, job history and skills and experience, or if we support you to improve your financial circumstances, we may hold detailed information about your household income and expenditure. 

If you ask us for care and support requirements we will hold detailed information about your needs and your family’s needs and where relevant, records of payments for the services provided to you.

Provision of information requested by us may form part of a ‘contractual requirement’

Without this information, we may not be able to provide this service.  We will make it clear at the point of data collection whether the information is voluntary. 
 
Where the processing of information concerns household members, it is in our legitimate interests to ensure that we are meeting the needs and expectations of all tenants and service users.  

To understand how we are performing

We may undertake call recordings for training and quality monitoring purposes. We may use your contact details to carry out market research and customer satisfaction surveys to help us to monitor our performance and to improve our services to you. 

To segment tenants and service users to help target our resources and prioritise services.

In managing and analysing complaints. 

For statistical analysis.

Legitimate interests

It is in our legitimate interests to understand how we are performing so we can meet our mission statement and objectives.   

Legal obligations

There may be a legal obligation for us to process your personal information or to demonstrate to our regulator, funders and other statutory bodies that we are fulfilling our obligations. 

We also use your personal information in the following ways:-

Keeping in touch with you, understanding your needs, and inviting you to events.

It is in our legitimate interests to communicate with you and keep you up to date with news and events in order to meet our objectives around social inclusion and helping to build communities.

Prevention and detection of crime, and quality management.

We will only hold information during the period of our relationship and for a set period afterwards to allow us to meet our legal obligations, including resolving any follow up issues between us. We have a Document Retention Policy, which sets out how long we keep different types of information for. This is based on National Housing Federation guidance, legal requirements and best practice. Please contact us if you would like any more information.

The right to be informed

Through the provision of privacy notices, we will be open and transparent about how and why we use your personal information.

The right of access

You have a right to ask us what personal information we hold about you and to request a copy of your information. This is known as a ‘subject access request’ (SAR). Subject Access Requests must be made in writing, we have a subject access form you can use for this purpose. Written requests must be accompanied by proof of your address and identify.

If you are seeking to obtain specific information about a particular matter or from a particular time period, it helps if you clarify the details of what you would like to receive in your written request. If someone is requesting information on your behalf we will require proof of identity (both yours and theirs); and written confirmation that you have given them your consent.

We have one month within which to provide you with the information you have asked for. However, we will be able to extend the period of compliance by a further two months where requests are complex or numerous. If this is the case, we will inform you within one month of the receipt of the request and explain why the extension is necessary.

The right to rectification

You can ask us to rectify your personal information if it is inaccurate or incomplete.  Please help us to keep our records accurate by keeping us informed if your details change. We will respond within one month. This can be extended by two months where the request for rectification is complex.

The right to erasure

The right to erasure is also known as ‘the right to be forgotten’. In some circumstances, you can ask us to delete or remove personal information, where there is no compelling reason for its continued processing.  This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the information. Our response will also be guided by the provisions of our Document Retention Policy and the General Data Protection Regulations. 

The right to restrict processing

In some circumstances you can ask us to restrict processing, for example:- 

• If you disagree with the accuracy of personal information.
• If we are processing your information on the grounds of legitimate interests (as detailed earlier), and whilst we consider whether our legitimate grounds override those of yours. 
• When processing is unlawful and you are against erasing the information and requests a restriction on the processing of information instead.
• If we no longer need the personal information but you require the information to establish, exercise or defend a legal claim.

The right to data portability

This allows you to obtain and reuse your personal information for your own purposes across different services. It allows you to move, copy or transfer personal information we hold about you across different services, you may be able to ask us to do this.  

The right to object

You can tell us if you object to our processing of your personal information, based on legitimate interests or for the purpose of direct marketing, including profiling.

Rights in relation to automated decision making and profiling

You can ask us to review any decisions that are determined by automated means.  You can also object to our use of your personal information for profiling. 

If you’d like to talk to us about your rights, you can contact us at csinfo@csha.org.uk alternatively on 0208 467 9146. 

In some situations, there may a number of legal grounds open to the Association with regard to the processing of your personal information. This may or may not include consent. However, in order to maintain the best possible relationship of trust, consent will be sought as ‘good practice’ wherever this is appropriate and possible. If we require your consent to process information we will:- 

• Ensure your consent is given freely
• We will be specific as to why we require your consent
• We will inform you of the reasons why we require consent 
• We will be clear about how we gain your consent including use of plain language and will always obtain a positive indication of your agreement rather than using tick boxes. 

Whenever the Association is collecting sensitive personal information, this will,  require explicit consent. However you have the right to withdraw consent at any time, where relevant and in accordance with the provisions set out in the General Data Protection Regulations.   

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There are a number of options available so that you do not have to store any cookies at all. You can either set your browser so that it will not accept and store any cookie, or if you have a little more time and knowledge you are able to allow only certain ‘trusted’ sites to store cookies on your computer.

Our Website uses cookies. We use cookies to provide statistical information regarding the use of our Website. Such information will not identify you personally. It is statistical data about our visitors and their use of our Website. This statistical data does not identify any personal details whatsoever. We may also gather information about your general Internet use by using a cookie file. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer, as cookies contain information that is transferred to your computer's hard drive. They help us to improve our Website and the service that we provide to you. All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. 

If you want to raise a complaint about the way we have processed your information or would like to seek an independent view, you can contact the Information Commissioner’s Office using the contact details provided at the end of this notice.

For further information you can contact the Data Protection Officer as follows:-

The Data Protection Officer
45 Invicta Close
Chislehurst
Kent
BR7 6SJ 

csinfo@csha.org.uk

For independent advice about data protection, privacy, e-privacy and data sharing issues, you can contact the Information Commissioner’s Office. Lots of useful information is accessible on their website:

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

Phone: 0303 123 1113
Email: casework@ico.org.uk
Website: www.ico.org.uk