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Privacy Policy

Introduction

At Lincolnshire Housing Partnership (LHP), we value the trust of our customers. We understand that you are aware of and care about your personal data and privacy. We take this seriously and always process your personal information in a fair and transparent way. This privacy policy details our practices regarding the collection and use of your personal data and sets out your rights under legislation including the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 (“GDPR”)

This privacy policy tells you what to expect when we process your personal information. It is important for you to read this policy in full to understand what information we hold about you, how we may use it and your rights in relation to your data.

We regularly review this policy and we may, from time to time, update this privacy policy as we undertake new personal data practices.

  1. What is personal data?

Personal data is classed as any information that directly relates to, and/or identifies you, whether directly or indirectly.

Any personal data that we collect and store must, by law, meet at least one of the 6 legal basis required for processing, which include by consent; for contractual purposes; under a legal obligation; for vital interest; by way of a public task or under another legitimate business interest.

Under law, certain data is classified as “special categories”, including:

  • Ethnicity, Race, Political Beliefs, Sexual Orientation
  • Trade-union membership
  • Medical & Health information
  • Criminal Records

Special Category data requires us to provide more robust security and accessibility measures.

  1. Information we ma collect from you

We need to process personal data in order to:

  • provide, manage and develop affordable housing for all.
  • provide property management & property maintenance services.
  • provide and manage care and support services.
  • deliver on our ambition to ‘transform lives and communities’.

The type of information we need from you will vary depending on our relationship with you. We may collect this via housing applications, tenancy agreements or when you correspond with us by phone, email or otherwise. We will only collect personal information like this when we need to. When we ask you for information, we will make it clear why we need it. We will also make it clear when you do not have to provide us with information and any consequences of not providing this.

We may collect all or some of the following information from you (as applicable) in order to progress your application and/or ongoing tenancy and to fulfil our legal/regulatory requirements:

  • your name and contact details (including telephone numbers, email addresses and details of anyone you may choose to represent you) for use across our organisation and by our contractors, suppliers and partners, where it is required and relevant to do so.
  • detailed personal information about you and other household members*, including (but not limited to) 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, bank details, benefits, council tax, housing benefits, universal credit details, medical information and details of any unspent criminal convictions.
  • recordings of telephone conversations you have with us.
  • we may also capture your image on our CCTV systems if you visit an estate, office or community facility which is covered by this facility.

* When you provide information about household members, we assume that you do so with their full knowledge and consent.

Provision of the majority of the information requested by us is part of a contractual requirement and without this information we will be unable to accept an application for services. For example, we cannot see if you are eligible for a home 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 the premises to, check that accommodation offered is adequate for current and near future needs of the household and to check that household members’ needs are being met.

Most information we hold will be collected directly from you, but we may sometimes also obtain this from third parties – such as the local authority, a previous landlord or other relevant community partner. In addition, we may also obtain information from publicly accessible sources – this would only be used to enhance the existing information that we already hold.

  1. How we will use your data

We will use the information you provide for the following purposes:

  • To assess housing applications and service eligibility.
  • To manage your lease.
  • To meet your needs in delivering our services.
  • To prevent fraud and illegal sub-letting and to confirm eligibility for any housing benefit/universal credit.
  • To assist with the prevention and detection of crime.
  • To manage the legal process if you want to access another home ownership route.
  • To meet our legal obligations, including any government reporting and the requirements of our regulators.
  • To liaise with welfare services, where appropriate, to keep you safe and secure.
  • To provide trace information in the event of any debt.
  • Direct marketing activities, but only where you have given us the permission to do so.

  1. How we may share your data

Sometimes we need to share personal information we hold about you with other organisations that we work with or who provide services on our behalf. When sharing information, we will make sure we comply with all aspects of data protection law, including the safe transfer of data.

Where the information is of a sensitive nature, for example about your health, we will generally obtain consent from you prior to sharing this information, unless we are required or already permitted to share this by law.

Outside of these we may share your information without first seeking your consent, but only where we have rigorously determined that sharing meets one (or more) of the Legal Basis as required by data protection law.

This may be with:

  • Our contractors to facilitate repairs, maintenance or improvement works.
  • Local authority teams such as housing, social services, environmental health and benefit agencies.
  • Utility companies (and their representatives) and Council Tax departments to ensure billing details are correct.
  • Independent mortgage advisors and solicitors.
  • Third parties providing services on our behalf, for example a mailing company distributing our newsletter; a research company carrying out a customer satisfaction survey, or a debt collection agency pursuing former tenant arrears.
  • Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative.
  • Police and other relevant authorities (e.g. Department of Work & Pensions, Probation Service, HM Revenue and Customs) in relation to the prevention and detection of crime, the apprehension of offenders or the collection of tax or duty.
  • Other statutory organisations e.g. social services, health authorities, occupational health organisations, Homes England, Housing Ombudsman, the National Housing Federation, as necessary for exercising statutory functions under public task.
  • Where ordered by the Court, or to protect an individual from immediate harm.
  1. How long we keep your data

How long we keep your data

We will only keep your data for as long as necessary to fulfil our contractual duties. Our retention policy is based around the recommendations from the national housing federation.

  1. How we keep your data safe

We have put into place appropriate organisational measures to reduce the risk to your personal data being misused, altered or lost. This includes the use of encryption and password protected files where appropriate. We have procedures in place to report any personal breaches that may occur, and we will inform you and the relevant regulators where we are legally required to.

  1. Transfers to other countries

As part of our offering, we may sometimes use third party service providers in a Data Processor capacity, whose business and/or technical services are within the European Economic Area (the “EEA”) which are protected by the same or similar regulatory requirements as the UK. We do not transfer data outside the EEA.

  1. Your Rights

You have a number of rights under law in regard to your personal data. These are:

  • The right to be informed
  • The right of access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to data portability
  • The right to object
  • Rights in relation to automated decision making and profiling.

Further details on each of these rights and how to raise a query with us can be found on our website under Your data-Your rights.

You can also talk to us about these by emailing the Data Protection Officer on dataprotection@lincolnshirehp.com or by telephoning us on 0345 604 1472.