Privacy Policy Keeping your data safe

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 describes our policies and practices regarding the collection and use of your personal data and sets out your rights under the Data Protection Act 2018 (which you might also know by the name GDPR).

This privacy policy tells you what to expect when we process your personal information. It applies to information about housing applicants, residents and other service users.  This is our main privacy notice, however, different regions may have additional privacy notices which will have been provided to you when you  registered. 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 recognize that the management of personal data and information privacy is an ongoing responsibility and we will be regularly reviewing and we will from time to time update this privacy policy as we undertake new personal data practices or adopt new privacy policies.

 

What is Personal Data?

Based on current legislation, personal data is classed as any information that directly relates and/or identifies you, whether directly or indirectly.

Under the EU’s General Data Protection Regulation:

Personal data is defined as “any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

Certain data are classified under the Regulation as “special categories”:

  • Racial
  • Ethnic origin
  • Political opinions
  • Religious beliefs
  • Trade-union membership
  • Genetic data
  • Biometric data
  • Health data
  • Data concerning a natural person's sex life
  • Sexual orientation
  • Other

 

Information we may need to collect from you and store for further use

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’.

We are committed to treating your information securely, with respect and in line with data protection law.

Information you give us

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 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 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 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. Please speak to us with any concerns.

Where enquiries relate to household members, it is in our legitimate interests to know who will be living in our 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 also obtain this from third parties - such as the local authority, your doctor (or other health professional), a previous landlord or other relevant community partner. In addition, we may also obtain information from publicly accessible sources - this would be used to enhance the existing information that we already hold.

 

How we use your information

We will process – that means collect, store and use – the information you provide in a manner that is compatible with our legal requirements, such as the Data Protection Act 2018 (which you may also know as GDPR). We will endeavor to keep your information accurate and up to date and will not keep it for longer than is necessary. In some instances, the law sets the length of time information has to be kept, but in most cases we will use our own procedural policy to ensure that we do not keep records outside business requirements.

Our aim is not to be intrusive, although in some cases we are required by law to collect data of a sensitive nature and we also try not to ask irrelevant or unnecessary questions. The information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Using your personal data

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

  • To assess housing applications, service eligibility and complete tenancy sign-ups.
  • To manage your tenancy or lease.
  • To meet your needs in delivering our services.
  • To prevent fraud and illegal sub-letting and to confirm eligibility for housing.
  • To assist with personal security and prevention and detection of crime.
  • To manage the legal process if you apply to buy your home or want to access another home ownership route.
  • When you engage with our additional guidance, advice and support services .
  • To meet our legal obligations including the requirements of our regulators.
  • To improve and personalise your experience when you use our any portals owned or delivered by us.
  • To improve our products and services and for the development of future products and services.
  • Direct marketing activities, where you have given us the permission to do so.
  • For internal record keeping and administration of records.

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 is in our ‘legitimate business interests’.

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.
  • Credit Reference agencies such as Experian as part of the Rental Exchange.  You can read the Rental Exchange Privacy Policy here.
  • Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative. More information can be found on the work undertaken by the Cabinet Office.
  • 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.
  • We may also share information when required by law for example where ordered by the Court or to protect an individual from immediate harm.
  • There may be occasions where we need to process your information outside of the European Economic Area (EEA), for example where we use a third party computer system supported by employees in the USA. Where we do this we will take all necessary steps to ensure that your information remains secure.  You can ask us for more information about how our International Processing arrangements affect you by using the contact details above.

 

Your Rights

The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects. A good explanation of them (in English) is available on the website of the Information Commissioner’s Office.

LHP under the General Data Protection Regulation provides the following rights for individuals in regard to their personal data:

  1. The right to be informed
  2. The right of access
  3. The right to rectification
  4. The right to erasure
  5. The right to restrict processing
  6. The right to data portability
  7. The right to object
  8. Rights in relation to automated decision making and profiling.

These collectively give you the rights to withdraw consent at any time where relevant.

 

The right to be informed

When we obtain your personal data, we have a duty to inform you how your data will be used.

The information we supply you is determined on whether we obtained the personal information from you directly or from another party. The Privacy Policy is set out to give you all the information you need to feel that you are well informed and that it is clear, concise, transparent, intelligible and easily accessible.

 

The right of access

You have a right to understand what personal data is being processed and have access to this personal information. This is usually referred to as a Subject Access Request (SAR).

When we receive a SAR we will provide a copy of the relevant information with 30 days of the request, when we have validated your identity and your rights to have this information.

If we are not able to respond to your request, we will explain why to you and inform you of your right to complain to the supervisory authority and to a judicial remedy. We will endeavour to do this without undue delay and at the latest within one month.

Please contact the Data Protection Office for more information.

 

The right to rectification

You have a right to have your personal data corrected if you believe there are inaccuracies or it is incomplete.

LHP will respond to rectification requests within 30 days of the request on validation of your identity and your rights to have this information rectified.

Where we are not taking action in response to a request for rectification, we will explain why and inform you of your right to complain to the supervisory authority and to a judicial remedy.

Please contact the Data Protection Office for more information.

 

The right to be forgotten

You have a right to have your personal data erased, this is also known as the right to be forgotten. This broad principle gives you the right to have your personal data removed if there is no compelling justification or legislative / regulatory reason to either retain your personal data or continue processing.

We will respond to erasure requests within 30 days of the request, once we have validated your identity and your right to have this information erased.

The right to erasure does not provide an absolute ‘right to be forgotten’. You have a right to have personal data erased and to prevent processing in specific circumstances:

  • Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
  • When the individual withdraws consent
  • When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
  • The personal data was unlawfully processed (ie otherwise in breach of the GDPR).
  • The personal data has to be erased in order to comply with a legal obligation

Where we are not taking action in response to a request for erasure, we will explain why and inform you of your right to complain to the supervisory authority and to a judicial remedy. 

Please contact the Data Protection Officer for more information

 

The right to restrict processing

You have a right to block or supress processing of your personal data under certain circumstance:

  • If you contest the accuracy of your personal data
  • If you object to the processing and are contesting the legitimate grounds LHP are using to process your personal data.
  • If processing is unlawful and you request restriction rather than erasure
  • If personal data is no longer used, but is needed to establish, exercise or defend a legal claim.

We will respond to restriction of processing requests within 30 days of the request, once we have validated your identity and your right to have this information rectified.

Where we are not taking action in response to a request to restrict processing, we will explain why and inform you of your right to escalate your complaint.

Please contact the Data Protection Officer for more information.

 

The right to data portability

You have a right to data portability, which allows you (in certain circumstances) to have your personal data ported across to another environment/organisation, in a safe and secure way, without hindrance to usability.

Please contact the Data Protection Officer for more information.

 

The right to object

You have a right to object to the processing of your personal data under certain circumstances.

We will respond to your objection within 72 hours, where we have validated your identity and your rights to object to your personal data being used.

If your objection is regarding direct marketing activity, we will stop processing your personal data in this way as soon as is practicable and within 7 days.

Please contact the Data Protection Officer for more information.

 

Transfers to other countries

As part of our offering, we may sometimes use third party service providers within the European Economic Area (the “EEA”) which are protected by the same or similar regulatory requirements as the UK. We may, on occasion, be required to transfer your personal data to countries outside of the EEA.

We ensure that any transfer to countries outside the EU are recognised as providing adequate level of protection for personal data, or has the provision of adequacies such as in the US (limited by the Privacy Shield Framework).

 

The right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint at any time with the Information Commissioner’s Office (ICO) 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.

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

Helpline: 0303 123 1113

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

You will always need to contact us in the first instance and you can get in touch with us by writing to us at:

The Data Protection Officer
Westgate Park
Charlton Street
Grimsby
North East Lincolnshire
DN31 1SQ

or by email at dataprotection@lincolnshirehp.com

 

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