Privacy Policy
Introduction
Lincolnshire Housing Partnership Limited (LHP) is a registered charitable Community Benefit Society under the Co-operative and Community Benefit Societies Act 2014 (registration number: 7748) with our registered office at Cartergate House, 26 Chantry Lane, Grimsby, North East Lincolnshire, DN31 2LJ. We are registered with the Information Commissioner’s Office (ICO) under registration number ZA345449.
We are the ‘data controller’ of the personal information we collect and use. This means we are responsible for ensuring it is processed lawfully, fairly, and transparently.
At LHP, we take your privacy seriously. This policy explains how we collect, use, and protect your personal data, and sets out your rights under relevant laws including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003 (PECR).
These laws guide how we handle your data across all our services — from housing support to service updates and optional news or event communications. Our Data Protection Officer (DPO) oversees our compliance with data protection laws and ensures we maintain high standards in handling your personal information.
We review and update this policy regularly. Please read it to understand what information we hold, how we use it, and your rights. If you have any questions or concerns, please contact us using the details in the ‘How to Contact Us’ section.
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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.
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Special categories of personal data
Special categories of personal data require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards, as required by law, when processing such data.
We may process special category data in the following circumstances:
- In limited situations, with your explicit written consent;
- Where we need to carry out our obligations in the field of employment, social security or social protection law;
- Where it is necessary for reasons of substantial public interest, on the basis of UK law (e.g. safeguarding, equality monitoring);
- Where it is necessary to protect your vital interests (or those of another person) where you are physically or legally incapable of giving consent;
- Where it is necessary for the establishment, exercise or defence of legal claims or where courts are acting in their judicial capacity;
- Where it is necessary for reasons of public interest in public health, such as protecting against serious cross-border health threats;
- Where the data has been manifestly made public by the data subject.
In line with this, we ensure that an appropriate Article 9 UK GDPR condition is satisfied whenever we process special category data.
Under law, special category data includes (but is not limited to):
- Ethnicity, race, religious or philosophical beliefs, sexual orientation
- Trade union membership
- Health information (including physical or mental health conditions)
- Criminal offence data (processed under separate safeguards under DPA 2018, Schedule 1)
We will ensure that an Article 9 UK GDPR condition applies in instances where we process special category data.
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Information we may collect from you
We collect different types of personal information depending on the services we provide and our relationship with you. This may include details you give us through housing applications, tenancy agreements, or when you contact us by phone, email, letter, or in person.
We only collect information that is necessary, relevant, and proportionate to deliver our services, meet legal obligations, or manage our responsibilities as a housing provider.
We will always explain:
- What information we’re collecting
- Why we need it
- Whether it’s required by law or optional
- What may happen if you choose not to provide it
Full details of how we use your data are set out in Section 4: How We Use Your Data.
Types of Information We May Collect:
We may collect the following, depending on your situation:
- Basic contact details: Name, phone number, email, address, and details of any representative
- Personal and household details: Date of birth, sex, employment, income, benefits, caring responsibilities, relationship status, nationality, access to financial services, and communication or accessibility needs
- Sensitive data (special category or criminal offence data): Health conditions, ethnicity, religion, sexuality, gender identity, socioeconomic factors or criminal convictions — collected only where relevant, necessary, and lawful (e.g. to assess housing eligibility, provide support, or meet safeguarding duties)
- Financial and housing data: National Insurance number, bank details, housing benefit or Universal Credit information, council tax details
- Recordings: Phone call recordings (where applicable)
If you provide information about other household members, please ensure they are aware and have agreed, where appropriate, to their data being shared.
We usually collect information directly from you. In some cases, we may also receive relevant data from third parties such as:
- Local authorities
- GPs or health professionals
- Previous landlords
- Support workers or community organisations
This may include:
- Confirmation of housing eligibility or priority status
- Information about medical or support needs
- Tenancy history or rent arrears
- Safeguarding or risk information
- Identity or household details
- Accessibility or communication needs
We may also check publicly available sources (e.g. the electoral roll or Companies House) to verify information you’ve provided.
We may use drones to capture aerial images and footage of our properties for communications purposes; any identifiable individuals will be blurred, and all data collection complies with the Data Protection Act 2018 and UK GDPR.
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How we will use your data
We use your personal data to deliver our services, meet legal obligations, and support our wider mission to make a difference to people by providing homes and supporting communities that improve lives. Our mission is focused on the basics, done well.
Our main uses include:
- Managing housing applications, tenancies, and leases
- Providing property, maintenance, and support services
- Meeting legal and regulatory requirements
- Safeguarding individuals and preventing fraud or crime
- Communicating with you, including through secure portals
- Sending relevant news or marketing (with your consent)
Some data is legally required or essential to provide our services. If you do not provide it, we may be unable to progress your application or deliver certain services. We will always tell you when information is optional and explain any impact of not providing it.
Lawful Bases for Using Your Data
We only process your data where we have a legal reason to do so under data protection law. This may include:
| Purposes for Processing | Lawful Basis |
|---|---|
| To assess housing applications, service eligibility and complete tenancy sign-ups. | Article 6(1)(b) – performance of a contract; Article 9(2)(b) – social protection (if special category data is involved) |
| To manage your tenancy or lease. | Article 6(1)(b) – performance of a contract |
| To meet your needs in delivering our services. | Article 6(1)(e) – public task; or Article 6(1)(b) – performance of a contract; Article 9(2)(g) – substantial public interest |
| To prevent fraud and illegal sub-letting and to confirm eligibility for any housing benefit/universal credit. | Article 6(1)(c) – legal obligation; Article 6(1)(e) – public task; Article 9(2)(g) – substantial public interest (Schedule 1 para 6) |
| To assist with the prevention and detection of crime. | Article 6(1)(e) – public task; Article 9(2)(g) – substantial public interest (Schedule 1 para 10: preventing or detecting unlawful acts) |
| To manage the legal process if you apply to buy your home or want to access another home ownership route. | Article 6(1)(b) – performance of a contract; Article 6(1)(c) – legal obligation (where statutory schemes apply) |
| To meet our legal obligations, including any government reporting and the requirements of our regulators. | Article 6(1)(c) – legal obligation |
| To liaise with welfare services, where appropriate, to keep you safe and secure. | Article 6(1)(e) – public task; Article 9(2)(g) – substantial public interest (Schedule 1 para 6 or 18: safeguarding of individuals) |
| To provide trace information in the event of any debt. | Article 6(1)(f) – legitimate interest (debt recovery); Article 9(2)(f) – establishment, exercise or defence of legal claims (if special data used) |
| To improve and personalise your experience when you use any portals owned or delivered by us. | Article 6(1)(f) – legitimate interest |
| Direct marketing activities, but only where you have given us the permission to do so | Article 6(1)(a) – consent; Privacy and Electronic Communications Regulations (PECR) apply |
| Recording conversations you have with us | Article 6(1)(f) – legitimate interest (e.g. training, quality assurance, dispute resolution); notify data subjects appropriately |
| Capturing your image on our CCTV systems if you visit a neighbourhood, office or community facility which is covered by this facility. | Article 6(1)(f) – legitimate interest (e.g. safety, crime prevention); Article 9(2)(g) – substantial public interest if special category data captured |
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How and when will you hear from us
We may contact you by email, phone, text, WhatsApp or post—based on your preferences—to:
- Share important updates about your tenancy or our services
- Request feedback to help improve what we do
- Provide information relevant to your property or local community
You can opt out of communications at any time.
We may also send service messages without consent when necessary to:
- Deliver your housing services or tenancy
- Meet legal obligations (e.g. safety checks, rent statements)
- Protect vital interests (e.g. emergency repairs or safeguarding)
These are essential communications and are not considered marketing.
For more on your rights and how to manage preferences, see Section 11: Your Rights.
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How We May Share Your Data
We sometimes share your personal information with organisations that work with us or provide services on our behalf. When we do, we always comply with data protection laws to keep your information safe.
For sensitive information (such as health details), we usually ask for your consent before sharing, unless the law permits or requires us to share it without consent.
We only share data where there is a lawful basis under UK GDPR (Article 6), and if it includes special category data (like health, ethnicity, or religion), we follow extra safeguards under Article 9 and the Data Protection Act 2018.
We may share your data with:
- Contractors for repairs, maintenance, or improvements
- Local authorities (housing, social services, environmental health)
- Utility companies and council tax departments for billing
- Mortgage advisors or solicitors for home ownership matters
- Service providers (e.g. mailing houses, surveyors, debt recovery)
- Credit reference agencies (e.g. Experian for tenancy checks)
- Fraud prevention and public protection agencies
- Law enforcement, courts, and government departments (e.g. HMRC)
- Support organisations (health teams, homelessness services, Homes England, Housing Ombudsman)
Where data is shared for safeguarding or health reasons, we rely on legal conditions relating to public interest or social care.
This list is not exhaustive. If you want more details about who we share data with, please contact us via the details under “How to Contact Us.”
We will never sell or rent your personal information. When we share your data with third parties, we ensure:
- Only necessary information is shared
- They use your data only for the agreed purpose
- They respect and protect your privacy
- If we end their services, your data is deleted or anonymised
When working with third parties and sharing personal data, we have data processing and sharing agreements in place to ensure your information is handled securely and responsibly.
We are not responsible for how other organisations store or interpret the data we share. Any issues with a third party’s records should be raised directly with them.
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How Long We Keep Your Data
We keep your personal information only for as long as necessary to provide our services and to meet legal, accounting, or reporting obligations. We follow the National Housing Federation’s recommended retention periods and, in line with legal requirements, usually retain tenancy records for six years after your tenancy ends. Some records may be kept longer where required by law or to resolve disputes. A full retention schedule is available on request.
When deciding how long to keep data, we consider its type and sensitivity, the risk of harm if it’s misused, the purpose of processing, and any legal obligations.
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Using Drones to Capture Aerial Images of Our Homes
We are now using drones to capture aerial photographs and footage of our homes and neighbourhoods. These images will be used for communications purposes, such as on our website, social media, publications, or presentations to help showcase our work and communities.
We want to reassure residents and the public:
- Our focus is on buildings and landscapes, not individuals.
- We do not take close-up pictures of people. The drones are operated at a high altitude, so any people in the images appear as unidentifiable dots or blurs.
- If any person is clearly identifiable, we will blur them out before using or storing the images.
We’re Doing This Legally and Responsibly
We take privacy and safety seriously. Our drone operations fully comply with the following regulations:
- Civil Aviation Authority (CAA):
We follow the UK’s Air Navigation Order 2016 (as amended), including:
- Operating in line with CAP 722 (Unmanned Aircraft System Operations in UK Airspace)
- Registering drones over 250g with the CAA
- Ensuring pilots hold a valid Flyer ID
- Holding a valid Operator ID, clearly displayed on the drone
- Health and Safety at Work Act 1974:
All drone flights are planned and conducted with safety in mind to avoid any risk to people or property. - Data Protection Act 2018 and UK General Data Protection Regulation (UK GDPR):
We ensure that the collection, storage, and use of any video or photographic data fully complies with data protection laws.
If you have any questions or concerns about our drone use, please get in touch with us.
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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.
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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.
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Automated Decision Making
Under UK data protection law, you have the right not to be subject to decisions made solely by automated means if they have legal or similarly significant effects.
Lincolnshire Housing Partnership does not currently use automated decision-making or profiling under Article 22 of UK GDPR. All decisions about your tenancy, application, or services are made by a person.
If this changes in future, we will update this privacy notice and let you know your rights, including the right to request human review, express your views, or challenge the decision.
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Your Rights
Under the UK General Data Protection Regulation (UK GDPR), you have several rights in relation to your personal information. These rights are:
- Right to be informed – You have the right to know how and why we collect and use your data. This privacy notice provides that information.
- Right of access – You have the right to request a copy of the personal data we hold about you (commonly known as a Subject Access Request).
- Right to rectification – You can ask us to correct any inaccurate or incomplete personal data we hold about you.
- Right to erasure – In certain circumstances, you can ask us to delete your personal data (also known as the “right to be forgotten”).
- Right to restrict processing – You can ask us to limit how we use your data in certain situations, such as while we are correcting inaccurate data.
- Right to data portability – You can request your data in a commonly used, machine-readable format and ask us to transfer it to another organisation.
- Right to object – You can object to the use of your data for direct marketing, profiling, or where our lawful basis is legitimate interest or public task.
- Rights in relation to automated decision-making and profiling – You have the right not to be subject to decisions made solely by automated means that significantly affect you.
You can also talk to us about these by contacting us through the details provided under “How to Contact Us”.
If you feel that we have not answered a data query satisfactorily, or we have neglected to look after your personal data as we should, or we have failed to comply with your rights, you can raise the matter (once you have let us know) with the data regulator:
The Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline: 0303 123 1113
Website: https://ico.org.uk/concerns/
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How to Contact Us
For further information regarding your personal data, your rights under data protection law or about Lincolnshire Housing Partnership’s approach to data protection in general please contact our Data Protection Officer at:
Cartergate House,
26 Chantry Lane,
Grimsby,
North East Lincolnshire,
DN31 2LJ
(t) 0345 604 1472
(e) dataprotection@lincolnshirehp.com